CMS Seeks Input on PBM Compensation Restrictions and Data Reporting for 2028 Implementation
CMS issued a request for information on pharmacy benefit manager compensation structures and business practices to inform implementation of new legislative requirements. The RFI focuses on two mandates taking effect in 2028: restrictions on remuneration PBMs and affiliates may receive for services related to Part D drug utilization, and new data reporting requirements. CMS is seeking technical input on PBM service arrangements, affiliate relationships, and compensation models. Comments will shape how CMS defines permissible PBM compensation and structures data collection requirements for Medicare Part D plans.
Medicaid managed care organizations with integrated Part D plans or pharmacy benefit arrangements structured similarly to Medicare will need to monitor the resulting compensation restrictions and reporting requirements, as state Medicaid programs increasingly scrutinize PBM arrangements and may adopt parallel transparency and compensation limitations.
Pharmacy · Managed Care
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