Comments on PBM Licensure and Regulation Model Act (December 2020)
Summary
The document is a letter from NAIC Consumer Representatives, dated December 18, 2020, providing comments on the Pharmacy Benefit Manager (PBM) Licensure and Regulation Model Act. The representatives express concerns that the Model Act alone is insufficient for states seeking comprehensive regulation of PBMs. They recommend further discussions, a white paper on PBM regulation, and inclusion of additional state citations in the model law. The letter emphasizes the impact of the Supreme Court decision in Rutledge vs. Pharmaceutical Care Management Association and urges continued efforts to address drug pricing and affordability.
