FTC Reached PBM Settlements on Insulin Pricing
Pharmacy benefit managers must adjust formulary management and payment practices for insulin products.
Updated on Sept. 22, 2026 in Healthcare

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The Federal Trade Commission has finalized settlement agreements with Express Scripts and CVS Caremark regarding rebate and incentive practices in the insulin market. The rulings establish new mandates for how these pharmacy benefit managers handle drug formularies and pharmacy payments.
Why it matters
The FTC pursued these agreements after investigating business practices it claimed contributed to inflated prescription drug costs. Operators should monitor whether these changes influence broader pharmaceutical pricing trends or spur the adoption of alternative benefit models.
The Federal Trade Commission reached settlements with two major pharmacy benefit managers, Express Scripts and CVS Caremark, governing their insulin market operations. The full scale of financial adjustments resulting from these new requirements for formularies and payments is not yet quantified.
The players
Federal Trade Commission
The U.S. government agency tasked with enforcing antitrust laws and consumer protection policies regarding business competition.
Express Scripts
A major pharmacy benefit manager that operates as an intermediary between health insurance plans and pharmaceutical manufacturers.
CVS Caremark
A large pharmacy benefit manager that manages prescription drug benefits for health plans and employers.
The details
The settlements dictate how these intermediaries manage drug formularies and organize pharmacy payments, specifically targeting the rebates and incentives used in the insulin sector. By changing the mechanics of these transactions, the FTC aims to alter how savings are passed along to patients. However, experts suggest employers may move to bypass these structures by adopting alternative offerings from PBMs that fall outside these specific new requirements.
Timeline
September 22, 2026
Market Landscape
This action extends the Federal Trade Commission's ongoing antitrust enforcement authority regarding the role of intermediaries in the healthcare supply chain. The move signals a broader regulatory effort to increase transparency in how pharmacy benefit managers interact with pharmaceutical manufacturers.
Employers should review their current PBM contracts to determine if existing incentive structures align with these new federal requirements. Firms may also consider evaluating alternative, transparent pharmacy benefit models to mitigate the risk of rising drug costs.
The takeaway
These settlements force a shift in how insulin rebates are processed, but their ability to lower total drug costs for businesses remains unproven. Operators should track whether these new requirements force a market shift toward alternative, low-rebate PBM offerings.
Further reading
For broader trends in industry regulation, see Healthcare.
Source note: This article includes information reported by News-Medical.
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