Comments on NAIC White Paper Draft on PBM Regulation (June 2023)
Summary
The document, dated June 1, 2023, is a letter from NAIC Consumer Representatives providing comments on the NAIC White Paper Draft-Guide to Understanding Pharmacy Benefit Manager (PBM) and Associated Stakeholder Regulation. It acknowledges the Subgroup’s effort in analyzing the role of PBMs, state regulatory approaches, and challenges in implementing PBM laws. It supports the continuation of the Subgroup, drafting PBM Model guidelines, and further dialogue. Specific comments on strengthening sections related to consumer access and affordability are included.
