West Health Comments on the Business Practices of PBMs

On behalf of West Health Policy Center, Sean Dickson responds to the FTC's request for comments on Pharmacy Benefit Managers (PBMs). The Center emphasizes PBMs’ vital role in reducing drug prices and addresses concerns about their business practices. The letter highlights the complex pharmaceutical market structure and the need for PBM consolidation to negotiate lower prices. It discusses the dynamics between PBMs, pharmaceutical manufacturers, and employers, offering insights into regulatory frameworks. Recommendations include supporting policies that maintain PBM negotiating power, strengthen employer-PBM relationships, extend transparency requirements, and promote generic utilization.