Comment on CMS-2026-2212-0001
HealthHIVSupportAdvocacy
Summary: HealthHIV supports the effort to reform Pharmacy Benefit Manager (PBM) compensation in Medicare Part D but urges CMS to ensure that reforms do not simply shift costs to patients or other parts of the system. They advocate for rigorous oversight of "fair market value" fees, the establishment of firm guardrails on incentive payments, and the collection of data on patient-facing measures like medication access and out-of-pocket costs.
HealthHIV appreciates the opportunity to comment on CMS’ Request for Information regarding Pharmacy Benefit Manager Compensation and Data Collection. And we support Congress’ effort to reform Pharmacy Benefit Manager (PBM) compensation in Medicare Part D. The effectiveness of that reform, though, will depend on whether CMS can prevent the same economic incentives from reappearing elsewhere in the system—through other various and differently-labeled service fees, incentive payments or transactions involving affiliated companies. We have seen in other areas, as with copay accumulator programs, how changes in payment policy can shift costs elsewhere in the system and ultimately affect patient access and out-of-pocket expenses. With this rule-making, we raise that as a similarly vital implementation concern.