HR Policy Association Pharmaceutical Coalition Testimony to the ERISA Advisory Council

This document is the testimony presented by Robert G. Restivo of General Dynamics Corporation on behalf of the HR Policy Association (HRPA) and its Pharmaceutical Coalition to the ERISA Advisory Council. The testimony discusses HRPA's efforts over the past decade to increase transparency and accountability in PBM contracting, including the development of the PharmaDirect program that disaggregates PBM services to allow for better control over pricing and performance. The testimony outlines the various challenges HRPA members have faced in negotiating with PBMs and the complex financial arrangements involved, but does not provide a specific recommendation on mandatory disclosure requirements.