Request for Information (RFI): Pharmacy Benefit Manager Compensation and Data Collection
Key claim: CMS is soliciting technical input on PBM compensation restrictions and data reporting requirements set to take effect in 2028 under recent Medicare Part D legislation.
Abstract
(Proposed Rule · Health and Human Services Department, Centers for Medicare & Medicaid Services) This request for information (RFI) solicits technical input on the services and business practices of pharmacy benefit managers (“PBMs”) and their affiliates to inform implementation of recent legislation. It specifically focuses on gathering information to inform two specific legislative requirements that are effective beginning calendar year 2028: restrictions on the remuneration that PBMs and their affiliates may receive for services in connection with the utilization of covered Part D drugs; and data reporting requirements.
Why this matters
The RFI is an early implementation step for statutory PBM compensation restrictions and data reporting requirements that will reshape how Part D plans pay pharmacy benefit managers starting in 2028. Technical choices made in the eventual rulemaking will determine what compensation arrangements are permitted and what data CMS collects, with downstream effects on drug pricing, plan design, and pharmacy reimbursement.