If you have a health plan, you have a pharmacy benefit manager, even if you have never heard its name. The PBM decides which drugs your plan covers, negotiates with manufacturers, contracts with pharmacies, and processes every prescription. Pharmacy is now about a quarter of total health spending for employers.
Here's the catch with rebates. Most contracts guarantee you a fixed dollar amount per brand prescription, not a percentage of what the PBM actually collects. If the PBM collects $500 on a script and guarantees you $200, the difference is theirs. And because the guarantee is per brand script, the system quietly rewards putting more expensive brand drugs on the formulary, not fewer.
It gets better. Each of the big three PBMs set up a separate rebate aggregator, sometimes called a group purchasing organization. Some of what used to be called rebates now shows up as "administrative fees" or "service fees" paid to the aggregator. If your contract says you get 100 percent of rebates, but the money is no longer called a rebate, you may not be getting 100 percent of anything.
That's why, when I audit a PBM contract, the definition of "rebate" is the first page I read. Also worth knowing: a transparent PBM in a fully insured plan doesn't help you much, because the carrier keeps the savings. In a self-funded or captive plan, the right PBM can be the single biggest lever you have.
Questions to ask
- Are our rebates guaranteed per script, or do we receive a percentage of everything collected, including aggregator fees?
- How does the contract define "rebate"?
- Is there spread pricing at retail or mail, and do we have audit rights?
- When a generic or biosimilar is available, why is the brand preferred?