The prescription coverage industry is rampant with conflicts of interest.
Unbeknownst to Plans, most consulting firms have agreed to act as brokers and feed business to certain PBMs in exchange for fees. Many consulting firms are also retained by PBMs to perform work and are therefore inclined to favor those PBMs or provide misleading analyses when asked to evaluate the performance of those PBMs.
Accordingly, it’s imperative that you require every consulting firm to execute a Conflict of Interest Disclosure Form and Agreement. The “disclosure” part of the Form should require the PBM to disclose all relationships and money flows between the consulting firm and any PBM. The “agreement” part of the Form should make clear that if the consulting firm fails to disclose its conflicts accurately, the consulting firm will be required to reimburse all fees that it receives from your Plan, as well as pay your Plan a liquidated damages penalty.
Pharmacy Benefit Consultants has drafted a model Disclosure Form & Agreement that your Plan can download for free:
We urge your Plan to use this Form:
- For every consulting firm that is already working on behalf of your Plan
- For every consulting firm your Plan is considering retaining
If you want to decrease and control your Plan’s costs, you need to retain a consulting firm that will act solely and exclusively in your Plan’s interests.
By taking action, you will also communicate to all consulting firms – and PBMs – that conflicts of interest will no longer be tolerated, and you will thus help change the entire prescription coverage industry.