PBM PROMOTIONS ARE RESPONSIBILITY OF MANUFACTURER-OWNER, FDA DRAFT GUIDANCE SAYS; SPONSORS ALSO ACCOUNTABLE FOR INDEPENDENT PBM CAMPAIGNS THEY "INFLUENCE"
Executive Summary
Manufacturers may be held responsible for violative promotional activities undertaken by an unaffiliated healthcare organization or PBM when "a contract between the sponsor and the healthcare organization/PBM to promote the sponsor's product(s) exists," FDA says in a draft guidance on promotions by pharmacy benefit management companies.