Comment from Tim Dube (Senior Vice President of Policy & Regulatory Affairs at the Pharmaceutical Care Management Association)

Summary: The Pharmaceutical Care Management Association (PCMA), representing pharmacy benefit managers, supports the DOJ and FTC's efforts to provide regulatory predictability and guidance on business collaborations. They specifically advocate for the reinstatement of the 2000 Business Collaboration Guidelines and request that the agencies examine how wholesaler-owned pharmacy services administrative organizations (PSAOs) and conditional discounting practices might impact competition and drug pricing.