Key Takeaways
- Congress passed the first major federal PBM reform, targeting Medicare Part D contracting and commercial spread pricing.
- CMS will define and enforce “reasonable and relevant” Part D contract terms to address unfair pharmacy contracts.
- Implementation will require rulemaking and is expected to take effect in 2029, making regulatory advocacy critical.
Cassity emphasized that this marks the first time the US Congress has enacted major pharmacy benefit manager (PBM) reform, representing more than 2 decades of advocacy by independent community pharmacies. She noted that similar reforms had nearly passed in late 2024 but ultimately stalled, making the bill’s passage a significant milestone.
This is the first time ever that Congress has passed PBM reform… it’s great, it’s helpful, it’s substantive, but it’s also historical. - Anne Cassity
The legislation includes reforms to Medicare Part D intended to address incentives that favor high-cost medications on formularies, increase transparency requirements for PBMs to plan sponsors, and eliminate spread pricing in the commercial market. For independent pharmacies, however, the most impactful provision relates to Medicare Part D contracting practices. Cassity described the current environment as a “take it or leave it” system in which PBMs dictate contract terms, often resulting in underpayment for dispensed prescriptions. Given that more than one-third of independent pharmacy revenue is typically tied to Medicare Part D, these practices have created sustained financial strain.
Under the new law, the Centers for Medicare & Medicaid Services (CMS) will be required to define and enforce “reasonable and relevant” contract terms within Part D. Cassity characterized this as a major step toward leveling the playing field between PBMs and pharmacies. However, she cautioned that implementation will require a lengthy regulatory process, including requests for information, proposed rules, and final rulemaking.
Although the reforms are not scheduled to take effect until 2029, Cassity underscored that the legislation represents meaningful progress toward greater fairness and oversight in public health program reimbursement and contracting.