Comment on CMS-2026-2212-0001

American Pharmacists AssociationSupportTrade association
Summary: The American Pharmacists Association (APhA) supports the RFI's goal of regulating PBM compensation and data collection. They urge CMS to use a broad definition of PBMs and "affiliates," strictly define "bona fide service fees" to exclude those tied to drug prices or volume, and ensure reporting requirements are comprehensive and harmonized with other federal rules.
Dear Secretary Kennedy and Administrator Oz, The American Pharmacists Association (APhA) appreciates the opportunity to provide HHS and CMS comments on the “Request for Information (RFI): Pharmacy Benefit Manager (PBM) Compensation and Data Collection.” APhA represents pharmacists, student pharmacists, and pharmacy technicians in all practice settings, including but not limited to community pharmacies, hospitals, long-term care facilities, specialty pharmacies, community health centers, physician offices, ambulatory clinics, managed care organizations, hospice settings, and government facilities. Our members strive to improve medication use, advance patient care, and enhance public health. Full comments are attached.

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