Comment on CMS-2026-2212-0001
Johnson & JohnsonSupportBusiness
Summary: Johnson & Johnson Innovative Medicine supports the RFI but argues that CMS should not use a market-based approach to determine Fair Market Value for PBM fees. They contend that because the PBM market is not properly competitive, market-based rates reflect the intermediaries' leverage rather than actual value, and they urge CMS to ensure definitions are prospective rather than retroactive.
See attached for comment letter.