CMS Seeks Guidance on Medicare Part D PBM Reform under the CAA 2026

Short summary

CMS issued an RFI on Medicare Part D PBM reforms (CAA 2026), seeking guidance on defining and enforcing restrictions on pharmacy benefit manager compensation and implementing data collection requirements effective January 2028. The RFI prioritizes six areas: PBM/affiliate definitions, bona fide service fees, fair market value determination, pharmacy payments, and comprehensive data collection. CMS signals concerns about entities circumventing regulations and remuneration flowing through unregulated channels.

• •CMS issued RFI on Medicare Part D pharmacy benefit manager reforms under CAA 2026
• •Six priority areas: PBM definition, affiliate classification, compensation restrictions, fair market value, pharmacy payments, data collection
• •Requirements effective January 1, 2028; CMS focused on substance over form to prevent regulatory circumvention

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