Key Talking Points:
- Removing or Eliminating Safe Harbors would Increase Costs
- PBM-Negotiated Rebates Reduce Costs
- Bottom Line on Prescription Drug Rebates
- Part D Point of Sale Pitfalls
- PBMs Do Not Support Clawback or Gag Clauses
Key Comment Letters and Related Materials:
- PCMA Comments on the 2019 Part D NPRM and RFI
- Addressing Point of Sale Rebates and DIR in CMS Proposed Rule and RFI
- Implementation Issues for Mandatory Rebates at POS
- Milliman Analysis: Medicare Part D Program Characteristics that Affect Plan Sponsor Margin
- Part D Bid Submission Timeline
Materials for Stakeholder Outreach:
Key Research, Infographics, and Other Materials
Rebates/DIR/Profits in Part D
- Medicare Trustees: Trend in Rebates vs. Administrative Costs in Part D
- Milliman Study: Value of DIR: Impact on Medicare Part D
- PCMA Member Survey: The Impact of POS Rebates and POS Pharmacy DIR
- Infographic: How Medicare Part D DIR Works
Rebates and Price Increases
- Visante Study: Increasing Prices Set by Drug Makers Not Correlated With Rebates
- Visante Study: No Correlation Between Increasing Drug Prices and Manufacturer Rebates in Major Drug Categories
- PCMA Infographic: Study Shows No Correlation Between Drug Rebates and Price Increases
International Drug Prices
PBM Value Proposition, Best Practices, and Competition
- The Return on Investment (ROI) on PBM Services
- Entities Providing PBM Services in the U.S.
- Infographic: PBM Best Practices
- Infographic: PBMs Save Patients and Plans
- Infographic: PBMs Save on Prescription Costs
- PCMA Statement to the FTC on Competition
Key Research on Rebates from Third Parties:
- For discussion of rebates being correlated to product uniqueness see Credit Suisse, Figure 2, “Relationship Between Product Uniqueness and Rebates”
- For general discussion of rebates and PBMs, see Altarum Institute “The Impact of Prescription Drug Rebates on Health Plans and Consumers” April 2018
