Statement of the National Community Pharmacists Association (NCPA) ERISA Advisory Council Hearing on PBM Compensation and Fee Disclosure

This document is the testimony of the National Community Pharmacists Association (NCPA) to the ERISA Advisory Council, advocating for mandatory disclosure of PBM compensation and fees, including rebates and other indirect revenue. NCPA argues that such transparency is necessary for ERISA plan sponsors to understand the true costs of PBM services and potential conflicts of interest, given the complex financial arrangements between PBMs, pharmacies, and drug manufacturers. NCPA recommends extending the ERISA 408(b)(2) disclosure requirements to cover PBMs, or alternatively, requiring the same disclosures as those mandated for PBMs serving state insurance exchanges and Medicare Part D plans.