A Six-Step Solution to the PBM Problem

Health Affairs Blog, Aug. 30, 2018

3 Pages Posted: 12 Oct 2018

Date Written: August 30, 2018


In the past year, pharmacy benefit managers (PBMs) have catapulted into public attention. While PBMs initially helped patients by reducing burdens and lowering price, today they are doing the opposite.

This short piece outlines 6 steps that could address the PBM problem. Congress can take four:

(1) ban gag clauses;

(2) require the disclosure of rebates and other financial benefits;

(3) prohibit retroactive fees charged to pharmacies; and

(4) address conflicts of interest between PBMs and pharmacies.

The government agencies can take the other two:

(5) robust merger enforcement; and

(6) a 6(b) FTC study.

Keywords: PBM, pharmacy benefit manager, drug pricing, rebates

JEL Classification: I18, K21, L40, L41, L43, L65, O34, O38

Suggested Citation

Carrier, Michael A., A Six-Step Solution to the PBM Problem (August 30, 2018). Health Affairs Blog, Aug. 30, 2018, Available at SSRN: https://ssrn.com/abstract=3251536

Michael A. Carrier (Contact Author)

Rutgers Law School ( email )

217 North Fifth Street
Camden, NJ 08102-1203
United States
856-225-6380 (Phone)
856-225-6516 (Fax)

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