AAM Statement in Response to Federal Trade Commission Request for Information on PBM Business Practices

WASHINGTON, D.C. (May 23, 2022) – Today, the Association for Accessible Medicines (AAM) and its Biosimilars Council submitted a comment letter to the Federal Trade Commission in response to its request for information on the ways that large, vertically integrated Pharmacy Benefit Managers (PBMs) are affecting drug affordability and access. The FTC sought information on a wide range of issues in the PBM market including contract terms, rebates, fees, pricing policies, steering methods, conflicts of interest, and consolidation.

A distinct set of PBM business practices have resulted in higher prices and delayed access to generics and biosimilars for patients, said AAM CEO Dan Leonard. These business practices directly cause consumer harm, undermine the long-term viability of the generics and biosimilars industry and imperil billions in annual savings for taxpayers and the U.S. health care system.

AAM’s submission details how PBMs force patients to overpay for generic medicines through copays that do not reflect their decreasing costs and how PBMs prefer high-cost brand drugs to the detriment of lower-cost biosimilar competition.

Generics and biosimilars are lower cost options, but too often PBMs do not encourage their use. And when they do, they can force patients to pay more than necessary, commented Biosimilars Council Executive Director Christine Simmon. We look forward to working with the Federal Trade Commission to investigate how PBMs contribute to ever increasing costs in the pharmaceutical supply chain and on approaches to meaningfully reduce the costs of prescription drugs for America’s patients.

An additional docket submission signed by several patient, consumer, taxpayer, and other groups bolstered AAM and the Council’s position by highlighting the negative impact these PBM practices have on their constituents and calling on the FTC to investigate.

Every day, allergy and asthma patients bear the brunt of anti-competitive PBM business practices. By restricting access to more affordable generic and biosimilar alternatives, PBMs are forcing the majority of allergy and asthma patients to pay for expensive brand-name medicines just to manage their conditions, said Tonya Winders, President and CEO of the Allergy & Asthma Network, a signatory of the letter. Winders concluded, It is critical that the FTC investigate how PBMs are inflating pharmaceutical prices and take swift action to promote competition and provide savings to patients who need these medicines most.

View FTC Comment Letter

View AAM Blog


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Allen Goldberg

About AAM

AAM is driven by the belief that access to safe, quality, effective medicine has a tremendous impact on a person’s life and the world around them. Generic and biosimilar medicines improve people’s lives, improving society and the economy in turn. AAM represents the manufacturers and distributors of finished generic pharmaceuticals and biosimilars, manufacturers and distributors of bulk pharmaceutical chemicals, and suppliers of other goods and services to the generic industry. Generic pharmaceuticals are 90 percent of prescriptions dispensed in the U.S. but only 18 percent of total drug spending.

About the Biosimilars Council

The Biosimilars Council, a division of the Association for Accessible Medicines (AAM), works to ensure a positive environment for patient access to biosimilar medicines. The Biosimilars Council is a leading source for information about the safety and efficacy of more affordable alternatives to costly brand biologic medicines. Areas of focus include public and health expert education, strategic partnerships, government affairs, legal affairs and regulatory policy. More information is available at www.biosimilarscouncil.org.


Association for Accessible Medicines


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