The U.S. Chamber submitted comments to the Federal Trade Commission in response to its Solicitation for Public Comments on the Impact of Pharmacy Benefit Managers. The Chamber expressed three major points in the comments:First, the FTC should analyze PBMs in an objective and empirical manner consistent with past reviews. It is critical that the FTC always conduct evaluations without bias and simply assess and follow the facts to draw conclusions from any analysis. During the past two decades, and under the leadership of both Republican and Democratic Chairs, the FTC has repeatedly examined PBMs and found that they can enhance consumer welfare. Second, and relatedly, the Chamber has serious concerns that the FTC’s current Solicitation is structured to elicit biased information about PBM business practices, their impact on patients, physicians, employers, and independent and chain pharmacies. Almost every single question appears to presuppose negative intent and actions. The Chamber stro

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