PBM Complaints FAQ

1. Why should pharmacists, consumers and prescribers file PBM complaints? 

The Iowa Insurance Division (IID) has jurisdiction to enforce violations of Iowa Code regulating PBMs and to enforce discipline. It is important for IID to receive complaints to understand the full extent of PBM practices that negatively impact Iowans.

2. Everyone is so busy...Will filing a complaint actually make a difference, or is it a waste of my time?

In addition to IID hiring additional staff to investigate PBM complaints and enforce PBM regulations, IPA received pushback from policy makers that there was a lack of data to justify PBM reform. It’s important that IID has compiled a record of PBM complaints to justify further action by the Legislature.

3. What if I have more information than the complaint form can accept? 

Opening a complaint will trigger an IID investigation and IID staff will reach out for additional information. Supporting documents such as PBM appeals, spreadsheets, claim reports, etc. can be submitted to IID. IPA is working with IID to adjust the complaint form for ease of submission.

4. What kinds of violations can I report? 

Pharmacies should report violations of Iowa Code Chapter 510B and IID Administrative Code Chapter 59. Pharmacies should also report other practices of concern. Legislators are monitoring PBM complaints, and formal complaints will provide additional justification for future legislative action.

5. What are examples of violations of Iowa’s PBM regulations? 

Examples of violations include the charging of fees to pharmacies, clawbacks and retroactive adjustments, failure to follow MAC transparency requirements described in the code, and requiring record keeping that is more stringent than state or federal law.