Comment on CMS-2026-2212-0001
Blue Cross and Blue Shield AssociationSupportTrade association
Summary: The Blue Cross Blue Shield Association (BCBSA) supports CMS's efforts to implement Section 6224 of the CAA, 2026, to improve transparency in PBM compensation. They recommend a narrow, function-based definition of PBMs and affiliates, the preservation of bona fide service fee frameworks, and the use of arm's-length transactions or independent valuations to determine fair market value.
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