In this comment letter PCMA is concerned that SB 38 creates costly and unnecessary regulation. SB 38 gives the director of the Division of Insurance unprecedented power to interfere in private contracts. SB 38 also establishes restrictions on audits done by PBMs to ensure that pharmacies are not engaging in fraudulent activities and to ensure that health care payers are getting what they pay for. The use of the term “multi-source generic drug” in the proposal will limit the types of generic drugs that can be reimbursed under a maximum allowable cost (MAC) methodology.