"NCPA's ... policy recommendations ... include: [1] Support for the [DOL's] recommendation to require PBMs to disclose all direct and indirect compensation to ERISA plans, to evaluate whether compensation to PBMs, pharmacies (including those owned by PBMs) and subcontractors are 'reasonable.' [2] Collaboration with DOL to create a standardized definition of what constitutes 'brand,' 'generic,' 'specialty,' and 'rebate' for the purposes of eliminating confusion in ERISA drug plan designs. [3] Endorsement of federal and state transparency efforts surrounding PBM 'maximum allowable cost' lists for generic prescription drugs. [4] Increased scrutiny of the conflicts of interest that can be attributed to PBMs operating as both a reimburser and competitor in the pharmacy marketplace."  MORE >>