This comment letter was submitted by PCMA in opposition to HB 944 which establishes the state auditor general’s authority to audit specified contracts that are downstream from the Department of Human Services’ (DHS) in Medicaid, and sets new contracting requirements in the delivery of the Medicaid pharmacy benefit. Last fall, changes made to contracts between DHS, Medicaid Managed Care Organizations (MCOs), and PBMs brought greater transparency to these relationships and to the Medicaid program, and created significant reporting obligations for PBMs and MCOs on pharmacy encounters, including reimbursements.