Every factual claim we published has a card here: what we said, where it comes from, what year it measures, and what it does not establish. Panels 1, 2 and 8 are the project's editorial position, not findings.
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Panel 3
More than $7.3 billion in dispensing revenue above estimated acquisition cost
Pharmacies affiliated with the three largest pharmacy benefit managers generated over $7.3 billion in dispensing revenue above their estimated acquisition cost for the specialty generic drugs studied. The analysis covered 51 drugs and 882 National Drug Codes, measured against the National Average Drug Acquisition Cost. The top ten drugs account for $6.2 billion of the total.
Measures 2017–2022. Federal Trade Commission, Second Interim Staff Report on Prescription Drug Middlemen, January 14, 2025.
What this does not establish. Revenue above estimated acquisition cost is not profit. It does not subtract the cost of dispensing. It is a multiyear subset covering specific drugs, not an annual figure and not a share of any federal spending total.
Read the FTC report announcement
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Panel 4
For 79 of the 100 most-rebated Part D drugs, patients collectively paid more than plan sponsors
Plan sponsors received $48.6 billion in rebates from drug manufacturers in 2021. Across the 100 Medicare Part D drugs receiving the most rebates, payments by beneficiaries were more than plan sponsor payments, after accounting for rebates, for 79 of them. Rebates may lower what a plan pays, but beneficiary payments are based on a drug’s gross cost before rebates.
Measures 2021. GAO-23-105270, published September 5, 2023.
What this does not establish. The comparison is aggregate, across those drugs. It is not a statement about any individual person's bill, it is not 79 percent of all medicines, and it does not describe employer plans or 2025 cost-sharing after the Part D benefit redesign.
Read the GAO report
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Panel 5
Closed to HHS, still open at GAO
GAO recommended that CMS monitor the effect of rebates on plan formulary design and on Medicare and beneficiary spending, to assess whether rebate practices are likely to substantially discourage enrollment by certain beneficiaries.
The Department of Health and Human Services did not concur. It stated in November 2025 that it considers the recommendation closed, on the grounds that the statutory non-interference clause bars it from interfering in negotiations between manufacturers, pharmacies and Part D sponsors, or from requiring a particular formulary or price structure. CMS also said its annual clinical formulary review makes a separate evaluation of rebate information unnecessary.
GAO continues to list the recommendation as Open. Its position is that CMS could monitor aggregated rebate and expenditure data from prior years without interfering in any negotiation or requiring any formulary.
GAO-23-105270, Recommendations for Executive Action. Recommendation status checked October 31, 2026.
What this does not establish. The disagreement concerns the recommendation, not the 79-of-100 finding. Nobody disputed the measurement. HHS’s objection rests on a statutory limit on its authority, which is a substantive legal position and not a refusal to look.
Check the recommendation status
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Panel 6
Gaps in knowing how Medicare Advantage supplemental-benefit dollars are spent
MedPAC estimated $86 billion of 2025 rebates financing extra benefits, with intended allocations of roughly $39 billion to non-Medicare services, $27 billion to reduced Medicare cost-sharing, $15 billion to Part D benefits and premiums, and $5 billion to Part B premiums. These are bid-based estimates. Actual use and spending on many supplemental benefits are poorly established, and encounter data are incomplete.
MedPAC June 2025 Report to Congress, chapter 2.
What this does not establish. A reporting gap is not proof the benefits were never delivered, and it is not a finding that the $86 billion was profit. Unused benefits are not automatically inappropriate: insurance also buys financial protection.
Read the MedPAC chapter
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Panel 7
The Labor Department's pharmacy benefit manager disclosure rule
On October 29, 2026 the Department of Labor finalized a rule requiring covered service providers to disclose their compensation to large self-insured group health plans, generally those with 100 or more participants, or offered by employers with 100 or more employees. Disclosure is required reasonably ahead of entering into, extending or renewing a contract, with 90 days deemed reasonable for renewals; then within 30 days of the end of each semiannual period, or quarterly if the plan requests it. A plan may audit the provider at least once a year.
Takes effect 60 days after publication in the Federal Register. Requirements apply to plan years beginning on or after July 1, 2027. Department of Labor, Employee Benefits Security Administration.
What this does not establish. The rule has not applied to anyone yet, so it has produced no measurable result. The disclosures go to the plan's fiduciaries, not automatically to the public. Smaller and fully insured plans are outside the detailed requirements but remain subject to the statutory obligation in ERISA section 408(b)(2)(B), so it is wrong to say nothing is disclosed before July 2027. We publish no savings estimate for this rule and make no claim that non-compliant contracts are automatically invalidated.
Read the DOL fact sheet · Read the announcement
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Panel 8 · the correction we carry
Payment timing explains much of Medicare's apparent spending acceleration
Medicare growth was recorded at 3.1 percent in fiscal 2024 against 9.4 percent once adjusted for payment timing, and at 14.1 percent in fiscal 2025 against 8.5 percent adjusted. The timing-adjusted dollar increases were roughly $78 billion and $77 billion. October capitation payments shift into September when October 1 falls on a weekend.
Congressional Budget Office, fiscal 2024 review and November 2025 monthly budget review.
What this does not establish. These are Medicare figures. They are not a fully reconciled timing adjustment of every federal health account, and they should not be scaled to produce one.
CBO fiscal 2024 review · CBO November 2025 review