Comment on CMS-2026-2212-0001

Summary: CVS Health supports the Request for Information but urges CMS to adhere strictly to the statutory language of the CAA 2026 to avoid overbroad interpretations of PBM compensation and "affiliate" definitions. They advocate for clear, workable definitions of "bona fide service fees" and "fair market value," and request that CMS avoid imposing additional data reporting requirements beyond those already mandated by statute.