MEMORANDUM

To: Interested Parties
From: Brendan Buck, PCMA
Re: PBM Reform is Done… Now What?
Date: February 3, 2026

Today’s the day. The House has passed PBM reform, and it will soon be signed into law, as part of the big government funding bill.

It’s a remarkable moment. Not for the impact on drug prices (higher). But rather because it is the culmination of a years-long effort by drugmakers to convince Congress that PBMs are the problem with high drug costs.

The pharmaceutical industry deserves serious credit for this campaign, which managed to persuade people that discounts are in fact bad, and PBM transparency, somehow, is the roadblock to falling drug prices.

It’s absurd on its face. But it worked. So good for them.

Such a feat of illogic takes a lot of time and money to pull off. And money they did spend. Over the last nearly decade, it has been impossible to escape the advertisements targeting lawmakers that point the finger at PBMs. The lobbying numbers are astonishing. Every newsletter in Washington has been purchased. And let’s not forget the dubious grants to random organizations for the purpose of turning uninterested nonprofits into rabid anti-PBM crusaders.

It’s what you can do when you have nearly unlimited resources to distract Washington from the problems you primarily have created.

The question today though is, “now what?” PBM reform is done. This boogeyman has been exorcised.

While drugmakers are quietly celebrating this achievement (they do in fact stand to make a lot more money from this law), they should also know that new oversight of their own actions is now coming.

It is long past time for lawmakers to look into the ways the pharmaceutical industry games the system to block competition and artificially keep drug prices high. Patent abuse, shadow pricing, direct to consumer advertisements, pay for delay, switching… the tactics are many. All of them in service of keeping prices high.

There are other players in the drug supply chain, such as the large wholesalers and their PSAOs, worthy of inquiry. But the time has come for drugmakers themselves to face the scrutiny they deserve.

PBMs have adapted on their own to respond to the market and policymakers. They have also now been regulated. The bad news for Pharma is it can no longer credibly run this game of distraction.