Comment from Matthew Seiler (Vice President and General Counsel at the National Community Pharmacists Association)

Summary: The National Community Pharmacists Association (NCPA) supports the development of updated collaboration guidelines, provided they clearly distinguish between procompetitive integration and anticompetitive price-fixing. They specifically urge the Agencies to address horizontal price-fixing by Pharmacy Benefit Managers (PBMs) that use algorithms or shared platforms to suppress pharmacy reimbursements.