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LUGPA Policy Brief: Pharmacy Benefit Manager (PBM) Price Transparency and Accountability Act

December 2025

The bipartisan PBM Price Transparency and Accountability Act seeks to strengthen visibility into pharmacy benefit manager (PBM) practices and reform key financial incentives in Medicare Part D and Medicaid. The legislation targets rebate-driven compensation structures, spread pricing, restrictive pharmacy networks, and other PBM behaviors that can inflate drug costs and limit patient access, issues with direct implications for independent physician practices.

Key Provisions

Delinking PBM Compensation from Drug Prices and Rebates

Prohibits PBM compensation in Medicare Part D and Medicaid from being tied to drug list prices, rebates, or similar price concessions, reducing incentives that favor higher-priced drugs over clinically appropriate, lower-cost alternatives.

Enhanced Reporting and Audit Transparency

Requires PBMs to provide detailed annual reports to Part D plan sponsors and HHS on rebates, administrative fees, pharmacy reimbursement, and pricing methodologies. Clarifies Part D sponsors' ability to audit PBM contracts to ensure compliance.

Strengthening “Any Willing Pharmacy” Requirements

Reinforces statutory obligations for Part D plans and Medicaid managed care organizations to contract with any pharmacy willing to accept standard terms and conditions, supporting independent and rural pharmacy access.

Mandatory Participation in the NADAC Survey

Requires all retail pharmacies, including physician in-office dispensing (IOD) programs, to participate in CMS’s National Average Drug Acquisition Cost (NADAC) survey or risk losing Medicaid dispensing eligibility.

Elimination of Spread Pricing in Medicaid

Requires full pass-through of Medicaid managed care prescription drug payments from PBMs to dispensing pharmacies, effectively ending spread pricing practices.

Why This Matters to LUGPA Members and Urology Patients

Opaque PBM practices and misaligned incentives frequently disrupt access to essential urologic medications, including oral oncolytics, androgen-deprivation therapies, overactive bladder treatments, and other specialty drugs commonly used in urology.

Current PBM policies often:

  • Steer patients toward higher-priced, higher-rebate drugs, increasing out-of-pocket costs;
  • Restrict access through preferred or PBM-owned pharmacy networks, interrupting coordinated care;
  • Undermine medically integrated dispensing programs through inadequate reimbursement and burdensome DIR fees, affecting adherence and continuity of care for complex conditions such as advanced prostate cancer.

These barriers negatively impact patient outcomes and challenge physician-led groups' ability to maintain integrated, patient-centered care models.

LUGPA Position

LUGPA supports the bill’s core transparency and reform measures, including:

  • Delinking PBM compensation from drug list prices.
  • Strengthened “any willing pharmacy” protections.
  • Full elimination of spread pricing in Medicaid.

However, LUGPA remains concerned that mandatory NADAC participation may create new administrative burdens for physician-owned dispensing operations without addressing longstanding reimbursement and direct and indirect remuneration (DIR) fee challenges.

LUGPA will continue working with congressional committees to ensure that final PBM reform legislation:

  • Protects physician-owned and medically integrated dispensing programs.
  • Addresses the impact of PBM fees and reimbursement practices.
  • Preserves urologists’ ability to provide accessible, coordinated, high-quality medication management for their patients.