2026-15913NoticeWallet

FTC Okays Caremark-Zinc Deal with Consent Order Strings

Published Date: 8/5/2026

Notice

Summary

The consent agreement in this matter settles alleged violations of Federal law prohibiting unfair methods of competition. The attached Analysis of Proposed Agreement Containing Consent Orders to Aid Public Comment describes both the allegations in the complaint and the terms of the consent order--embodied in the consent agreement-- that would settle these allegations.

Analyzed Economic Effects

8 provisions identified: 7 benefits, 0 costs, 1 mixed.

Insulin Copay Caps and Guaranteed Access

If your plan sponsor adopts a formulary that includes an insulin product covered by Caremark's Copay Certainty Program, Caremark must provide full access to that program to all members unless the plan sponsor opts out in writing. The program caps out-of-pocket costs at $25 for a 0–34 day supply, $50 for a 35–68 day supply, and $75 for a 69+ day supply.

Retail Community Pharmacy Payment Rules

Caremark must offer retail community pharmacies (defined as businesses with three or fewer store locations) a standard offering that reimburses them based on the actual cost of acquiring drugs plus a dispensing fee, pays for non-dispensing services, and will not exclude any retail community pharmacy willing to agree to the standard terms.

Rebates Passed Through At Point of Sale

Caremark must offer a standard option to plan sponsors that lets members receive the benefit of any rebate or discount at the point of sale, without charging fees except actual pre-funding costs. The standard offering also forbids spread pricing and bars Caremark from providing plan sponsors rebate guarantees or other pre-determined compensation guarantees.

Stop Tying Out-of-Pocket To List Price

Caremark's standard offering must ensure member out-of-pocket costs are not tied to a drug's list price or any benchmark higher than the plan sponsor's contracted rate minus rebates; member costs must be no higher than the plan sponsor's contracted rate minus any rebates. Additionally, Caremark must provide full access to its programs that reduce out-of-pocket costs for members.

Place Low-WAC Versions On Formularies

Caremark must place low-WAC (lower list-price) versions of high-WAC drugs on its four standard commercial formularies at no disadvantage to the high-WAC version, unless the low-WAC version has a higher net cost or the drug was listed as 'Currently in Shortage' in the FDA Drug Shortage Database at the time the formulary takes effect or within the 18 months prior.

Delink Manufacturer Pay From List Price

For its standard offering, Caremark must not base compensation received from drug manufacturers, directly or indirectly, on a drug's list price (WAC). This provision aims to remove incentives tied to higher list prices.

Pharmacies May Work With Hub Service Providers

Caremark is prohibited from imposing or enforcing rules that prevent or restrict a pharmacy's engagement with third-party digital pharmacy hub service providers, so long as the pharmacy complies with law, regulation, and certain transparency rules. Caremark also may not interfere with a pharmacy's ability to engage with a hub, subject to limited exceptions (e.g., regulatory exclusion lists, suspected fraud).

Plan Sponsors Can Request Different Terms

Caremark's Proposed Order lets plan sponsors request customized terms that differ from the standard offering; in that case Caremark must provide the standard offering and obtain a written signed acknowledgment that the plan sponsor received and understood the standard offering before agreeing to different terms. Aetna's fully-insured health plans must adopt the patient protections and are excluded from this 'meeting competition' exception.

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Key Dates

Published Date
Comments Due
Effective Date
8/5/2026
9/4/2026
1/1/2027

Department and Agencies

Department
Independent Agency
Agency
Federal Trade Commission
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