ACHP Comments on CMS PBM Compensation & Data RFI

ACHP supports CMS’ implementation of the pharmacy benefit manager (PBM) reforms enacted in the Consolidated Appropriations Act of 2026; reforms that increase transparency, strengthen accountability and tie PBM compensation to bona fide services rather than drug prices, rebates, spread pricing or other misaligned incentives. At the same time, ACHP urges CMS to set clear guardrails that avoid inadvertently capturing nonprofit, provider-aligned health plans, integrated delivery systems and internal pharmacy functions that neither operate as third-party PBMs nor retain PBM-related revenue.