Dear APCI members,

The U.S. Federal Trade Commission has issued a Request for Information on how Pharmacy Benefit Managers affect drug affordability and access. The commission wants to know how PBMs affect patients, physicians, employers, and independent pharmacies on a wide range of issues, including contract terms, rebates, fees, pricing policies, steering methods, conflicts of interest, and consolidation.

APCI is asking our members to please share your specific experiences as a pharmacist or pharmacy owner as to how PBM practices have negatively affected your patients or your pharmacy. The goal of these comments is to provide the FTC with enough valid information to launch a full-scale study into unfair PBM practices. Submitting effective comments is the first step toward meaningful PBM regulation at the federal level.

When submitting your comments, please keep the following guidelines in mind:

• Read the full Request for Information (available here) and consider how your comments will best meet the commission's needs.
• Include information about yourself and your pharmacy in your comments (i.e., My name is John Smith and I am the owner of Smith Drugs in Anytown, USA).
• Keep your comments factual and focused on the request for information. This is not a forum to slam the FTC or simply rant about PBMs. Constructive comments are the most likely to have an influence on regulators.
• There is no minium or maximum length for an effective comment. Be concise, but support your claims with substantive data and personal experiences.
• Don't feel obligated to comment on every issue raised by the FTC. Limit your comments to the issues that most strongly concern your pharmacy and your patients.
• Comments on the economic effects of PBM practices are especially helpful.
• Do not include any information in your comments that would violate HIPAA statues or contract terms.

The deadline for comment submission is April 25, so submit your comments today!