Federal Trade Commission: Legislation ‘More Likely to Undermine Competition’

Proposal Would Have Inflated Californians’ Rx Drug Bills by 7 Percent or $17 Billion

Measure Opposed by California Chamber of Commerce; California Manufacturers & Technology Association

Washington, DC; 09.30.04 — Faced with compelling evidence that one-size-fits-all PBM “disclosure” legislation would increase the cost of prescription drugs for California consumers and employers while providing no corresponding benefit, last evening California Governor Schwarzenegger vetoed AB 1960 and, in doing so, has sent a clear message to federal and state policymakers contemplating similar proposals, the Pharmaceutical Care Management Association (PCMA) said today. PCMA is the national association representing America’s pharmacy benefit managers (PBMs).

“PCMA applauds Governor Schwarzenegger for protecting California consumers and employers from higher prescription drug costs,” said PCMA President Mark Merritt. “Numerous reports â?? from the Federal Trade Commission to the Congressional Budget Office â?? have shown that mandated PBM disclosure would only undermine competition and increase prescription drug costs by billions of dollars. Given the proposal’s cost with no corresponding benefit, it’s hardly surprising the measure drew strong opposition from the California Chamber of Commerce and the California Manufacturers & Technology Association. By vetoing AB 1960, Governor Schwarzenegger has done the right thing for California consumers and employers.”

Under the guise of “disclosure,” AB 1960 would have undermined PBMs’ ability to negotiate deep discounts for California consumers and employers by effectively mandating public disclosure of proprietary contracting information. Public disclosure of PBM contracting information would give more pricing power to drug manufacturers and create artificial price floors. AB 1960 would have harmed California consumers by undermining PBMs’ ability to utilize a full array of quality improvement tools they rely upon to help consumers. Lastly, AB 1960 would have harmed California employers by eliminating flexibility in contracting for PBM clients by locking in place a one-size-fits-all approach to prescription-drug benefits administration.

Numerous reports and data document the increased costs to consumers and employers associated with mandated PBM disclosure. Specifically:

Federal Trade Commission’s Office of Policy Planning, Bureau of Competition, & Bureau of Economics. In a September 3, 2004 letter to California Assembly Member Greg Aghazarian, the Federal Trade Commission’s Office of Policy Planning, Bureau of Competition, and Bureau of Economics examined AB 1960 and concluded the measure “is more likely to undermine competition than promote it.” Furthermore, AB 1960 “may have the unintended consequence of limiting competition, thus increasing the cost of pharmaceuticals and ultimately decreasing the number of Americans with coverage for pharmaceuticals.”
PricewaterhouseCoopers. In a July 2004 report, PricewaterhouseCoopers estimated that a disclosure provision similar to that contained in AB 1960 would increase prescription drug costs in California by 7 percent â?? or more than $17 billion over the next ten years. In addition, PricewaterhouseCoopers estimates that another provision in AB 1960, limiting therapeutic interchange, would increase costs by 5.2 percent, or more than $13 billion from 2005-2014.
Congressional Budget Office: During last year’s Medicare prescription drug debate, the Congressional Budget Office estimated that public disclosure of drug price negotiation information would increase the cost of the Medicare drug benefit by $40 billion over ten years and increase Medicare beneficiaries’ part D premiums by more than five percent in 2006 alone. The Medicare public disclosure provision was ultimately rejected by Congress.
With the veto of AB 1960, California becomes the tenth state this year to reject mandated PBM disclosure legislation. Similar proposals have been rejected this year in New York, Florida, Washington state, Maryland, Minnesota, Mississippi, Kansas, Iowa, and Vermont. A similar measure passed in Maine last year has been blocked from taking effect by the US District Court, while in the District of Columbia, PCMA is seeking to enjoin Title II of the DC Access Rx Act of 2004. In addition to DC, South Dakota has passed mandated PBM disclosure legislation in 2004.

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1. Letter to California Assembly Member Greg Aghazarian. Federal Trade Commission’s Office of Policy Planning, Bureau of Competition and Bureau of Competition. September 3, 2004. Available at http://www.ftc.gov/opa/2004/09/capbm.htm
2. PricewaterhouseCoopers, “The Value of Pharmacy Benefit Management and the National Cost Impact of Proposed PBM Legislation,” July 2004. Commissioned by PCMA. Available at www.pcmanet.org
3. Congressional Budget Office, “Cost Estimate of HR 1, Medicare Prescription Drug and Modernization Act, and S 1, Prescription Drug and Medicare Improvement Act of 2003,” Page 15. July 22, 2003.

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The Pharmaceutical Care Management Association (PCMA) is the national trade association representing America’s pharmaceutical benefit managers (PBMs). PCMA member companies provide pharmaceutical care management services to more than 200 million Americans.

Contact Information:
Phil Blando
202-207-3614

Washington, DC; 09.28.04 — Mark Merritt, President of the Pharmaceutical Care Management Association (PCMA) released the following statement regarding the ongoing debate on Medicare’s draft formulary model guidelines issued by the US Pharmacopeial Convention (USP). PCMA is the national association representing America’s pharmacy benefit managers (PBMs):

” In the current debate over the USP formulary recommendations, some advocacy groups assert that any Medicare formulary must include hundreds and hundreds of narrow therapeutic drug categories and classes—virtually assuring that each and every drug on the market would be covered without regard to clinical evidence and cost-effectiveness. In reality, this approach does not reflect standard—and successful—approaches widely used the commercial marketplace, where formularies with 50 to 100 meaningful therapeutic classes provide access to a broad range of prescription drugs while encouraging price competition among therapeutically similar products.

” The reason PBMs were envisioned as playing a central role in the new Medicare drug benefit is simple: PBMs have proven successful in the commercial market at managing drug benefits for more than 200 million Americans, including two-thirds of seniors. PBM clinical and cost-management tools—including formularies—provide broad access to drugs while reducing costs an average 25 percent, according to PricewaterhouseCoopers. Implementing a Medicare formulary with hundreds and hundreds of therapeutic classes would, in fact, jeopardize the long-term viability of the program and put seniors’ access to medications at risk.

“There are five basic reasons Medicare should look to what has worked in the commercial marketplace as the best pathway to affordability and access in the new Medicare drug benefit:

Plan sponsors will compete for enrollees based on attractive offerings, including high-quality formularies. Information on drugs covered in the formulary will be readily available to new and existing enrollees. Plans will have strong incentives to cover widely used products in order to attract and retain enrollees.
Plan sponsors will rely on clinical evidence first and foremost when developing formularies. Independent, expert panels of clinical experts known as Pharmacy and Therapeutics Committees will guide formulary development. A P&T Committee’s primary consideration in the development of a formulary is clinical appropriateness. In cases where there are therapeutically equivalent drugs, the PBM will evaluate the most cost-effective alternative, which will be recommended for placement on the formulary.
As proven in the commercial marketplace, formularies provide broad access to prescription drugs. According to a 2003 study by the Government Accountability Office, competitive PBM-administered programs offered to federal employees generally featured ‘non-restrictive drug formularies’ that included ‘coverage of most drugs.’ In short, enrollees generally enjoyed ‘unrestricted access to prescription drugs,’ according to GAO.
Effective formularies are essential to maintaining an affordable drug benefit. In 2005, pharmacy benefit management activities—including formularies—will reduce prescription drug costs by $937 per Medicare beneficiary in private plans, or about $18 billion, according to PricewaterhouseCoopers. These data apply to beneficiaries with prescription drug coverage provided through private plans, including Medicare Advantage health plans, Medicare supplemental policies, and employer-sponsored retiree coverage.
The Centers for Medicare and Medicaid Services (CMS) will have extensive oversight of the new Medicare drug benefit, including approving each drug plan’s formulary, before it can participate in Medicare. The agency stated in the rules proposed to govern the new benefit that “it is our expectation that plans’ formularies will provide Part D enrollees a comprehensive benefit â?? one that covers an amount and variety of drugs sufficient to treat all disease states.”
” America’s seniors deserve a Medicare prescription drug benefit that builds upon PBMs’ proven success in the commercial marketplace in striking the right balance between cost, access, and quality. PCMA and its member companies will continue to work with beneficiaries, policymakers, and others to ensure that marketplace tools and techniques can be used to bring all seniors the same broad access to prescription drugs enjoyed by vast majority of Americans.”

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The Pharmaceutical Care Management Association (PCMA) is the national trade association representing America’s pharmaceutical benefit managers (PBMs). PCMA member companies provide pharmaceutical care management services to more than 200 million Americans.

Contact Information:
Phil Blando
202-207-3614

CMS Report Lauds Generic Substitution, E-Prescribing, Disease Management Programs As Key to Lowering Drug Costs, Improving Quality

Washington, DC; 09.20.04 — A recent report from the Centers for Medicare and Medicaid Services (CMS) identifying safe and effective approaches to lowering states’ Medicaid prescription drug costs recognizes many of the tools pioneered by pharmacy benefit managers and suggests that many states have yet to realize their full cost-savings and quality-improvement potential, the Pharmaceutical Care Management Association (PCMA) said today. PCMA is the national association representing America’s pharmacy benefit managers (PBMs).

“CMS has recognized that even though state Medicaid programs don’t save as much as they could if they used the full range of PBM tools, they still generate substantial savings and quality improvements through generic substitution, e-prescribing, and disease management programs,” said PCMA President Mark Merritt. “This new CMS analysis is only the latest in a series of reports â?? from the Government Accounting Office, the Congressional Budget Office, the Federal Trade Commission, and others â?? about the effectiveness of PBMs and adds to the growing body of evidence about the value PBMs add to the system.”

The report, “Safe and Effective Approaches to Lowering State Prescription Drug Costs: Best Practices among State Medicaid Drug Programs,” was published by CMS on September 9, 2004. The paper explains that states have implemented a variety of cost-containment mechanisms that have allowed them to reduce pharmacy expenditures and maintain beneficiary access to vital health care services. Yet, the report notes that “in general, states have not yet taken advantage of all of these approaches.”

The paper identifies four key strategies for states to lower their prescription drug costs and improve quality for Medicaid beneficiaries:

Generic Substitution. CMS notes that the “potential cost savings that can be achieved by the use of generic drugs has prompted 39 states to require that the generic version of a drug be dispensed to Medicaid beneficiaries when one is available. Under these mandatory generic substitution policies, the brand name drug remains available to beneficiaries through prior authorization.” While broadly available in the commercial marketplace, CMS notes that generics “are not as widely used in some Medicaid programs” â?? even though the savings compared to brand-name drugs can be substantial. The report notes that the state of Minnesota expects to save $10 million annually through its generic substitution program. Similarly, CMS notes that the state of Idaho’s program has saved $11.7 million in state and federal funds and that “pharmacy groups in the state have been very supportive of the state’s generic substitution policy.”
Disease Management Programs in Medicaid. CMS notes that “disease management programs are an emerging strategy for states to reduce overall expenditures, including drug expenditures, through more appropriate medication use for Medicaid beneficiaries with chronic illnesses. These programs usually include adherence to evidence-based practice guidelines, provide support services to assist physicians in monitoring their patients, more closely manage patient care including the proper use of drugs, and promote patient adherence to an individual treatment plan, which includes improved medication compliance.” The CMS report highlights a Washington state initiative which is helping 175,000 non-managed care Medicaid beneficiaries manage complex and chronic conditions â?? including asthma, congestive heart failure, diabetes, and end-stage renal disease â?? through preventive care and patient education and is expected to save the state 5 percent annually on overall medical costs for program participants. In North Carolina, the state’s Community Care program is relying upon 2,000 physicians to work collaboratively with local health departments, hospitals, and social service agencies to help manage the care of 513,000 Medicaid beneficiaries. The program’s Pharmacy Management Initiative has lowered prescription drug costs of participants by 22 percent through the use of a preferred drug list and is expected to save $9 million in 2004 through its drug utilization review program.
E-prescribing. The CMS report highlights a Florida e-prescribing initiative that allows prescribing physicians to prescribe a medication that is on the state’s preferred drug list, to access clinical information about prescription drugs, and to receive patient medical histories that help detect adverse drug interactions and drug allergies. Currently, 1000 prescribers use e-prescribing technology and the state expects to expand the number to 3000, thereby allowing for 80 percent of the drugs to be e-prescribed in Florida. CMS notes that e-prescribing will “improve medical care, reduce cost, and prevent fraud and abuse.” CMS also notes that e-prescribing “has resulted in less inappropriate or duplicative prescribing (polypharmacy), a reduction in severe drug interactions, and fraud detection from individuals seeking narcotics prescriptions from multiple physicians.”
Supplemental Rebate Agreements. The CMS report details have a variety of options states have available in driving down prescription drug prices. In addition to rebates received under the national drug rebate agreement, states may also negotiate state-specific supplemental rebates for their Medicaid population or participate in a multi-state pooling supplemental rebate agreement. According to CMS, 33 states are receiving Medicaid supplemental rebates in additional to those received under the National Rebate Agreement.

The full CMS report may be accessed at http://www.cms.hhs.gov/medicaid/drugs/strategies.pdf

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The Pharmaceutical Care Management Association (PCMA) is the national trade association representing America’s pharmaceutical benefit managers (PBMs). PCMA member companies provide pharmaceutical care management services to more than 200 million Americans.

Contact Information:
Phil Blando
202-207-3614

CMS Report Lauds Generic Substitution, E-Prescribing, Disease Management Programs As Key to Lowering Drug Costs, Improving Quality

Washington, DC; 09.20.04 — A recent report from the Centers for Medicare and Medicaid Services (CMS) identifying safe and effective approaches to lowering states’ Medicaid prescription drug costs recognizes many of the tools pioneered by pharmacy benefit managers and suggests that many states have yet to realize their full cost-savings and quality-improvement potential, the Pharmaceutical Care Management Association (PCMA) said today. PCMA is the national association representing America’s pharmacy benefit managers (PBMs).

“CMS has recognized that even though state Medicaid programs don’t save as much as they could if they used the full range of PBM tools, they still generate substantial savings and quality improvements through generic substitution, e-prescribing, and disease management programs,” said PCMA President Mark Merritt. “This new CMS analysis is only the latest in a series of reports â?? from the Government Accounting Office, the Congressional Budget Office, the Federal Trade Commission, and others â?? about the effectiveness of PBMs and adds to the growing body of evidence about the value PBMs add to the system.”

The report, “Safe and Effective Approaches to Lowering State Prescription Drug Costs: Best Practices among State Medicaid Drug Programs,” was published by CMS on September 9, 2004. The paper explains that states have implemented a variety of cost-containment mechanisms that have allowed them to reduce pharmacy expenditures and maintain beneficiary access to vital health care services. Yet, the report notes that “in general, states have not yet taken advantage of all of these approaches.”

The paper identifies four key strategies for states to lower their prescription drug costs and improve quality for Medicaid beneficiaries:

Generic Substitution. CMS notes that the “potential cost savings that can be achieved by the use of generic drugs has prompted 39 states to require that the generic version of a drug be dispensed to Medicaid beneficiaries when one is available. Under these mandatory generic substitution policies, the brand name drug remains available to beneficiaries through prior authorization.” While broadly available in the commercial marketplace, CMS notes that generics “are not as widely used in some Medicaid programs” â?? even though the savings compared to brand-name drugs can be substantial. The report notes that the state of Minnesota expects to save $10 million annually through its generic substitution program. Similarly, CMS notes that the state of Idaho’s program has saved $11.7 million in state and federal funds and that “pharmacy groups in the state have been very supportive of the state’s generic substitution policy.”
Disease Management Programs in Medicaid. CMS notes that “disease management programs are an emerging strategy for states to reduce overall expenditures, including drug expenditures, through more appropriate medication use for Medicaid beneficiaries with chronic illnesses. These programs usually include adherence to evidence-based practice guidelines, provide support services to assist physicians in monitoring their patients, more closely manage patient care including the proper use of drugs, and promote patient adherence to an individual treatment plan, which includes improved medication compliance.” The CMS report highlights a Washington state initiative which is helping 175,000 non-managed care Medicaid beneficiaries manage complex and chronic conditions â?? including asthma, congestive heart failure, diabetes, and end-stage renal disease â?? through preventive care and patient education and is expected to save the state 5 percent annually on overall medical costs for program participants. In North Carolina, the state’s Community Care program is relying upon 2,000 physicians to work collaboratively with local health departments, hospitals, and social service agencies to help manage the care of 513,000 Medicaid beneficiaries. The program’s Pharmacy Management Initiative has lowered prescription drug costs of participants by 22 percent through the use of a preferred drug list and is expected to save $9 million in 2004 through its drug utilization review program.
E-prescribing. The CMS report highlights a Florida e-prescribing initiative that allows prescribing physicians to prescribe a medication that is on the state’s preferred drug list, to access clinical information about prescription drugs, and to receive patient medical histories that help detect adverse drug interactions and drug allergies. Currently, 1000 prescribers use e-prescribing technology and the state expects to expand the number to 3000, thereby allowing for 80 percent of the drugs to be e-prescribed in Florida. CMS notes that e-prescribing will “improve medical care, reduce cost, and prevent fraud and abuse.” CMS also notes that e-prescribing “has resulted in less inappropriate or duplicative prescribing (polypharmacy), a reduction in severe drug interactions, and fraud detection from individuals seeking narcotics prescriptions from multiple physicians.”
Supplemental Rebate Agreements. The CMS report details have a variety of options states have available in driving down prescription drug prices. In addition to rebates received under the national drug rebate agreement, states may also negotiate state-specific supplemental rebates for their Medicaid population or participate in a multi-state pooling supplemental rebate agreement. According to CMS, 33 states are receiving Medicaid supplemental rebates in additional to those received under the National Rebate Agreement.

The full CMS report may be accessed at http://www.cms.hhs.gov/medicaid/drugs/strategies.pdf

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The Pharmaceutical Care Management Association (PCMA) is the national trade association representing America’s pharmaceutical benefit managers (PBMs). PCMA member companies provide pharmaceutical care management services to more than 200 million Americans.

Contact Information:
Phil Blando
202-207-3614

In 2005, PBMs to Save Each Medicare Beneficiary with Drug Coverage Through Medicare Advantage, Employer-Sponsored Retiree Coverage$937 Dollars on Cost of Prescriptions

Washington, DC; 09.14.04 —Testifying today before the Senate Finance Committee on proposed rules governing the new Medicare prescription drug benefit, PCMA President & CEO Mark Merritt said preserving PBMs’ proven cost containment and quality improvement techniques for beneficiaries “should be job one” and identified six key areas that could challenge effective PBM participation in the Medicare drug benefit, the Pharmaceutical Care Management Association (PCMA) said today. PCMA is the national association representing America’s pharmacy benefit managers (PBMs).

“In the commercial marketplace, PBMs have relied upon a broad range of tools and techniques to expand access, promote quality, improve outcomes, and drive down the cost of prescription drugs,” said Mr. Merritt in remarks before the Senate Finance Committee. “Preserving PBMs’ ability to participate effectively in Medicare should be job one going forward. Without the effective participation of PBMs in Medicare, the cost of the drug benefit could skyrocket and seniors could face higher premiums and out-of-pocket costs.”

According to a new analysis conducted by PricewaterhouseCoopers, PBMs drive down the cost of prescription drugs, on average, by 25 percent. Medicare beneficiaries enrolled in private plans are also seeing real savings from PBMs. Next year, in 2005, PricewaterhouseCoopers estimates that PBMs will save $937 dollars for each Medicare beneficiary with drug coverage provided through private plans, including Medicare Advantage plans and employer-sponsored retiree coverage.

Mr. Merritt also highlighted for the Committee six key issue areas in the regulatory process that could challenge effective PBM participation in the new Medicare drug benefit:

Formularies. PCMA has been monitoring closely the process of the US Pharmacopeia (USP) in developing model formulary categories and classes. While PCMA believes the USP’s proposed model formulary structure is somewhat overly detailed, it can, nonetheless, serve as a starting point for formulary development. PCMA believes it is not necessary, however, to expand further the number of categories and classes contained within the USP proposal. For example, formularies in the commercial marketplace with 80 to 90 categories of drugs can provide coverage for 500 or more different drugs.

Pharmacy & therapeutics (P&T) committees. In developing clinically-sound formularies, PBMs rely upon panels of experts, called Pharmacy and Therapeutics (P&T) committees, to make formulary recommendations and develop lists of preferred drugs. PCMA has concerns regarding the implication in the proposed rule that CMS is considering investing P&T committees with broad authority â?? beyond their areas of expertise â?? over administration of the entire drug benefit offered by a prescription drug plan. P&T committees do not typically have the broad financial and administrative management expertise necessary to administer drug benefits.

E-prescribing. PCMA commends the Administration and Members of Congress from both sides of the aisle for the assertive stance they have adopted on the development of e-prescribing. E-prescribing holds the promise of reducing drug-related medical errors and improving safety through the application of enhanced technology. As the Centers for Medicare & Medicaid Services (CMS) work to implement e-prescribing standards into Medicare, CMS must protect the PBM e-prescribing infrastructure that is the most sophisticated in health care today.

Confidentiality of proprietary contracting information. Maintaining confidentiality in proprietary contracting and drug price negotiation — including in the new Medicare drug benefit — is essential to preserving PBMs’ ability to negotiate discounts for consumers and purchasers. Going forward, a clear distinction should be drawn between disclosure of proprietary contracting information and the cost of a prescription to the beneficiary. Public disclosure of proprietary contract terms between PBMs, drug manufacturers, and retailers would dramatically alter the competitive landscape by giving competitors access to proprietary price negotiation strategies and, in turn, increase the cost of prescription drugs. The Congressional Budget Office has estimated that public disclosure of proprietary contracting information would increase the cost of the Medicare drug benefit by $40 billion over ten years and increase Medicare beneficiaries’ part D premiums by more than five percent in 2006 alone.

Appropriate program oversight and beneficiary protection, not micromanagement. PCMA believes the success of the new drug benefit will depend in no small measure on the active participation of PBMs. PCMA members have the knowledge, experience, and infrastructure that is essential for administering this new benefit. Given this record and the extremely short time frame for implementation of the new program, it is critical that the regulations not impose considerable new burdens or require significant changes in the way PBMs currently conduct their business in the commercial marketplace.

Risk in stand-alone drug benefit. PCMA is encouraged by recent comments made by Administrator McClellan regarding predictability and encouraging participation in the stand-alone drug benefit. This, coupled, with preserving existing PBM tools, is the key to maximizing participation in the stand-alone benefit.

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The Pharmaceutical Care Management Association (PCMA) is the national trade association representing America’s pharmaceutical benefit managers (PBMs). PCMA member companies provide pharmaceutical care management services to more than 200 million Americans.

Contact Information:
Phil Blando
202-207-3614

Washington, DC; 09.09.04 — A new, open letter from the independent pharmacy lobby crowing about their record profits and gross margins despite the “bad news” of a Medicare drug benefit and discount drugs cards shows once again that the independent pharmacy lobby is more concerned about protecting their bottom line than helping seniors access affordable prescription drugs, the Pharmaceutical Care Management Association (PCMA) said today. PCMA is the national association representing America’s pharmacy benefit managers (PBMs).

“For the past five years, the independent pharmacy lobby has opposed effort after effort to make prescription drugs more affordable and accessible for seniors,” said PCMA President Mark Merritt. “Now they’re crowing about ‘thriving’ with record profits and sales despite the ‘bad news’ of the Medicare drug benefit. Instead of pining for days gone by when they could charge seniors and the uninsured the highest drug prices of all consumers, the independent pharmacy lobby should work collaboratively with seniors, PBMs, health plans, and others to make prescription drugs more affordable for all Americans.”

The open letter from the National Community Pharmacists Association (NCPA) is running in the current issue of at least one trade magazine. In the letter, the NCPA laments “all of the ‘bad ‘news’ that bombards us on a daily basis in our pharmacies,” including the mail-service pharmacy option, the Medicare drug benefit, and Medicare drug discount cards. The NCPA goes on to note that “despite all the negative forces at work against us, independents are doing a great job of surviving and thriving.”

And ’surviving and thriving’ they are. This past June, the NCPA released data today from their forthcoming report, 2004 NCPA-Pfizer Digest. The report is funded by an unrestricted grant from Pfizer, Inc. The report confirms that independent pharmacies raked in record profits and sales in 2003. Among the key findings from their own presentation, “Independent Pharmacy Today:”

· In 2003, independent pharmacy comprised a $77 billion marketplace. Nearly 60 percent of independent pharmacies reported sales of more than $2.5 million; with 30 percent reporting sales of more than $4 million;
· Total store sales climbed at a double-digit growth rate in 2003, up 12 percent from 2002;
· Independent pharmacy prescription sales increased 10 percent in 2003, compared to 2002;
· Independent pharmacy gross margins stood at 23.8 percent in 2003, the second consecutive annual increase;
· Independent pharmacy net profit is at its highest levels in at least ten years; and
· The number of independent pharmacies increased in 2003 to 23,956 pharmacies

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The Pharmaceutical Care Management Association (PCMA) is the national trade association representing America’s pharmaceutical benefit managers (PBMs). PCMA member companies provide pharmaceutical care management services to more than 200 million Americans.

Contact Information:
Phil Blando
202-207-3614