On behalf of the food industry and the thousands of supermarket pharmacies operated by our member companies, we at FMI – the Food Industry Association thank the Federal Trade Commission (FTC) for once again requesting public comment about the practices of Pharmacy Benefit Managers (PBMs) and their impact on patients, physicians, employers, independent and chain pharmacies, and other businesses across the pharmaceutical distribution system. Our comments, which reflect not only FMI’s insight, but also the expertise of FMI’s Pharmacy Operations Task Force, focus on the anticompetitive effects of the contract terms imposed by PBMs and how PBMs leverage their concentrated market power to the detriment of supermarket pharmacies and consumers, among others. We are particularly concerned about the way PBMs’ anticompetitive practices threaten patient access and the way PBMs are leveraging such practices to erode competition among pharmacies. FMI therefore calls on the Commission to move forward with a 6(b) study of the PBM industry, including the relationship between large PBMs, pharmacies and health insurers as well as the impact of PBM anticompetitive practices on both drug prices and pharmacies, and to use all the tools at the agency’s disposal to protect patient access and competition.

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