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FTC's Interim Staff Report on PBMs: Why Transparency Tools are the Prescription for Change

Ferrin Williams, PharmD MBA


The Federal Trade Commission's (FTC) second interim staff report shines a light on critical issues surrounding prescription drug costs and highlights the need for transparent pricing and accessible shopping tools to help patients, employers, and plan sponsors make informed decisions. While the report identifies disparities and challenges in the pharmacy benefit management (PBM) system, the best solution lies in empowering consumers with tools that make it easy to compare prices and choose the best value.


PBM Arguments and Why They’re Only One Piece of the Puzzle


The PBMs have made two key arguments in response to the FTC’s findings:


  1. Bulk Savings Claims: One PBM stated that it saved eligible patients $1.3 billion in 2024, with a median out-of-pocket cost of $5.

  2. Subset Argument: PBMs argue that the FTC’s report focuses on a small subset of medications representing less than 2% of total annual drug spending.


These arguments may sound compelling, but they fail to address the reality faced by individuals. Bulk savings didn’t help my grandmother, who recently paid ten times more for her medication than she needed to. The current system is failing patients like her, who deserve clear and accessible information about their medication costs. Transparency and a shopping tool are real solutions, ensuring every consumer—not just those benefiting from bulk discounts—can access the best value for their prescriptions.


Scripta’s book-of-business data illustrates just how extreme pricing discrepancies can be:


  • Teriflunomide: $6.81 minimum vs. $1,655.56 maximum (243x difference).

  • Genvoya: $8.33 minimum vs. $1,316.33 maximum (158x difference).

  • Latuda: $5.97 minimum vs. $6,937.89 maximum (1162x difference).

  • Fluocinonide: $5.01 minimum vs. $2,881.28 maximum (575x difference).


Without transparent pricing and shopping tools, these differences remain hidden, leaving patients and their employer to bear unnecessary costs.


Transparent Pricing Models and the Need for Comparison Tools


Recent announcements about cost-plus pricing models have sparked discussions about efforts to make prescription drug pricing more transparent. While these models aim to simplify and stabilize costs for plan sponsors, they often differ significantly in their approach to transparency. For example, some models publicly post prices, enabling individuals to see exactly what they will pay, while others provide more predictable pricing for employers but lack consumer-facing visibility.


Ultimately, true transparency requires not only predictable pricing but also tools that empower individuals to compare options easily. The key to real change lies in pairing transparent pricing with a shopping navigator, enabling patients and plan sponsors to access the best-value medications confidently and efficiently. By providing visibility and facilitating price comparisons, solutions like Scripta Insights bridge the gap, ensuring that both plan sponsors and their members can make informed decisions.


The Role of the FTC


The FTC’s involvement is critical in ensuring accountability and fairness in this system. For too long, drug pricing practices have escaped the level of oversight that other industries, like airlines, receive. If the pricing manipulation seen in the pharmaceutical and PBM industries were happening in the airline industry, the FTC would be in offices the same day.


The FTC’s report highlights the growing profit center that specialty generics represent for the Big 3 PBMs. While the PBMs claim their practices save money overall, the report demonstrates how pricing games have eroded trust and increased costs for patients and employers alike. These findings must lead to actionable reform.


The Path Forward


The solution is clear: While we await the FTC to engage in what may become a long and drawn-out legal battle with the PBMs over these initial allegations, there is a solution that plan sponsors and their members can act on now. Transparent pricing and consumer-friendly shopping tools, like those offered by Scripta Insights, provide an immediate path forward. These tools are no longer a "nice-to-have" but a critical necessity in today’s environment. Many employers across the nation have adopted the Scripta solution, empowering their members with the ability to shop for the best-value medications. With tools like these, individuals can make informed decisions, avoid overpaying, and access the medications they need without unnecessary financial strain.


This is about more than dollars and cents—it’s about people’s lives. Patients deserve a healthcare system that works for them, not against them. Transparent pricing, combined with accessible tools for navigating the market, is the key to rebuilding trust and ensuring fairness. The FTC’s report is a call to action for real change. Let’s answer it.



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Scripta™ is neither a pharmacy nor a doctor. The benefit service does not tell you what drug to take and does not participate in the drug selection process. Only your physician can determine the medications that are right for you. These alternative medications are options for less costly drugs that physicians may prescribe in place of the medications you are taking now. Scripta has reviewed your current medications only for the purpose of identifying potential cost savings for you to consider with your physician. Scripta has not analyzed the effectiveness or other therapeutic aspects of these medication alternatives. Accordingly, this report and any other forms of communication received from Scripta are not, nor should they be interpreted as, any form of treatment, drug regimen review, or provision of counseling or consultation by a prescriber, pharmacist or pharmacy. Do not stop taking your medication, change your medication, or start taking a new medication without being directed to do so by your physician and filling the prescription under the oversight of a licensed pharmacist. The alternatives set forth above may not be equivalent to your current medication, may interact adversely with your other medications, may not be indicated in light of your other conditions, may cause different or severe side effects, or may be less effective at treating your condition. Medication prices are approximate based on information provided by your pharmacy benefits manager, insurance plans, and/or employer, and may vary from pharmacy to pharmacy. Check with your insurance plan to obtain a full list of pharmacies where your prescriptions can be filled. All information herein is HIPAA protected, treated as highly confidential, and never shared with your employer.

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