Comments on NAIC White Paper Draft on PBM Regulation (September 2023)
Summary
The document, dated September 15, 2023, is a letter from NAIC Consumer Representatives expressing strong support for the NAIC White Paper Draft-A Guide to Understanding Pharmacy Benefit Manager (PBM) and Associated Stakeholder Regulation. The letter appreciates the Subgroup’s efforts but reiterates the need to include specific PBM practices and state laws in the final draft. It also urges the NAIC to update sections on federal interest and move forward with recommendations to improve consumer access and affordability of prescription medications.