Over the last few years, Congress has tried to pass some type of reform of pharmacy benefit managers (PBMs). There continues to be bipartisan agreement on the need for change in PBMs’ business practices, but little agreement on what that should look like.

The House recently passed a reconciliation bill that contains some measures — including the prohibition of spread pricing in Medicaid, transparency requirements in Medicare Part D, and a measure that would require a flat fee payment structure for PBMs in Medicare Part D — some suggest these measures are unlikely to have a significant impact on the supply chain.

In the void left by the absence of reform at the national level, states have stepped in to regulate PBMs and their relationships with pharmacies. In 2024 alone, there were 33 b

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