Request for Information Regarding the Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule

The American Pharmacists Association (APhA) appreciates the opportunity to provide the Department of the Treasury (DOT), Internal Revenue Service (IRS), Department of Labor (DOL), Employee Benefits Security Administration (EBSA), Department of Health and Human Services (HHS), and Centers for Medicare and Medicaid Services (CMS) (collectively "the Departments") with comments on "Request for Information Regarding the Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule." APhA and the Departments agree that "transparency in healthcare pricing is a priority."1 APhA supports efforts that lead to greater price transparency, as increased transparency will enable patients to make more informed decisions about their health. However, APhA has concerns regarding the utilization of this information by certain entities, such as pharmacy benefit managers (PBMs), within the drug supply chain, which could manipulate the data to lower reimbursements for pharmacies at a loss when dispensing medications, which will jeopardize patient access to needed medications. Additionally, APhA notes that as patients get access to this information, they will come to the pharmacy with questions and expectations that they only have to pay the price obtained from the prescription drug machine-readable file at that pharmacy counter; thus, any education or services provided by a pharmacist represents an unfunded mandate on our nation's pharmacists for these insurance benefit consultations that should be compensated by both commercial and public (Medicare and Medicaid) health plans. APhA is the only organization advancing the entire pharmacy profession. APhA represents pharmacists, student pharmacists, and pharmacy technicians in all practice settings, including but not limited to community pharmacies, hospitals, long-term care facilities, specialty pharmacies, community health centers, physician offices, ambulatory clinics, managed care organizations, hospice settings, and government facilities. Our members strive to improve medication use, advance patient care, and enhance public health. [1] Request for Information Regarding the Prescription Drug Machine-Readable File Requirement in the Transparency in Coverage Final Rule, 90 Fed. Reg. 23303, 23303 (June 2, 2025). Available at: https://www.federalregister.gov/d/2025-09858/p-20.