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entitled 'Federal Employees' Health Benefits: Effects of Using Pharmacy 
Benefit Managers on Health Plans, Enrollees, and Pharmacies' which was 
released on January 10, 2003.



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Report to the Honorable Byron L. Dorgan, U.S. Senate:



United States General Accounting Office:



GAO:



January 2003:



Federal Employees’ Health Benefits:



Effects of Using Pharmacy Benefit Managers on Health Plans, Enrollees, 

and Pharmacies:



GAO-03-196:



GAO Highlights:



Highlights of GAO-03-196, a report to the Honorable Byron L. Dorgan, 

U.S. Senate:



Why GAO Did This Study:



Rising prescription drug costs have contributed to rising employer 

health plans premiums in recent years. Most federal employees, 

retirees, and their dependents participating in the Federal Employees 

Health Benefits Program (FEHBP), administered by the Office of 

Personnel Management (OPM), are enrolled in plans that contract with 

pharmacy benefit managers (PBM) to administer their prescription drug 

benefits. 



GAO was asked to examine how pharmacy benefit managers participating 

in the federal program affect health plans, enrollees, and pharmacies.  

GAO examined the use of PBMs by three plans representing about 55 

percent of the 8.3 million people covered by FEHBP plans.  For example, 

GAO surveyed 36 retail pharmacies on prices that a customer without 

third-party coverage would pay for 18 high-volume or high-expenditure 

drugs and compared these prices to prices paid by the plans and PBMs. 



What GAO Found:



The PBMs reviewed produced savings for health plans participating in 

FEHBP by obtaining drug price discounts from retail pharmacies and 

dispensing drugs at lower costs through mail-order pharmacies, passing 

on certain manufacturer rebates to the plans, and operating drug 

utilization control programs.  For example, the average price PBMs 

obtained from retail pharmacies for 14 brand name drugs was about 18 

percent below the average price paid by customers without third-party 

coverage.



Enrollees in the plans reviewed had wide access to retail pharmacies, 

coverage of most drugs, and benefited from cost savings generated by 

the PBMs.  Enrollees typically paid lower out-of-pocket costs for 

prescriptions filled through mail-order pharmacies and benefited from 

other savings that reduced plans’ costs and therefore helped to lessen 

rising premiums.

 

Most retail pharmacies participate in the FEHBP plans’ networks in 
order 

to obtain business from the large number of enrollees covered.  
Pharmacy 

associations report that the PBMs’ large market shares leave some 
retail 

pharmacies with little leverage in negotiating with PBMs.  Retail 

pharmacies must accept discounted reimbursements from PBMs they 
contract 

with and perform additional administrative tasks associated with claims 

processing.  



OPM generally concurred with GAO’s findings.  The plans and PBMs 

reviewed provided technical comments, and two independent reviewers 

stated the report was fair and balanced.  One pharmacy association 

expressed strong concerns, including that the report did not more 
broadly 

address economic relationships in the PBM industry.  GAO examined 

relationships between the PBMs and manufacturers and pharmacies 
specific 

to their FEHBP business.  However, relationships between PBMs and other 

entities for other plans were beyond the report’s scope.



GAO HIghlights Figure:



[See PSDF for image]



[End of Figure]



Contents:



Letter:



Results in Brief:



Background:



PBMs Achieved Savings through Price Discounts, Rebate Payments, and 

Managing Drug Use:



PBMs Provided FEHBP Enrollees Generally Unrestricted Access to 

Prescription Drugs, Cost Savings, and Other Benefits:



Pharmacies Included in PBM Retail Networks Must Accept Discounted 

Prices and Perform Various Administrative Tasks:



PBMs Received Compensation from Plans and Payments from Manufacturers 

for Their FEHBP Business:



Concluding Observations:



Agency and Other Comments and Our Evaluation:



Appendix I: Scope and Methodology:



Appendix II: Comments from the Office of Personnel 

Management:



Appendix III: GAO Contact and Staff Acknowledgments:



Related GAO Products:



Tables:



Table 1: FEHBP Plans and PBMs Reviewed:



Table 2: FEHBP Plans’ Formularies Compared to VA National Formulary:



Table 3: Comparison of Enrollee Cost-Sharing for a 90-day Supply of 

Retail and Mail-Order Prescription Drugs, 2002:



Table 4: Selected High-Volume or High-Expenditure Drugs for 3 FEHBP 

Plans:



Figures:



Figure 1: PBM Relationships with Market Participants:



Figure 2: PBM Discounted Plan Prices Compared to Cash-Paying Customer 

Prices for 30-Day Supplies, April 2002:



Figure 3: Overview of PBMs’ Compensation and Payment Sources:



Abbreviations:



AMP: average manufacturer price:



AWP: average wholesale price:



BCBS: Blue Cross and Blue Shield:



FEHBP: Federal Employees Health Benefits Program:



GEHA: Government Employees Hospital Association:



HMO: health maintenance organization:



IOM: Institute of Medicine:



MAC: maximum allowable cost:



NACDS: National Association of Chain Drug Stores:



NCPA: National Community Pharmacists Association:



NDC: National Drug Code:



OPM: Office of Personnel Management:



PBM: pharmacy benefit managers:



SEC: Securities and Exchange Commission:



VA: Department of Veterans Affairs:



WAC: wholesale acquisition cost:



January 10, 2003:



The Honorable Byron L. Dorgan

United States Senate:



Dear Senator Dorgan:



The increasing cost of prescription drugs has been a key component of 

rising employer health care costs in recent years. In 2001, total 

employer health benefit costs rose 11 percent, while prescription drug 

costs rose 17 percent.[Footnote 1] Many employer-sponsored health plans 

and insurers contract with pharmacy benefit managers (PBMs) to help 

manage their prescription drug benefits. PBMs negotiate drug prices 

with pharmacies and drug manufacturers on behalf of health plans and, 

in addition to other administrative, clinical, and cost containment 

services, process drug claims for the health plans. In 2001, nearly 200 

million Americans had their prescription drug benefits managed by a 

PBM. Most federal employees, retirees, and their dependents 

participating in the Federal Employees Health Benefits Program (FEHBP), 

the largest employer-sponsored health insurance program in the United 

States, are enrolled in plans that contract with PBMs to manage their 

prescription drug benefits.



Because PBMs play a critical role in managing prescription drug 

benefits, you asked us to examine PBMs’ role within the FEHBP program. 

In particular, we addressed the following questions:



1. Do PBMs achieve savings, and, if so, how?



2. How do FEHBP plans’ use of PBMs affect enrollees, including access 

to prescription drugs and out-of-pocket spending?



3. How do FEHBP plans’ use of PBMs affect retail pharmacies, including 

pharmacies’ reimbursements for drugs dispensed and administrative 

requirements?



4. How are PBMs compensated for services provided to FEHBP plans?



To respond to these questions, we examined the use of PBMs by three 

FEHBP plans: Blue Cross and Blue Shield (BCBS), Government Employees 

Hospital Association (GEHA), and PacifiCare of California. Together, 

these plans accounted for about 55 percent of the 8.3 million people 

covered by FEHBP as of July 2002 and represented various plan types and 

PBM contractors.[Footnote 2] BCBS contracted with the two largest PBMs 

in the United States for its pharmacy benefit services--Medco Health 

Solutions, a subsidiary of the pharmaceutical company Merck & Co., 

Inc., and AdvancePCS. GEHA contracted with Medco Health Solutions and 

PacifiCare of California contracted with Prescription Solutions, 

another subsidiary of PacifiCare Health Systems.



We reviewed contracts between the PBMs and plans, financial statements 

regarding payments made between the plans and PBMs, and retail and 

mail-order prices for selected drugs from the FEHBP plans we reviewed 

and the PBMs with which they contracted. We also obtained pricing 

information from retail pharmacies, interviewed officials at the Office 

of Personnel Management (OPM),[Footnote 3] and associations 

representing PBMs and retail pharmacies, and reviewed studies regarding 

the use of PBMs and prescription drug payments. Specifically:



* To assess whether PBMs achieve cost savings, we obtained April 2002 

prices for 18 drugs that the three FEHBP plans paid to their PBMs for 

retail and mail order prescriptions.[Footnote 4] We compared these 

prices to cash prices[Footnote 5] that customers would pay at retail 

pharmacies in California, North Dakota, Washington, D.C., and the 

Virginia and Maryland suburbs of Washington, D.C., and to Medicaid 

reimbursement rates in these locations. In addition, we obtained plan 

and PBM data on drug manufacturers’ rebates that PBMs pass on to plans 

and any estimated savings resulting from certain PBM intervention 

techniques such as drug utilization reviews and prior authorization.



* To examine the effect of PBM services on enrollees’ access to drugs 

and out-of-pocket costs, we reviewed plan documents; compared the 

plans’ retail pharmacy networks to the number of licensed retail 

pharmacies in California, the District of Columbia, Maryland, North 

Dakota, and Virginia; and compared the number of drugs and therapeutic 

classes included on the plans’ formularies[Footnote 6] with the 

National Formulary for the Department of Veterans Affairs 

(VA).[Footnote 7]



* To examine the effect of PBMs on retail pharmacies, we interviewed 

representatives of retail pharmacies and associations and 

representatives of FEHBP plans and PBMs. We also compared the PBMs’ 

payments to retail pharmacies for selected drugs to industry-reported 

manufacturer and wholesale prices that estimate pharmacy acquisition 

costs.



* To examine how PBMs were compensated for services they provided FEHBP 

plans, we examined the contracts between plans and PBMs and associated 

annual financial statements and financial information that PBMs filed 

with the Securities and Exchange Commission (SEC).



While the plans and PBMs provided certain data that they considered 

proprietary, we do not report such data that can be linked to a 

specific plan or PBM but instead report aggregated drug price, cost, 

savings, and compensation data. We did not independently verify 

information provided by plans, PBMs, or pharmacies. Appendix I provides 

additional information on our scope and methodology, and a list of our 

related products is included at the end of this report. Our work was 

conducted from September 2001 through December 2002 according to 

generally accepted government auditing standards.



Results in Brief:



The three PBMs we examined achieved savings for FEHBP-participating 

health plans by using three key approaches: obtaining drug price 

discounts from retail pharmacies and dispensing drugs at lower costs 

through their mail-order pharmacies; passing on certain manufacturer 

rebates to the plans; and using intervention techniques that reduce 

utilization of certain drugs or substitute other, less costly, drugs. 

The average price PBMs negotiated for drugs from retail pharmacies was 

about 18 percent below the average cash price customers would pay at 

retail pharmacies for 14 selected brand-name drugs and 47 percent below 

the average cash price for 4 selected generic drugs. These price 

savings may overstate PBMs’ negotiating success because, absent a PBM, 

plans would likely manage their own drug benefits and also attempt to 

negotiate discounts with retail pharmacies. PBMs provide plans even 

greater savings when drugs are dispensed through their mail-order 

pharmacies. The average mail-order price was about 27 percent and 53 

percent below the average cash price customers would pay at a retail 

pharmacy for the selected brand name and generic drugs, respectively. 

In addition to discounts, PBMs passed through to plans certain rebates 

they earned from drug manufacturers. Across the three plans, rebates 

reduced total annual drug spending by 3 percent to 9 percent from 1998 

through 2001. Although difficult to precisely quantify, PBMs also 

achieved savings through intervention techniques such as prior 

authorization and drug utilization reviews that identify excess use, 

duplicative therapies, or the availability of effective, low-cost drug 

alternatives. For example, plans reported savings in 2001 for various 

intervention techniques that ranged from less than 1 percent to 9 

percent of their total spending on prescription drug benefits.



FEHBP enrollees generally had unrestricted access to retail pharmacies 

and prescription drugs, savings in out-of-pocket spending, and other 

safety and customer service benefits. PBMs maintained retail pharmacy 

networks for the FEHBP plans that included most retail pharmacies--

typically 90 percent to nearly 100 percent in five jurisdictions we 

reviewed. Drug formularies administered by the PBMs were generally not 

overly restrictive; they included drugs in most major therapeutic 

categories and mechanisms existed to allow enrollees to obtain 

nonformulary drugs when prescribed by a physician, although sometimes 

at a higher out-of-pocket cost. Enrollees also shared in the savings 

PBMs generated for FEHBP plans. For example, enrollees generally paid 

less in out-of-pocket costs for drugs from the PBMs’ mail-order 

services than they would at retail pharmacies. Additional PBM savings 

passed on to plans translated into smaller premium increases for 

enrollees. Further, each PBM operated a program to review prescriptions 

at the point of purchase to help prevent:



potentially adverse drug interactions, and the PBMs reported that they 

generally met or exceeded contractual standards on customer service 

quality.



Pharmacies that participate in retail networks established by FEHBP 

plans’ PBMs must accept discounted prices and undertake additional 

administrative tasks not required for cash-paying customers’ 

transactions. Although these pharmacies were reimbursed by the PBMs 

below the level paid by cash-paying customers, we estimate that PBM 

reimbursements exceeded pharmacies’ drug acquisition costs--not 

including overhead costs or any discounts or rebates some pharmacies 

may obtain--by an average of approximately 8 percent for brand-name 

drugs we selected for review. Administrative requirements to process 

PBM and other third-party prescriptions are greater than for cash 

transactions. For example, pharmacy staff must file claims 

electronically, may be required to contact physicians to approve 

formulary drug substitutions, or counsel patients on plan benefits. 

Also, retail pharmacies may lose market share to PBM mail-order 

pharmacies because some PBMs use cost incentives and enrollee health 

information to promote the use of mail order over retail pharmacies. 

Nevertheless, most retail pharmacies participate in PBM networks 

because of the large market share PBMs represent and the prescription 

and nonprescription sales generated by customers the PBMs help bring 

into the stores. Pharmacy associations report that retail pharmacies 

often have little leverage with PBMs, with negotiations only occurring 

when a large chain will not accept the PBM’s contractual terms or an 

independent pharmacy in a rural area must be included to meet health 

plans’ access requirements.



PBMs received compensation for their FEHBP business from FEHBP plans 

and payments from pharmaceutical manufacturers through various methods.



* PBMs collected fees from FEHBP plans for various administrative and 

clinical services including processing claims and conducting drug 

utilization reviews. These administrative fees, which varied by plan 

depending on contracted services, accounted for an average of about 1.5 

percent of each plan’s total drug benefit spending in 2001.



* FEHBP plans we reviewed paid PBMs discounted prices for retail drugs 

that were virtually the same as prices PBMs paid to reimburse retail 

pharmacies. However, plans paid lower prices for mail-order drugs 

supplied by the PBM. While not disclosing their acquisition costs for 

mail-order drugs, PBM officials said that discounted prices paid by the 

plans to PBMs for mail-order drugs were generally higher than prices 

PBMs paid manufacturers to acquire drugs.



* The PBMs we reviewed varied in the extent to which they retained a 

share of drug manufacturers’ rebates associated with their FEHBP 

business or passed it all on to the FEHBP plans they contracted with. 

The PBMs also received other rebates or payments from manufacturers 

based on their total business with a particular drug manufacturer. 

While information on the size of these payments was unavailable, PBMs’ 

public financial information suggests that rebates or other payments 

from drug manufacturers may be a large source of PBM earnings.



In commenting on a draft of this report, OPM generally concurred with 

our findings. The plans and PBMs we examined reviewed the report for 

the accuracy of information regarding their arrangements and provided 

technical comments that we incorporated as appropriate. Two independent 

experts indicated that the report was fair and balanced and provided 

technical comments. An official for the National Association of Chain 

Drug Stores (NACDS) expressed strong concerns in response to our draft 

report, primarily regarding the scope of our work. An official of the 

National Community Pharmacists Association (NCPA) separately said he 

concurred with the NACDS official’s comments. A major concern was that 

the report’s focus on FEHBP plans did not adequately address the full 

scope of economic relationships in the PBM industry, including those 

between drug manufacturers and PBMs and the extent to which these 

relationships create incentives for PBMs to encourage the use of 

certain potentially higher-cost drugs. We examined contracts and 

relationships between the PBMs and drug manufacturers and pharmacies 

specific to their FEHBP line of business. However, relationships 

between PBMs and manufacturers and pharmacies for other plans were 

beyond the report’s scope.



Background:



Most FEHBP plans contract with a PBM to help manage their prescription 

drug benefits, and those that do not contract with a PBM have internal 

components that employ techniques commonly used by PBMs, according to 

OPM officials. The three FEHBP plans we reviewed covered more than half 

of all FEHBP enrollees and paid $3.3 billion for about 65 million 

prescriptions dispensed to these enrollees in 2001. Table 1 shows plan 

enrollment and PBMs we reviewed.



Table 1: FEHBP Plans and PBMs Reviewed:



BCBS; July 2002 Enrollment (percentage of total FEHBP enrollment): 

4,038,671 (48.8); PBMs: AdvancePCS (retail); Medco Health Solutions 

(mail order).



GEHA; July 2002 Enrollment (percentage of total FEHBP enrollment): 

441,151 (5.3); PBMs: Medco Health Solutions.



PacifiCare of California; July 2002 Enrollment (percentage of total 

FEHBP enrollment): 57,042 (0.7); PBMs: Prescription Solutions.



Source: OPM.



Notes: As of July 2002, FEHBP plans covered 8.3 million people.



Some FEHBP plans offer two benefit options, including BCBS (standard 

and basic options) and GEHA (high and standard options).



[End of table]



PBMs offer health plans a variety of services including negotiating 

price discounts with retail pharmacies, negotiating rebates with 

manufacturers, and operating mail-order prescription services and 

administrative claims processing systems. PBMs also provide health 

plans with clinical services such as formulary development and 

management, prior authorization and drug utilization reviews to screen 

prescriptions for such issues as adverse interactions or therapy 

duplication, and substitution of generic drugs for therapeutically 

equivalent brand-name drugs. In order to provide these services, PBMs 

operate with multiple stakeholders in a complex set of relationships, 

as shown in figure 1.



Figure 1: PBM Relationships with Market Participants:



[See PDF for image]



[End of figure]



Note: Other market interactions occur that are not represented in 

figure 1, including information exchanges among PBMs, manufacturers, 

wholesalers, physicians, health plans, and enrollees.



Health plans are primarily responsible for overseeing PBM activities 

and for reporting to OPM any problems that could affect benefits 

service delivery to enrollees. OPM oversight responsibilities include 

negotiating plan benefits and changes, monitoring drug benefit service 

delivery, reviewing customer service reports, conducting on-site visits 

with pharmacy benefit managers, and handling appeals and complaints 

from FEHBP enrollees regarding their pharmacy benefits.



PBMs Achieved Savings through Price Discounts, Rebate Payments, and 

Managing Drug Use:



PBMs achieved savings for FEHBP plans primarily by obtaining price 

discounts for drugs, obtaining rebate payments from manufacturers, and 

employing various intervention techniques to control drug utilization 

and cost. In comparison to cash-paying customer prices, PBMs we 

reviewed obtained significant discounts from retail pharmacies and 

offered even greater discounts when prescriptions were dispensed 

through mail-order pharmacies. In addition, PBMs passed on to plans 

some or all manufacturers’ rebates associated with the FEHBP plans’ 

contracts and used intervention techniques that reduced plan spending 

on drug benefits.



PBMs Obtained Discounted Prices Significantly Below Those Paid by Cash-

Paying Customers:



In comparison to prices cash-paying customers without third-party 

coverage would pay at retail pharmacies, the PBMs we examined achieved 

significant discounts for drugs purchased at retail pharmacies and 

offered even greater discounts through their mail-order pharmacies. The 

average price PBMs obtained for drugs from retail pharmacies was about 

18 percent below the average price cash-paying customers would pay at 

retail pharmacies for 14 selected brand-name drugs and 47 percent below 

the cash price for 4 selected generic drugs. For the same quantity, the 

average price paid at mail order for the brand and generic drugs was 

about 27 percent and 53 percent below the average cash-paying customer 

price, respectively.[Footnote 8] (See fig. 2.):



Figure 2: PBM Discounted Plan Prices Compared to Cash-Paying Customer 

Prices for 30-Day Supplies, April 2002:



[See PDF for image]



[End of figure]



Note: Most mail-order pharmacies dispense at larger volumes, typically 

a 90-day supply. Average mail-order discounts from cash-paying customer 

prices increase slightly if prescriptions are dispensed for a 90-day 

supply rather than for a 30-day supply.



Moreover, PBMs we reviewed obtained greater discounts from retail 

pharmacies than did state Medicaid programs, which represent another 

major purchaser of drugs through retail pharmacies. We estimate that 

the average reimbursement rate for drugs by 5 Medicaid programs we 

reviewed was about 11 percent below the average price cash-paying 

customers would pay at retail pharmacies for the selected brand-name 

drugs (compared to 18 percent for the FEHBP plans we reviewed) and 23 

percent below the average cash price for the selected generic drugs 

(compared to 47 percent for the FEHBP plans we reviewed).[Footnote 9]



While PBMs negotiated prices significantly lower than a cash-paying 

customer would pay, these discounts may overstate the level of savings 

plans achieve from using PBMs since no benchmark exists to accurately 

determine what discounts plans would obtain without a PBM. In the 

absence of a PBM, FEHBP plans could obtain some level of drug price 

discounts from retail pharmacies and drug manufacturers but would also 

directly incur the costs associated with undertaking these 

responsibilities. Also, PBMs can negotiate deeper discounts for plans 

with smaller networks of retail pharmacies because the pharmacies can 

anticipate receiving a higher concentration of the plans’ enrollees. 

For example, BCBS introduced its basic option in 2002 that includes a 

smaller network of retail pharmacies--about 70 percent as many 

pharmacies as its standard option--and deeper discounts in its retail 

pharmacy payments compared to its standard option.



PBMs Further Reduced Plans’ Drug Expenditures by Passing Through 

Certain Manufacturer Rebates:



PBMs also passed through to the FEHBP plans they contracted with some 

or all of drug manufacturer rebates associated with their FEHBP 

business. Over the past 4 years, we estimate that the plans we reviewed 

received rebate payments that effectively reduced plans’ annual 

spending on prescription drugs by 3 percent to 9 percent. The share of 

rebates PBMs pass through to plans varies and is subject to contractual 

agreements negotiated between PBMs and the plans.[Footnote 10]



Rebates and formularies are interrelated. Drug manufacturers provide 

PBMs certain rebates depending not only on inclusion of their drugs on 

a plan’s formulary but also on the PBMs’ ability to increase a 

manufacturer’s market share for certain drugs. Formulary incentives, 

such as lower enrollee cost sharing for certain drugs compared to 

competing therapeutically equivalent drugs, encourage the former’s use. 

Manufacturers may pay higher rebates when formularies have stronger 

incentives to use specific drugs. Therefore, PBMs may be able to 

provide other health plans with higher rebates if their formularies are 

more restrictive than those of the FEHBP plans we examined.



PBM Intervention Techniques Contributed to Plans’ Savings, but Are 

Difficult to Quantify:



Although PBM intervention techniques help contain plans’ cost increases 

by managing drug utilization and identifying opportunities to dispense 

less expensive drugs, their full impact on savings is not easily 

quantifiable. The FEHBP plans and PBMs we reviewed reported savings for 

individual intervention techniques ranging from less than 1 percent to 

9 percent of plans’ total drug spending in 2001.[Footnote 11] Because 

plans varied in their use of intervention techniques and employed 

different cost savings methodologies, these estimates may not be 

comparable across plans. Techniques plans most commonly used included 

concurrent drug utilization review, prior authorization, therapeutic 

brand interchange, and brand to generic substitution. The reported 

cumulative effect of several techniques for one plan amounted to 14 

percent of drug spending.



Measuring cost savings from PBM intervention techniques is difficult 

for various reasons, including:



* Savings methodologies did not reflect the effect intervention 

techniques may have over time on enrollees’ utilization patterns and 

physicians’ prescribing practices. That is, there may be a sentinel 

effect from PBMs’ reviews whereby enrollees and physicians may stop 

filling or prescribing drugs that do not meet PBMs’ utilization review 

or refill criteria, but the extent to which these behavior changes 

occur is beyond the scope of PBMs’ data systems.



* Plans and PBMs we reviewed did not consistently measure the number or 

costs of drugs not dispensed as a result of PBM interventions that 

result in drug substitutions, denials for adverse drug interaction, or 

other interventions, making it difficult to estimate savings from 

certain intervention techniques.



* Plans did not systematically measure savings when the primary goal of 

the intervention technique was patient safety and compliance with 

drugs’ clinical guidelines.



Among various intervention techniques, concurrent drug utilization and 

prior authorization provided some plans the largest quantifiable 

savings. The following are examples of intervention savings estimates 

reported by plans we reviewed.



* Drug utilization review includes the PBM examining prescriptions 

concurrently at the time of purchase to assess safety considerations, 

such as potential adverse interactions, and compliance with clinical 

guidelines, including quantity and dose. These reviews can also occur 

retrospectively to analyze enrollees’ drug utilization and physicians’ 

prescribing patterns. Two plans estimated savings from drug utilization 

review ranging from 6 percent to 9 percent, with about 60 percent to 80 

percent of the savings from concurrent reviews, including claim denials 

from the PBM to prevent early drug refills and safety advisories to 

caution pharmacists about potential adverse interactions or therapy 

duplications.[Footnote 12] The remaining estimated savings are from 

retrospective reviews.



* Prior authorization requires enrollees to receive approval from the 

plan or PBM before dispensing certain drugs that treat conditions or 

illnesses not otherwise covered by plans, have high costs, have a high 

potential for abuse, or are ordered in unusual quantities. Some plans 

may also require prior authorization for nonformulary drugs. Each of 

the plans we reviewed required prior authorization for certain drugs 

such as growth hormones and a drug used to treat Alzheimer’s disease. 

Two plans reported savings from prior authorization ranging from 1 

percent to 6 percent of plan spending for drugs that either were not 

dispensed or were substituted for with less costly alternatives.



* Therapeutic interchange encourages the substitution of less expensive 

formulary brand-name medications considered safe and effective for more 

expensive nonformulary drugs within the same drug class. Two plans 

reported savings ranging from 1 percent to 4.5 percent from therapeutic 

interchange. These estimates are in addition to savings associated with 

rebates plans earned for drugs in the formulary.[Footnote 13]



* Generic substitution involves dispensing less expensive, chemically-

equivalent generic drugs in place of brand name drugs. Where a PBM 

specifically intervened by contacting the physician to change a 

prescription from requiring a brand name to allowing a generic drug, 

one plan reported savings of less than 1 percent of the plan’s total 

drug spending. The other two plans said they do not have readily 

available data to measure savings from PBM interventions for generic 

drugs. All three plans reported more general information on their 

generic drug use, but the extent to which generic drugs are used cannot 

solely be attributed to PBMs because plan benefit design and physician 

prescribing patterns also influence generic drug use. On average, the 

plans we reviewed reported that generic drugs were dispensed more often 

by retail pharmacies (about 45 percent of all drugs dispensed) than by 

mail-order pharmacies (about 34 percent). The difference in use of 

generic drugs may in part reflect differences in the types of drugs 

that are typically dispensed through retail and mail-order pharmacies. 

For drugs where a generic version was available, the retail and mail-

order pharmacies dispensed generic drugs at more similar rates--on 

average 89 percent of the time for retail pharmacies and 87 percent of 

the time for mail-order pharmacies.



PBMs Provided FEHBP Enrollees Generally Unrestricted Access to 

Prescription Drugs, Cost Savings, and Other Benefits:



PBMs we reviewed generally provided enrollees with access to a nearby 

pharmacy, maintained formularies for plan enrollees that included drugs 

in most major therapeutic categories, and provided access to 

nonformulary drugs when medically necessary. The FEHBP plans passed on 

savings generated by the PBMs to enrollees in the form of lower out-of-

pocket costs for prescription drugs in certain instances, such as 

through lower cost sharing for drugs obtained through mail-order 

pharmacies, and a smaller increase in premiums for all enrollees than 

might occur absent the PBM savings. Enrollees also benefited from PBM 

intervention programs to prevent potentially dangerous drug 

interactions and customer service that generally met or exceeded 

quality standards established in contracts negotiated with the FEHBP 

plans.



PBMs Provided Enrollees Access to Broad Retail Pharmacy Networks and 

Generally Nonrestrictive Drug Formularies:



Nearly all FEHBP enrollees had a retail pharmacy participating in their 

plan within a few miles of their residence. Two of the plans required 

the PBM to assure that at least 90 percent of enrollees had at least 

one pharmacy located within 5 miles of their residences. The PBMs for 

these plans reported to us they exceeded plans’ access standards and 

that close to 100 percent of enrollees live within 5 miles of a network 

pharmacy. The third plan did not have a specific contractual access 

standard, but plan officials said they have verified that well over 90 

percent of enrollees live within 5 miles of a network pharmacy. We also 

compared the PBMs’ networks statewide in five states to the total of 

licensed retail pharmacies and found high levels of pharmacy 

participation. In most instances, we estimate that more than 90 percent 

to nearly 100 percent of licensed retail pharmacies participated in the 

PBM networks.[Footnote 14]



Enrollees also had few restrictions on which drugs they could obtain. 

While the plans’ formularies varied with respect to the number of drugs 

covered, they included prescription drugs in most major therapeutic 

categories.[Footnote 15] To provide a benchmark for comparing the 

breadth and depth of the FEHBP formularies, we compared the three 

formularies to the outpatient prescription drugs included in the 

Department of Veterans Affairs (VA) National Formulary, considered by 

the Institute of Medicine to be not overly restrictive.[Footnote 16] 

Each plan included over 90 percent of the drugs listed on the VA 

formulary or a therapeutically equivalent alternative, and included at 

least one drug in 93 percent to 98 percent of the therapeutic classes 

covered by VA.[Footnote 17] (See table 2.):



Table 2: FEHBP Plans’ Formularies Compared to VA National Formulary:



Plan: BCBS; Percent of VA formulary drugs included in plan formulary: 

80; Percent of VA formulary drugs not in plan formulary but having a 

therapeutic equivalent in plan formulary: 16; Percent of VA formulary’s 

therapeutic classes covered by plan formulary[A]: 93.



Plan: GEHA; Percent of VA formulary drugs included in plan formulary: 

97; Percent of VA formulary drugs not in plan formulary but having a 

therapeutic equivalent in plan formulary: 2; Percent of VA formulary’s 

therapeutic classes covered by plan formulary[A]: 98.



Plan: PacifiCare of California; Percent of VA formulary drugs included 

in plan formulary: 79; Percent of VA formulary drugs not in plan 

formulary but having a therapeutic equivalent in plan formulary: 15; 

Percent of VA formulary’s therapeutic classes covered by plan 

formulary[A]: 95.





Source: GAO analysis of 2002 BCBS, GEHA, and PacifiCare of California 

formularies and the VA National Formulary.



[A] A VA therapeutic class was considered included if the plan 

formulary listed one or more VA drugs or a therapeutically equivalent 

alternate within the VA therapeutic class.



[End of table]



Each plan provided enrollees access to nonformulary drugs, although 

sometimes with higher cost sharing requirements.[Footnote 18] GEHA 

provided coverage to all nonformulary drugs at no additional cost to 

enrollees. BCBS had additional cost sharing requirements for 

nonformulary and certain formulary drugs under its basic option plan. 

Enrollees must pay a flat $25 copayment for formulary brand drugs but 

must pay the greater of a $35 copayment or 50 percent of the plan’s 

cost for nonformulary brand drugs (known as coinsurance). BCBS required 

the enrollees to pay the same 25 percent coinsurance for formulary and 

nonformulary drugs under its standard option plan. PacifiCare of 

California did not impose additional cost sharing for nonformulary 

drugs but generally required enrollees (or their physicians) to 

demonstrate the medical necessity and lack of effective alternative 

formulary drugs prior to approving coverage of a nonformulary drug.



PBM Savings Helped Reduce Enrollees’ Costs for Out-of-Pocket 

Prescription Drug Spending and Premiums:



FEHBP enrollees benefited from cost savings generated from PBM services 

through lower costs for mail-order prescriptions, lower cost sharing 

linked to PBMs’ discounts obtained from retail pharmacies, and a lower 

increase in premiums overall. PBM mail-order pharmacy programs often 

provided for lower out-of-pocket costs for 90-day supplies of drugs 

than an enrollee would pay for the same prescriptions filled at a 

retail pharmacy. The GEHA high option plan and PacifiCare of California 

imposed lower cost-sharing requirements for mail order while the BCBS 

standard option plan imposed a flat copayment for mail order but 

required enrollees to pay 25-percent coinsurance at retail. The flat 

copayments provided an incentive for enrollees to use mail order for 

more expensive brand drugs. Only the GEHA standard plan included the 

same cost sharing requirements for both retail and mail order. (See 

table 3.):



Table 3: Comparison of Enrollee Cost-Sharing for a 90-day Supply of 

Retail and Mail-Order Prescription Drugs, 2002:



Plan: BCBS; Option: Standard; Enrollee’s cost share at retail pharmacy: 

25% coinsurance; Enrollee’s cost share at mail-order pharmacy: $10 

copayment generic; $35 copayment brand.



Option: Basic[A]; Enrollee’s cost share at retail pharmacy: $30 

generic; $75 brand; Greater of 50% coinsurance or 

$105 copayment for nonformulary brand; Enrollee’s cost share at mail-

order pharmacy: Mail-order not available.



Plan: GEHA[B]; Option: High; Enrollee’s cost share at retail pharmacy: 

$15 generic; $45 single-source brand[C]; $90 multisource brand[D]; 

Second and subsequent refills are greater of 50% coinsurance or 

applicable copayment; Enrollee’s cost share at mail-order pharmacy: $10 

generic; $35 single-source brand[C]; $50 multisource brand[D].



Option: Standard; Enrollee’s cost share at retail pharmacy: $15 

copayment generic; 50% coinsurance brand; Enrollee’s cost share at 

mail-order pharmacy: $15 copayment generic; 50% coinsurance brand.



Plan: PacifiCare of California[B]; Option: HMO; Enrollee’s cost share 

at retail pharmacy: $15 copayment generic; $45 copayment brand; 

Enrollee’s cost share at mail-order pharmacy: $10 copayment generic; 

$30 copayment brand.





Source: GAO analysis of BCBS, GEHA, and PacifiCare of California 

prescription drug benefits literature.



[A] BCBS basic option limits initial prescription to a 34-day supply 

with a $10 copayment for generic drugs, $25 copayment for brand-name 

drugs, and the greater of 50 percent coinsurance or $35 for 

nonformulary brand-name drugs. Continuing prescriptions and refills can 

be for up to a 90-day supply with the enrollee paying the higher cost 

share amount.



[B] GEHA and PacifiCare of California limit the quantity of drugs 

dispensed through retail pharmacies to a 30-day supply; therefore, we 

tripled the copayments required for a 30-day supply.



[C] Brand-name drugs available from only one manufacturer, no generic 

equivalent available.



[D] Brand-name drugs available from more than one manufacturer and have 

a generic equivalent available.



[End of table]



The interaction between a plan’s benefit design and PBM cost savings 

can also affect the amount of enrollees’ out-of-pocket costs for 

prescription drugs.[Footnote 19] For example, in instances where a plan 

required enrollees to pay a coinsurance rate representing a portion of 

the actual drug cost, enrollees shared directly in price discounts PBMs 

obtained from pharmacies. To illustrate, for a hypothetical drug with 

an undiscounted cash price of $64, and a PBM-obtained discount price of 

$52, an enrollee in a plan with a 25-percent coinsurance requirement 

would pay $13 rather than $16. In contrast, where a plan’s benefit 

design provides for a fixed copayment, such as $15 per prescription, 

enrollees would pay the same regardless of the discount that PBMs 

obtained.



PBM savings were also passed on to enrollees in the form of premiums 

that were less than they otherwise would be. Fee-for-service FEHBP plan 

premiums are based on past years’ claims data for FEHBP 

enrollees.[Footnote 20] Consequently, PBM reductions in plan claims 

costs for prescription drugs translate into lower premiums for 

enrollees in later years. For example, we estimate that PBM savings in 

the form of rebates passed on to the two fee-for-service FEHBP plans we 

examined between 1998 and 2000 translate into about a 1-percent 

decrease from what the plans’ future premiums would have been. In 

contrast to savings through cost sharing and other benefit design 

features that accrue only to those enrollees who use the prescription 

drug benefit, PBM savings in the form of premium savings accrue to all 

enrollees, regardless of whether they use prescription drugs.



Enrollees Also Benefit from PBM Drug Utilization Review Programs and 

Customer Service:



Each FEHBP plan’s PBM provided a drug utilization review program to 

screen prescription drug therapies for such problems as adverse 

interactions, incorrect dosages, or improper duration of treatment. 

PBMs maintained a centralized database on each enrollee’s drug history 

and shared this information electronically with pharmacies at the time 

the prescription was filled. PBMs are often the only entity with 

complete information on a patient’s medications--particularly when 

enrollees are prescribed medication by more than one physician or fill 

prescriptions at different pharmacies. We have previously reported that 

automated drug utilization systems linked to a centralized database 

provide a more thorough prospective review and more benefits than 

reviews based on manual or local systems.[Footnote 21]



PBMs provide customer service when they interact directly with FEHBP 

enrollees, such as when enrollees contact the PBMs to seek information 

about their prescriptions, resolve problems with having their 

prescription drugs filled, or obtain drugs through the mail-order 

pharmacy. Customer service quality is measured against customer service 

standards negotiated between each FEHBP plan and PBM. These standards 

included such measures as phone call answer time, mail-order 

prescription turn-around time and accuracy rates, and customer 

satisfaction as measured through enrollee surveys. Data provided by the 

PBMs indicate that they generally met or exceeded these standards, 

although we did not independently verify these data.[Footnote 22]



Pharmacies Included in PBM Retail Networks Must Accept Discounted 

Prices and Perform Various Administrative Tasks:



Retail pharmacies that participate in the PBM networks used by FEHBP 

plans are affected by PBM policies and practices. For example, PBMs 

reimbursed pharmacies at levels below cash-paying customers, but above 

the pharmacies’ estimated drug acquisition costs. Processing PBM or 

other third-party prescriptions involves additional administrative 

requirements compared to cash transactions, and some PBMs may draw 

business away from retail pharmacies by providing savings and other 

incentives to encourage pharmacy customers to use PBMs’ mail-order 

pharmacies. Nevertheless, participation in the PBM retail networks is 

important for pharmacies because the PBMs serving the FEHBP plans we 

reviewed also contract with other clients that cumulatively represent a 

large share of the national population that purchase prescription and 

other nonprescription items from retail pharmacies.



PBMs Reimbursed Retail Pharmacies Less than Cash-Paying Customers but 

Above Estimated Costs:



PBMs for the three FEHBP plans we reviewed reimbursed retail pharmacies 

at rates below what a cash-paying customer would pay but still above 

the pharmacies’ estimated acquisition costs. The average price paid for 

a typical 30-day supply was nearly 18 percent below the cash-paying 

customer price for 14 selected brand-name drugs and 47 percent below 

the average case price for 4 selected generic drugs. As a result, the 

gross margin earned by retail pharmacies on the PBM transactions is 

lower on average than for cash-paying customers.[Footnote 23]



We estimate that these PBM discounted prices are higher on average than 

the pharmacies’ cost to acquire these drugs. Retail pharmacies 

typically purchase drugs from intermediary wholesale distributors and, 

to a lesser extent, from drug manufacturers directly. Because no data 

source exists to identify pharmacies’ actual acquisition costs for 

drugs, we used the wholesale acquisition cost (WAC) and added a mark-up 

of 3 percent to estimate pharmacy acquisition costs for drugs purchased 

from wholesalers.[Footnote 24] Accordingly, for the three FEHBP plans 

we reviewed, we estimate that the prices that the PBMs paid to retail 

pharmacies provided an average margin of about 8 percent above the 

pharmacies’ average acquisition costs for 10 brand drugs we reviewed.

[Footnote 25],[Footnote 26] These estimated margins on the drugs do not 

reflect a drug store’s profit on drug sales because store overhead and 

dispensing costs are not deducted.[Footnote 27] They also do not 

reflect the costs of drugs when purchased directly from manufacturers 

rather than wholesalers nor any rebates or discounts that pharmacies 

may receive from suppliers or manufacturers. Moreover, because WAC is 

an average of prices charged by manufacturers to multiple purchasers, 

it may not accurately reflect the acquisition costs for any 

individual retail pharmacy.



PBM Transactions Require Additional Administrative Tasks and Incur 

Higher Processing Costs for Retail Pharmacies:



PBM and other third-party transactions require pharmacy staff to 

undertake tasks not associated with cash-paying customer transactions, 

such as submitting claims electronically, responding to prior 

authorization requests, contacting physicians to approve formulary drug 

substitutions, and responding to patients’ questions about their health 

plan benefits. Pharmacists and pharmacy association representatives we 

interviewed indicated that the administrative requirements imposed by 

FEHBP-participating PBMs are generally similar to those imposed by PBMs 

associated with other health plans. Several studies have found that 

pharmacy staff spent significant time addressing third-party payment 

issues. For example, based on surveys of 201 retail pharmacies, one 

consultant found that 20 percent of pharmacy staff time was spent on 

activities directly related to third-party issues.[Footnote 28] A 

synthesis of multiple studies concluded that third-party prescriptions 

cost from $0.36 to $1.55 more than cash transactions to 

process.[Footnote 29]



Compared to larger chain pharmacies, independent pharmacies may find 

PBM processing tasks particularly burdensome or costly. For example, 

independent pharmacies may be more likely to use pharmacists to process 

third-party transactions because they tend to have fewer other staff 

available, such as pharmacy technicians and clerks, according to a 

retail pharmacy association official. One study found that the average 

labor cost to process third-party prescriptions that required pharmacy 

staff intervention (such as responding to an initial claim denial) was 

44 percent higher for an independent than a chain pharmacy. This study 

attributes the higher costs to the independent pharmacy’s greater 

reliance on pharmacists for performing certain third-party processing 

tasks.[Footnote 30]



PBMs Use Financial and Other Incentives to Steer Retail Pharmacy 

Customers to Mail-Order Programs:



PBMs may also attempt to steer some enrollees away from retail 

pharmacies to their mail-order pharmacies. Two of the PBMs we reviewed 

send letters to some enrollees who purchase medications at a retail 

pharmacy informing them that their costs under the mail-service 

pharmacy program would be lower. These letters may include forms to 

facilitate the transfer of the prescription from the retail to the 

mail-order pharmacy. In 2001, the three FEHBP plans we reviewed 

dispensed 21 percent of all prescriptions through mail order, a higher 

share than the industry average. Nationally, a growing but still small 

share of prescription drugs is dispensed through mail-order pharmacies-

-about 5 percent of prescriptions and 17 percent of prescription sales 

in 2001.[Footnote 31]



Most Pharmacies Participate in PBMs’ Retail Networks:



Most licensed pharmacies participate in the FEHBP PBMs’ retail pharmacy 

networks, in part because PBMs represent such a substantial market 

share-nearly 200 million Americans in 2001.[Footnote 32] Plan and PBM 

representatives noted that access to these enrollees benefits retail 

pharmacies by increasing traffic in the stores and thus sales of 

prescriptions and nonprescription items. According to NACDS, 

nonprescription sales nationally accounted for 5 percent of total sales 

for independent pharmacies and 39 percent of total sales for chain 

pharmacies in 2001.[Footnote 33] However, pharmacy association 

representatives report that PBMs’ large market shares leave many retail 

pharmacies with little leverage in negotiating with PBMs. These 

officials indicate that retail pharmacies may have to “take or leave” a 

PBMs’ proposed contract with actual negotiations only occurring in 

instances when a large chain will not accept the contractual terms or 

an independent pharmacy without nearby competitors in a rural area must 

be included to meet health plans’ access requirements. While it is 

difficult to assess how frequently these situations occur, chain 

pharmacies constituted 37 percent of all retail pharmacies and the top 

four chain drugs stores accounted for 30 percent of all pharmacy sales 

in 2000, according to NACDS.[Footnote 34]



PBMs Received Compensation from Plans and Payments from Manufacturers 

for Their FEHBP Business:



PBMs received compensation directly from FEHBP plans for administrative 

services and drug costs as well as payments from pharmaceutical 

manufacturers. (See fig. 3.) PBM earnings from administrative fees and 

payments for mail-order drugs paid by the plans we reviewed varied 

depending on contractual arrangements. In addition, the PBMs we 

reviewed varied as to whether they retained a portion of drug 

manufacturer rebates associated with the FEHBP contracts, and all the 

PBMs received other rebates or payments from drug manufacturers.



Figure 3: Overview of PBMs’ Compensation and Payment Sources:



[See PDF for image]



[End of figure]



Note: The extent to which a PBM receives compensation and payments from 

any one of these sources varies based on its contractual arrangements 

with plans and manufacturers. For example, some PBMs may contract with 

a separate entity to provide mail-order services.



Specifically, the PBMs we reviewed received administrative fees, 

payments for drugs, and manufacturer rebates for their FEHBP business. 

They also received other rebates or payments from drug manufacturers 

based on their entire line of business with a particular manufacturer.



Administrative fees. PBMs charged plans fees for a broad range of 

clinical and administrative services, including utilization reviews, 

prior authorization, formulary development and compliance, claims 

processing, and reporting. Administrative fees for plans we reviewed 

varied but on average accounted for about 1.5 percent of total plan 

drug spending in 2001.



Payments for Retail and Mail-Order Drugs. PBMs we reviewed retained 

little or no revenue from plan payments for retail drug costs and 

dispensing fees because they were largely passed through to retail 

pharmacies.[Footnote 35] While not disclosing their acquisition costs 

for mail-order drugs, PBM officials said that plan payments were 

somewhat higher than their payments to pharmaceutical manufacturers for 

mail-order drugs. Using the average manufacturer price (AMP) as a proxy 

for PBMs’ mail-order acquisition costs,[Footnote 36] we estimate that 

the discounted price for mail-order drugs that plans and enrollees paid 

were on average higher than the estimated mail-order acquisition cost 

for some (but not all) brand-name drugs and all generic drugs that we 

reviewed. On average, the AMP was about 2 percent below the plan prices 

for 7 of the 14 brand-name drugs we reviewed but about 3 percent higher 

than the plan prices for the other 7 brand-name drugs. The AMP was 

below plan prices for all four generic drugs we reviewed.



Rebates. PBMs shared with the FEHBP plans certain rebates that a drug 

manufacturer provides a PBM associated with their FEHBP business, 

although the extent to which the PBMs retained a portion of these 

rebates varied, depending on the contracts negotiated between the plans 

and PBMs. We estimate the rebates retained by the PBMs we reviewed 

represented less than half of one percent of total plan drug spending. 

The plans we reviewed varied as to whether they reimbursed PBMs 

separately for administrative services in exchange for a larger share 

of contractual rebates or they received less of the contractual rebates 

and were charged low or no fees for administrative services.



PBMs also received other manufacturer rebates or payments for services 

based on their total volume of a particular manufacturer’s drugs sold 

through FEHBP plans and other plans. For example, one PBM we reviewed 

earned additional manufacturer rebates for its efforts to increase drug 

manufacturers’ share of certain products. The PBMs also received fees 

from manufacturers for various services, such as encouraging physicians 

to change prescribing patterns, educational services to enrollees 

regarding compliance with certain drug regimens, and data reporting 

services. These rebates and other payments were a large portion of 

PBMs’ earnings, according to PBM officials and industry experts, but 

the actual amounts were undisclosed because they are proprietary. 

Public financial information suggests that manufacturer payments are 

important sources of earnings. For example, in financial reports 

submitted to the SEC, two of the PBMs we reviewed stated that 

manufacturer rebates and fees were key to their profitability.[Footnote 

37]



Concluding Observations:



PBMs are central to most FEHBP plan efforts to manage their 

prescription drug benefits, and PBMs have helped the FEHBP plans we 

reviewed reduce what they would likely otherwise pay in prescription 

drug expenditures while generally maintaining wide access to most 

retail pharmacies and drugs. As the cost of prescription drugs 

continues to increase, FEHBP plans are likely to encourage PBMs to 

continue to leverage their purchasing power with drug manufacturers and 

retail pharmacies and pass on the savings to the plans and their 

enrollees. However, attempts to achieve additional cost savings can 

involve trade-offs for plan enrollees. For example, additional savings 

through formulary management can accrue if more restrictive formularies 

are used, but enrollees would likely have unrestricted access to fewer 

drugs. Similarly, retail pharmacies may be willing to provide deeper 

discounts as part of smaller, more selective retail pharmacy networks. 

Smaller networks have the potential to draw more enrollees into 

participating stores but offer enrollees access to fewer retail 

pharmacies. OPM, FEHBP plans, and PBMs must balance these trade-offs in 

designing affordable and accessible prescription drug benefits for 

federal employees.



Agency and Other Comments and Our Evaluation:



We provided a draft of this report to OPM, the three plans and three 

PBMs we reviewed, two pharmacy associations (NACDS and NCPA), and two 

independent expert reviewers.



In written comments, OPM generally concurred with our findings. OPM 

highlighted the advantages and trade-offs associated with FEHBP plans’ 

use of PBMs in providing affordable drug benefits and providing 

enrollees with access to prescription drugs. Appendix II contains OPM’s 

comments.



The plans and PBMs reviewed the report for the accuracy of information 

regarding their arrangements and provided technical comments regarding 

information we reported about them, which we incorporated as 

appropriate. Two independent external experts on pharmaceutical drug 

pricing who were not affiliated with PBMs, pharmacies, or drug 

manufacturers indicated that the draft was fair and balanced. They also 

provided technical comments that we incorporated as appropriate.



In oral comments, NACDS’ Vice President for Policy and Programs 

expressed strong concerns, particularly focusing on the scope of our 

work, and NCPA’s Senior Vice President for Government Affairs and 

General Counsel separately informed us that he generally concurred with 

NACDS’ comments. NACDS’ concerns included the following:



* Our draft did not adequately address the overall PBM industry and how 

it operates, including special economic relationships that may exist 

between some drug manufacturers and PBMs. The NACDS representative 

stated that these relationships create incentives for PBMs to encourage 

use of certain manufacturers’ drugs even if they are more costly to the 

plan or enrollees. As we noted in the draft, we were asked to examine 

the role of PBMs specifically for FEHBP-participating plans and 

enrollees, not the PBM industry in general. While the savings we report 

through discounts, rebates, and certain interventions do not reflect 

whether PBMs encourage higher-cost drugs, the FEHBP plans we reviewed 

informed us they believed they saved money from using PBMs. 

Relationships between PBMs and manufacturers and pharmacies for other 

plans were beyond the scope of this report. In response to the concern 

about PBMs’ influence on drug switching, we added information based on 

two PBMs’ filings with the SEC regarding an ongoing Department of 

Justice investigation of certain PBMs’ relationships with 

pharmaceutical manufacturers and retail pharmacies.



* The draft report did not include information about all three plans’ 

use of generic drugs, which is one means to reduce the overall cost of 

the drug benefit. In the draft report, we addressed savings PBMs 

achieve through direct interventions to switch from a prescribed brand 

drug to a generic, as opposed to overall generic use rates, which are 

affected by other factors such as plans’ benefit designs. To clarify 

our findings, we added information on the relative use of generic drugs 

among the retail and mail order pharmacy services for the plans we 

reviewed.



* Our finding that the PBMs we reviewed retained little or no 

compensation from the payments they receive from plans for retail drugs 

because they pass these payments on in total to the retail pharmacies 

seemed inconsistent with NACDS’ experience. While PBMs’ contractual 

arrangements with other plans may differ, the contractual arrangements 

with the FEHBP-participating plans we reviewed resulted in the PBMs 

passing through to the retail pharmacies the entire payment that they 

receive from the plans.



* Our estimate that retail pharmacies’ drug acquisition costs are on 

average about 8 percent below the payments they receive from the FEHBP 

plans we reviewed implies this is a profit and does not adequately 

acknowledge overhead costs. Our draft report stated that this estimated 

margin does not reflect a retail drug store’s profit because it does 

not include overhead costs nor certain other savings that may be 

available to some drug stores. We revised the report to better clarify 

this point and added information regarding NACDS’ and other recent 

studies’ estimates of overhead costs for retail pharmacies on a per 

prescription basis.



We are sending copies of this report to the Director of the Office of 

Personnel Management, appropriate congressional committees, and other 

interested parties. We will also make copies available to others upon 

request. This report is also available at no charge on GAO’s Web site 

at http://www.gao.gov.



If you or your staff have any questions, please call me at (202) 512-

7118. Another contact and key contributors to this assignment are 

listed in appendix III.



Sincerely yours,



signed by Kathryn G. Allen:



Kathryn G. Allen

Director, Health Care--Medicaid

 and Private Health Insurance Issues:



[End of section]



Appendix I: Scope and Methodology:



We examined the use of pharmacy benefit managers (PBM) by three Federal 

Employees Health Benefits Program (FEHBP) plans: Blue Cross and Blue 

Shield (BCBS), Government Employees Hospital Association (GEHA), and 

PacifiCare of California. Together, these plans accounted for about 55 

percent of the 8.3 million people covered through FEHBP plans as of 

July 2002 and represented various plan types and PBM 

contractors.[Footnote 38] BCBS contracted with the two largest PBMs in 

the United States, Medco Health Solutions and AdvancePCS, for its 

pharmacy benefit services. GEHA contracted with Medco Health Solutions 

and PacifiCare of California contracted with Prescription Solutions, 

another subsidiary of PacifiCare Health Systems.



We reviewed contracts between the PBMs and plans, financial statements 

regarding payments made between the plans and PBMs, and retail and 

mail-order prices for selected drugs from the FEHBP plans we reviewed 

and the PBMs with which they contracted. We also obtained pricing 

information from retail pharmacies, interviewed officials at the Office 

of Personnel Management (OPM), the federal agency responsible for 

administering FEHBP, and associations representing PBMs and retail 

pharmacies, and reviewed studies regarding the use of PBMs and 

prescription drug payments.



Specifically, to assess the drug discount savings PBMs achieved, we 

selected 18 drugs that were among the drugs with the highest 

expenditures or number of prescriptions dispensed based on data 

reported by the plans. Combined, these 18 high-volume/high-expenditure 

drugs represented 12 percent of all prescriptions dispensed to 

enrollees of the selected FEHBP plans and 16 percent of total plans’ 

drug expenditures in 2001. In selecting these drugs, we also sought to 

ensure a distribution of generic and brand drugs for a range of 

treatment conditions sold by different drug manufacturers. Table 4 

lists the drugs included in our price comparisons.



Table 4: Selected High-Volume or High-Expenditure Drugs for 3 FEHBP 

Plans:



Drug name (strength) and dosage form: Brand; Condition for which drug 

is used[A]: [Empty].



Drug name (strength) and dosage form: Aciphex (20 mg), tablets; 

Condition for which drug is used[A]: Ulcers.



Drug name (strength) and dosage form: Allegra (180 mg), tablets; 

Condition for which drug is used[A]: Allergies.



Drug name (strength) and dosage form: Celebrex (200 mg), capsules; 

Condition for which drug is used[A]: Arthritis.



Drug name (strength) and dosage form: Celexa (20 mg), tablets; 

Condition for which drug is used[A]: Depression.



Drug name (strength) and dosage form: Claritin (10 mg), tablets; 

Condition for which drug is used[A]: Allergies.



Drug name (strength) and dosage form: Fosamax (70 mg), tablets; 

Condition for which drug is used[A]: Osteoporosis.



Drug name (strength) and dosage form: Lipitor (10 mg), tablets; 

Condition for which drug is used[A]: Cholesterol.



Drug name (strength) and dosage form: Lotensin (20 mg), tablets; 

Condition for which drug is used[A]: High blood pressure.



Drug name (strength) and dosage form: Norvasc (5 mg), tablets; 

Condition for which drug is used[A]: High blood pressure.



Drug name (strength) and dosage form: Paxil (20 mg), tablets; Condition 

for which drug is used[A]: Depression.



Drug name (strength) and dosage form: Premarin (0.625 mg), tablets; 

Condition for which drug is used[A]: Osteoporosis.



Drug name (strength) and dosage form: Prevacid (30 mg), capsules; 

Condition for which drug is used[A]: Ulcers.



Drug name (strength) and dosage form: Prilosec (20 mg), capsules; 

Condition for which drug is used[A]: Ulcers.



Drug name (strength) and dosage form: Zocor (20 mg), tablets; Condition 

for which drug is used[A]: Cholesterol.



Drug name (strength) and dosage form: Generic; Condition for which drug 

is used[A]: [Empty].



Drug name (strength) and dosage form: Albuterol (90 mcg), aerosol; 

Condition for which drug is used[A]: Asthma.



Drug name (strength) and dosage form: Atenolol (50 mg), tablets; 

Condition for which drug is used[A]: High blood pressure.



Drug name (strength) and dosage form: Furosemide (40 mg), tablets; 

Condition for which drug is used[A]: High blood pressure.



Drug name (strength) and dosage form: Hydrocodone with Acetaminophen 

(5-500 mg), tablets; Condition for which drug is used[A]: Pain.





Source: Rx List at http://www.rxlist.com/.



[A] These drugs may also be used be used to treat conditions other than 

those listed in the table.



[End of table]



At our request, the plans provided prices paid as of April 2002 for the 

most common strength, dosage form, and quantity dispensed for these 

drugs at retail pharmacies (typically, a 30-day supply) and at mail-

order pharmacies (typically, a 90-day supply).[Footnote 39] Prices 

represent the plan and enrollees’ share of the drug ingredient cost--

expressed as a discount from an industry standard price such as the 

average wholesale price (AWP)[Footnote 40] or maximum allowable cost 

(MAC)[Footnote 41]--plus a dispensing fee. We did not independently 

verify the accuracy of these plan-reported prices.



To compare prices negotiated with PBMs for retail and mail-order 

prescriptions to cash prices a customer without third-party coverage 

would pay at retail pharmacies, we surveyed 36 pharmacies in 

California, North Dakota, Washington, D.C., and the Virginia and 

Maryland suburbs of Washington, D.C., from April 18 through April 30, 

2002. We selected the locations to be geographically diverse, 

specifically including California because it is the only state in which 

PacifiCare of California operates, North Dakota to include a state with 

a low population density, and the Washington, D.C., metropolitan area 

because it includes a large number of FEHBP enrollees. We randomly 

selected 12 pharmacies in each of these areas, including both large 

chain pharmacies and independent or small chain pharmacies. We 

determined that each of the pharmacies surveyed participated in the 

retail networks for each of our selected FEHBP plans serving that area. 

From each pharmacy, we obtained prices for a 30-day supply of the 18 

selected drugs. These prices are applicable only to the pharmacies 

surveyed and at the time they were obtained.



We also compared prices plans paid to retail and mail-order pharmacies 

to the pharmacies’ estimated acquisition costs. Retail pharmacies 

typically purchase drugs from intermediary wholesale distributors and-

-to a lesser extent--drug manufacturers, while PBM-owned mail-order 

pharmacies more typically purchase drugs from manufacturers. Since no 

data source exists to identify pharmacy acquisition costs, we estimated 

retail pharmacies’ acquisition costs for drugs purchased from 

wholesalers using the wholesale acquisition prices (WAC) reported in 

Red Book, a compilation of drug pricing data published by Medical 

Economics Company, Inc., as of April 2002.[Footnote 42] We added 3 

percent to WAC to estimate the wholesalers’ margin, based on 

information provided by retail pharmacy officials. To estimate mail-

order pharmacies’ acquisition costs for drugs purchased directly from 

drug manufacturers, we used industry-reported and confidential average 

manufacturers’ price information (AMP) obtained from the Centers for 

Medicare & Medicaid Services. We selected WAC and AMP prices for our 18 

selected drugs using the most common national drug code reported by the 

plans for reimbursing retail and mail-order prescription 

claims.[Footnote 43] The acquisition costs we have estimated cannot be 

generalized beyond the drugs we reviewed. Also, the acquisition costs 

we reported are based on averages for the drugs we reviewed, and 

individual pharmacies or mail-order operations may have higher or lower 

acquisition costs.



To assess enrollee access to prescription drugs, we compared the number 

of retail pharmacies in the plans’ retail pharmacy networks to the 

total number of licensed retail pharmacies in California, the District 

of Columbia, Maryland, North Dakota, and Virginia. To examine the 

breadth and depth of each plan’s formulary, we compared each plan’s 

formulary to the National Formulary developed by the Department of 

Veterans Affairs (VA). Although the VA formulary was designed for the 

veteran-specific population, it is considered by the Institute of 

Medicine as not overly restrictive based on its comparison with other 

formularies and clinical literature.[Footnote 44] We obtained the 

National Formulary from the VA’s Pharmacy Benefits Management Strategic 

Healthcare Group. The VA formulary contains approximately 1,200 items, 

including generic, brand name, and over-the-counter drugs, devices, and 

supplies. We requested that VA officials remove devices, supplies, and 

drugs that are usually prescribed on an in-patient basis or are 

available over-the-counter because the FEHBP plans we reviewed cover 

inpatient drugs as part of the hospital benefit and do not cover drugs 

available over-the-counter. The resulting list included 513 outpatient 

prescription drugs representing 162 therapeutic classes. To examine the 

breadth and depth of each plan’s formulary relative to these outpatient 

prescription drugs from the VA formulary, we determined whether each of 

the drugs and therapeutic classes included on the list of drugs drawn 

from the VA formulary was also included on each of the plan 

formularies. Each plan also provided us with examples of 

therapeutically equivalent drugs included on the plan’s formulary for 

drugs that did not have an exact match on the VA formulary list. We 

considered a VA therapeutic class to be included on a plan formulary if 

at least one of the VA drugs in that class or a therapeutically 

equivalent drug was listed in the plan formulary. For VA therapeutic 

classes not included on a plan formulary, we used National Institutes 

of Health and Medco Health Solutions on-line databases to analyze the 

types of medical conditions treated by the excluded drugs within these 

classes.



[End of section]



Appendix II: Comments from the Office of Personnel Management:



UNITED STATES OFFICE OF PERSONNEL MANAGEMENT WASHINGTON, DC 20415-1000:



Ms. Kathryn G. Allen:



Director, Health Care --Medicaid and Private Health Insurance Issues 

U.S. General Accounting Office Washington, D.C. 20548:



Dear Ms. Allen:



Thank you for the opportunity to comment on draft report FEDERAL 

EMPLOYEES’HEALTH BENEFITS: Effects of Using Pharmacy Benefit Managers 

on Health Plans, Enrollees, and Pharmacies (GAO-03-196).



We have always believed our health plans’ private sector Pharmacy 

Benefit Management (PBM) partners help our health plans provide 

affordable drug benefits that meet our enrollees’ needs and help keep 

costs down. I was pleased to see you determined that PBMs do help keep 

costs down while offering excellent access to prescriptions for our 

consumers. We understand and agree that PBMs add administrative costs, 

but that they are not excessive.



The President’s health care agenda is based on patient-centered health 

care, preservation of choice and excellent quality. The Federal 

Employees Health Benefits (FEHB) Program is a competitive model and 

health plans offer the benefits that they believe their current 

enrollees want and that would also be attractive to prospective 

enrollees. Our consumers are also price sensitive, so health plans make 

efforts to offer their benefit packages at affordable prices. FEHB is 

market-driven - aspects of the insurance industry that work in the 

private sector are also reflected in the FEHB Program. Many private 

sector employers take advantage of the opportunities offered through 

the use of PBMs.



Your review of PBMs in the FEHB Program rightly points out the 

advantages of PBMs as well as the trade-offs. Our Federal consumers 

have come to expect convenient and easy-to-use pharmacy benefits 

programs that offer abroad range of affordable prescription drugs. The 

role of the Office of Personnel Management (OPM) as a purchaser is to 

balance our consumers’ expectations for comprehensive benefits against 

cost implications and marketplace realities. We believe our traditional 

private-sector partnerships have allowed us to deliver the goods and 

services our consumers want and to help keep the FEHB Program on the 

cutting-edge of employer-sponsored benefit programs.



It should be pointed out that OPM’s reliance on the private sector is 

fundamental. The private sector PBMs must generate income above actual 

costs in order to stay in business, as is the case in any market. That 

is why, for example, net pharmacy acquisition costs are incorporated 

into the negotiated price health plans pay for the services offered by 

PBMs. The fundamentals of the market place also contribute to the 

reasons why some pharmacies devote more resources to managing their 

PBM business than others do. Likewise, the customer service component 

of each type of vendor plays a big role in building customer business 

and retention.



We have also provided comments on several technical issues related to 

the draft report in the enclosure.



Thank you, again, for the opportunity to comment.



Sincerely,



Signed by Kay Coles James:



Kay Coles James

Director:



[End of section]



Appendix III: GAO Contact and Staff Acknowledgments:



GAO Contact:



John Dicken (202) 512-7043:



Acknowledgments:



The following staff made important contributions to this report: 

Rashmi Agarwal, Randy Dirosa, Betty Kirksey, Carmen Rivera-Lowitt, and 

Annesha White.



[End of section]



Related GAO Products:



VA and DOD Health Care: Factors Contributing to Reduced Pharmacy Costs 

and Continuing Challenges. GAO-02-969T. Washington, D.C.: 

July 22, 2002.



Medicare Outpatient Drugs: Program Payments Should Better Reflect 

Market Prices. GAO-02-531T. Washington, D.C.: March 14, 2002.



Prescription Drugs: Prices Available Through Discount Cards and From 

Other Sources. GAO-02-280R. Washington, D.C.: December 5, 2001.



Medicare: Payments for Covered Outpatient Drugs Exceed Providers’ Cost. 

GAO-01-1118. Washington, D.C.: September 21, 2001.



VA Drug Formulary: Better Oversight Is Required, but Veterans Are 

Getting Needed Drugs. GAO-01-183. Washington, D.C.: January 29, 2001.



Prescription Drugs: Adapting Private Sector Management Methods for a 

Medicare Benefit. GAO/T-HEHS-00-112. Washington, D.C.: May 11, 2000.



Prescription Drug Benefits: Applying Private Sector Management Methods 

to Medicare. GAO/T-HEHS-00-84. Washington, D.C.: March 22, 2000.



Pharmacy Benefit Managers: FEHBP Plans Satisfied With Savings and 

Services, but Retail Pharmacies Have Concerns. GAO/HEHS-97-47. 

Washington, D.C.: February 21, 1997.



FOOTNOTES



[1] William M. Mercer Incorporated, Mercer/Foster Higgins National 

Survey of Employer-Sponsored Health Plans 2001, (New York: 2002).



[2] BCBS and GEHA are fee-for-service plans, while PacifiCare of 

California is a health maintenance organization (HMO).



[3] OPM has overall administrative responsibility for FEHBP and 

authority to contract with private plans, including fee-for-service 

insurers and HMOs, to operate the program. As of July 2002, OPM had 

contracts with 183 participating plans.



[4] These prices represent the combined enrollee and plan portion paid.



[5] Cash prices refer to the price paid for a prescription without any 

insurance or other third-party coverage.



[6] Formularies include lists of prescription drugs, grouped by 

therapeutic class (groups of drugs that are similar in chemistry, 

method of action, and purpose of use), that health plans or insurers 

encourage physicians to prescribe and beneficiaries to use.



[7] We used the VA formulary as a benchmark for comparison because the 

Institute of Medicine has determined that it is not overly restrictive. 

The IOM committee also concluded that the VA formulary is in some 

respects more but in many respects less restrictive than other public 

or private formularies. See David Blumenthal and Roger Herdman editors, 

VA Pharmacy Formulary Analysis Committee, Division of Health Care 

Services, Institute of Medicine, Description and Analysis of the VA 

National Formulary (National Academy Press, Washington, D.C.: 2000). 



[8] In addition to greater discounts, mail-order programs also save 

money for plans because only one dispensing fee is assessed for a 

typical 90-day supply of drugs rather than three dispensing fees for 

each of three 30-day supplies at retail pharmacies. Accounting for the 

dispensing fee savings for a 90-day supply, effective average discounts 

from cash-paying customer prices rise slightly from 27.3 to 27.7 

percent for the selected brand drugs and from 52.5 to 59.1 percent for 

the selected generic drugs. Two of the three plans we reviewed limit 

coverage for prescriptions dispensed at retail pharmacies to a 30-day 

supply. The third plan limits coverage for retail prescriptions up to 

an initial 34-day supply but allows up to a 90-day supply for 

subsequent prescriptions under its lower option; it allows 90-day 

supplies for all prescriptions under its higher option. We did not 

survey retail pharmacies for drug prices for a 90-day supply.



[9] Medicaid reimbursement and cash-paying customer prices are for 

California, North Dakota, Washington, D.C., and the Virginia and 

Maryland suburbs of Washington, D.C.



[10] Under FEHBP, plans may negotiate rebates as part of contractual 

agreements with PBMs. In contrast, as a condition of Medicaid coverage 

for outpatient drugs, manufacturers are required to provide state 

Medicaid programs with certain rebates. For brand name drugs, Medicaid 

rebates must be a minimum of 15.1 percent of the average manufacturers’ 

price (AMP). For the 14 brand name drugs we reviewed, we estimate that 

the minimum Medicaid rebate would reduce costs by an average of at 

least 12 percent. For generic drugs, Medicaid rebates must equal 11 

percent of the AMP, which we estimate would reduce costs by an average 

of about 2 percent for the 4 generic drugs we reviewed. Moreover, 

states may negotiate additional rebates with manufacturers in order to 

reduce costs. 



[11] Plans did not have estimates for all of their intervention 

techniques. 



[12] Savings from concurrent utilization review may be reduced if an 

enrollee subsequently obtains a prescription or refill. One PBM 

estimated savings for claims denied for early refills only if a refill 

had not been obtained within 14 days.



[13] While plans reported savings from therapeutic interchange, 

concerns have been raised that in some cases PBMs’ relationships with 

manufacturers and retail pharmacies influence PBM interventions, such 

as substituting higher-cost drugs when lower-cost therapeutic 

equivalent drugs are available. Medco Health Solutions and Advance PCS 

filings with the SEC indicate that the Department of Justice is 

undertaking an industrywide investigation to examine PBM relationships 

with pharmaceutical manufacturers and retail pharmacies and PBMs’ 

programs related to drug formulary compliance, which includes rebates 

and other payments made by manufacturers to PBMs. The SEC filings show 

that the Department of Justice is also investigating payments made by 

PBMs to retail pharmacies or others in connection with PBM 

interventions. 



[14] The states are California, the District of Columbia, Maryland, 

North Dakota, and Virginia. Estimates of pharmacy participation rates 

are approximate because of ongoing changes in the number of pharmacies 

licensed in each state and included in each PBM network and because PBM 

retail pharmacy networks may include a small number of nonretail 

pharmacies, such as hospital pharmacies. In 2002, BCBS began offering a 

basic option to FEHBP enrollees that includes about 70 percent as many 

pharmacies nationwide as the BCBS standard option but still meets 

contractual standards for a retail pharmacy to be located within a few 

miles of nearly all basic option enrollees. More than 200,000 people 

are in BCBS’s basic option compared to about 3.8 million people in the 

standard option.



[15] Formularies may be developed by the plan with suggestions for 

changes from a PBM, or entirely by a PBM and used by the plan. BCBS and 

PacifiCare designed their own formularies, while GEHA used a formulary 

developed by Medco Health Solutions. Decisions on inclusion of drugs in 

a formulary are typically made by a pharmacy and therapeutics committee 

composed of physicians and pharmacists. Plan officials and documents 

described such committees as being designed to evaluate the safety, 

efficacy, and cost of drugs in all therapeutic categories before 

recommending drugs for inclusion on the formulary. Plans we reviewed 

had no or few committee members affiliated with the plan or PBM. 



[16] See Blumenthal and Herdman, Description and Analysis of the VA 

National Formulary.



[17] BCBS excluded from its formulary 7 percent of the VA therapeutic 

classes, which contain drugs to treat insect stings, itching, psoriasis 

and other skin disorders, erectile dysfunction, certain types of 

rheumatoid arthritis, fungal eye infections, lung diseases where mucous 

complicates the condition, constipation, and a topical anesthetic and 

water inhaler. GEHA excluded from its formulary 2 percent of the VA 

therapeutic classes, which contain drugs to treat opiate (e.g., heroin, 

morphine) dependence, constipation, and a topical anesthetic. 

PacifiCare of California excluded from its formulary 5 percent of the 

VA therapeutic classes, which contain drugs to treat various 

infections, opiate (e.g., heroin, morphine) dependence, psoriasis and 

other skin disorders, erectile dysfunction, and inflamed gingiva. 

PacifiCare of California’s formulary also did not include several 

injectable drugs that are covered separately under the plan’s medical 

benefit. 



[18] OPM indicates that, in conducting annual negotiations with plans, 

it seeks to ensure enrollee access to nonformulary drugs although such 

access may involve higher cost sharing requirements. 



[19] A plan’s pharmacy benefit design includes the drugs a plan will 

cover through its formulary, the quantities in which drugs will be 

dispensed, the sources from which drugs may be obtained, and enrollee’s 

cost-sharing requirements, such as copayments. 



[20] For most HMOs, the premium rate is based on rates charged to the 

two employer groups closest in size to the plan’s FEHBP enrollment. 

Because these premiums are based on the HMO’s overall premium setting 

strategies and not just the FEHBP claims experience, the extent to 

which rebates and other PBM savings for the plan’s FEHBP business would 

yield lower premiums depends on the HMO’s current market strategies for 

setting competitive premiums and passing on lower costs in the form of 

lower premiums to FEHBP and similarly sized groups. About 30 percent of 

FEHBP enrollees are covered under an HMO plan.



[21] U.S. General Accounting Office, Prescription Drugs: Automated 

Prospective Review Systems Offer Potential Benefits for Medicaid, GAO/

AIMD-94-130 (Washington, D.C.: 

Aug. 5, 1994).



[22] Contracts called for the PBMs to regularly report to the plans 

their actual performance in relation to the standards and usually 

provided plans with the right to audit these performance reports and 

impose penalties or terminate the contract if PBM performance fell 

below the standards. In a few recent instances, financial penalties 

were imposed when performance temporarily fell short of a standard. For 

example, one PBM paid a penalty of $40,000 for failing to meet the plan 

standard concerning call answer time during 2 months of 2001, but the 

PBM met the standard during the remainder of the year.



[23] In 2001, about 16 percent of all prescriptions were purchased by 

customers who paid the entire cost without any third-party coverage, 

and the remainder were paid by customers with third-party payers, 

including Medicaid, according to the National Association of Chain Drug 

Stores. 



[24] WAC is a published, industry-reported measure of the average price 

manufacturers charge wholesalers. According to retail pharmacy 

representatives, wholesalers sell drugs to retail pharmacists for about 

1 to 3 percent above WAC on average. WAC does not include rebates or 

discounts manufacturers may offer to wholesalers. 



[25] Margins on drugs represent the portion of PBM drug reimbursements 

(including dispensing fees) and enrollees’ share of costs that exceed 

the pharmacy’s acquisition costs for the selected drugs. Retail plan 

prices represent 10 of the 14 brand-name drugs we examined because the 

wholesale acquisition cost was not available for the other 4 brand-name 

drugs. The PBM negotiated prices were also higher than the estimated 

acquisition costs for all four generic drugs we reviewed. 



[26] The U.S. Department of Health and Human Services Office of 

Inspector General recently released estimates of pharmacy acquisition 

costs for drugs reimbursed by state Medicaid programs. Using its 
approach 

to estimate the acquisition costs for the drugs we reviewed would 
result 

in prices that PBMs paid retail pharmacies providing an average margin 

of about 6 percent above the pharmacies’ average acquisition costs for 

the 10 brand drugs and about 14 percent above for the 4 generic drugs. 

See Department of Health and Human Services, Office of Inspector 

General, Medicaid Pharmacy - Additional Analyses of the Actual 

Acquisition Cost of Prescription Drug Products, (Washington, D.C.: 

September 2002).



[27] While it was not possible to identify the pharmacies’ overhead 

costs for the 18 drugs we reviewed, recent studies done for the 

California and Texas Medicaid programs estimate that the median 

dispensing costs for pharmacies participating in these states’ Medicaid 

programs were about $6.95 and $5.95 per prescription, respectively. See 

Myers and Stauffer LC, “Study of Medi-Cal Pharmacy 

Reimbursement,”(Missouri: June 2002) and “Determination of the Cost of 

Dispensing Pharmaceutical Prescriptions for the Texas Vendor Drug 

Program,” (Missouri: August 2002). The National Association of Chain 

Drug Stores (NACDS) estimates that retail pharmacies’ dispensing costs 

were on average $7.26 per prescription in 2001. See NACDS, The Chain 

Pharmacy Industry Profile 2002 (Alexandria, Virginia: 2002).



[28] Arthur Andersen LLP, Pharmacy Activity Cost and Productivity 

Study, November 1999.



[29] Richard N. Herrier et al., “Case Study Using Descriptive Analysis 

to Estimate Hidden Costs In Processing Third Party Prescriptions,” 

Journal of the American Pharmaceutical Association, 40, no. 5 

(September/October 2000). In addition to synthesizing other studies, 

this study also conducted time and motion measurement of retail 

pharmacies and based on this new research estimated that third-party 

prescriptions cost an average of $0.44 to $0.61 more than cash 

transactions to process.



[30] Richard N. Herrier, et al.



[31] National Association of Chain Drug Stores, The Chain Pharmacy 

Industry Profile, 2002 (Alexandria, VA: 2002). 



[32] Independent pharmacies were somewhat less likely to participate in 

FEHBP PBM retail networks than chain pharmacies. For example, we found 

that all but one of the pharmacies not participating in two PBM retail 

networks in the District of Columbia were independent. Similarly, a 

2001 survey of pharmacies in Connecticut, New Jersey, New York, and 

Pennsylvania by the Pharmaceutical Care Management Association found 

independent drug stores somewhat less likely to participate in PBM 

retail networks (96.5 percent) than chain drug stores (99.9 percent). 

According to a pharmacy industry representative, independent pharmacies 

may have fewer staff available to manage third-party transactions and 

contracting functions. In addition, certain PBM contract requirements 

can pose a challenge, such as requiring the use of computer systems or 

software that may be unaffordable to some small, independent 

pharmacies, according to another pharmacy industry representative.



[33] National Association of Chain Drug Stores, The Chain Pharmacy 

Industry Profile, 2002 (Alexandria, VA: 2002).



[34] National Association of Chain Drug Stores, The Chain Pharmacy 

Industry Profile, 2002 (Alexandria, VA: 2002) and Booz Allen Hamilton, 

Medicare-endorsed Prescription Drug Card Assistance Initiative, 

(McLean, VA: 2002). 



[35] The plan and enrollees share the cost of retail drugs, with the 

enrollee share paid directly to the retail pharmacy.



[36] The AMP is the average price paid to a drug manufacturer by 

wholesalers for prescription drugs distributed to the retail pharmacy 

class of trade, after deducting customary prompt pay discounts. AMP was 

created by the Omnibus Budget Reconciliation Act of 1990 (Pub. L. No. 

101-508, § 4401, 104 Stat. 1388, 1388-156) for determining Medicaid 

rebates and is not publicly available. It is calculated by the 

manufacturer and submitted to the Centers for Medicare & Medicaid 

Services, the federal agency that determines Medicaid rebates. 



[37] See AdvancePCS, 10-K Form filed with SEC on June 28, 2002 and 

Medco Health Solutions Form S-1, filed with SEC on April 17, 2002. A 

10-K Form is an annual report that many for-profit corporations must 

file with SEC within 90 days of the close of their fiscal year and a S-

1 Form is a basic registration form that may be used to register a 

proposed public offering with SEC. These publicly available documents 

contain audited financial statements and other information on a 

corporation’s financial condition. 



[38] BCBS and GEHA are fee-for-service plans, while PacifiCare of 

California is a health maintenance organization (HMO).



[39] We were unable to obtain the retail and mail-order price for one 

drug from one plan because the drug was not available on the plan’s 

formulary at the specified strength.



[40] Drug manufacturers suggest a list price that wholesalers charge 

pharmacies. The average of the list prices, collected for many 

wholesalers, is called a drug’s AWP.



[41] MACs represent upper limit prices that an insurer or health plan 

will reimburse for generically available or multiple source 

medications. 



[42] Red Book CD-ROM, vol. 24 (April 2002).



[43] National Drug Codes (NDCs) are the universal product identifiers 

for drugs for human use and are unique for each chemical entity, dosage 

form, manufacturer, strength, and package size. 



[44] See IOM, Description and Analysis of the VA National Formulary. 

The IOM used several criteria to assess the restrictiveness of the VA 

formulary, including how the VA formulary compares to formularies used 

in other public and private health care systems, and how it compares to 

reasonableness standards in the literature. The IOM committee also 

concluded that the VA formulary is in some respects more but in many 

respects less restrictive that other public or private formularies. The 

VA formulary does not contain specific types of drugs, such as 

pediatric drugs, that typically would be covered by the FEHBP plans we 

reviewed. 



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