Written Testimony of Lynn Quincy, Pharmacy Benefit Managers: Strategies To Increase Their Value For Consumers

This document is the written testimony of Lynn Quincy, Associate Director for Health Reform Policy at Consumers Union, to the ERISA Advisory Council. Quincy argues that mandatory disclosure of PBM compensation and fees, including rebates and other indirect revenue sources, is necessary to ensure employers and consumers pay competitive prices for prescription drugs and coverage. Quincy cites the FTC's findings that such transparency is not required for competitive outcomes, and that mandatory disclosure would likely reduce competition and increase prices. Quincy also discusses the differences between the Affordable Care Act's PBM disclosure requirements and the potential ERISA disclosure rule, noting the latter could be more harmful due to lack of strong confidentiality protections.