Possible outcomes of potential disclosure requirements in Medicare Part D

State and federal legislators have introduced proposals that could require pharmacy benefit managers (PBMs) to publicly disclose financial and business information, including rebates. In Medicare Part D, pharmaceutical manufacturers pay rebates to PBMs or plan sponsors in exchange for preferred formulary coverage. While contracting terms are considered confidential, the disclosure requirement could lead to publishing of the rebate amounts. The Pharmaceutical Care Management Association (PCMA) has requested Milliman to review potential outcomes of disclosure requirements on Medicare Part D. This white paper presents information on the topic in the following sections: 

• Potential outcomes 
• Additional considerations
• Stakeholder detail
• Methodology 
• Disclosures

This paper was commissioned by Pharmaceutical Care Management Association.