The Federal Trade Commission has reached a proposed settlement with CVS Caremark, one of the nation’s largest pharmacy benefit managers (PBMs), over allegations that the company inflated the price of insulin and created barriers to access for people with diabetes. The agreement, filed on March 23, 2026, follows a similar settlement last month with Cigna’s Express Scripts and stems from a 2024 complaint against CVS Caremark, Express Scripts, and UnitedHealth’s OptumRx.
While the specific terms of the settlement are still pending review and approval by the FTC chair, a CVS spokesperson confirmed the company expects the process to conclude in the coming weeks. The spokesperson stated, “The proposed agreement is subject to review and approval by the FTC chair. Final terms are still pending and will be confirmed once the settlement is officially finalized. We will be able to provide additional details following this review.”
The FTC’s case centered on claims that PBMs, acting as intermediaries between drug manufacturers, insurance plans, and pharmacies, were not passing on the full extent of rebates and discounts they negotiated with insulin manufacturers to patients. This practice, the FTC alleged, artificially raised out-of-pocket costs for individuals relying on this life-sustaining medication. Insulin is critical for managing diabetes, a chronic condition affecting millions of Americans, and affordability has been a growing concern for patients and policymakers alike.
The Broader Crackdown on PBM Practices
The settlements with CVS Caremark and Express Scripts represent a significant escalation in federal scrutiny of PBMs, which have historically operated with limited oversight. The FTC’s investigation, launched in September 2024, aimed to uncover how PBMs’ complex business models impact drug pricing and patient access. The agency argued that the rebate system, while intended to lower overall healthcare costs, often incentivized PBMs to favor higher-priced drugs that generate larger rebates, rather than the most affordable options for patients.
The case against these PBMs highlighted the lack of transparency in the pharmaceutical supply chain. Patients often don’t know the true cost of their medications or how much their insurance plan is paying. This lack of information makes it tough for individuals to shop around for the best prices or advocate for more affordable options. The FTC’s action signals a commitment to increasing transparency and accountability within the PBM industry.
How PBMs Influence Insulin Costs
Pharmacy benefit managers play a powerful role in determining which drugs are covered by insurance plans and at what cost. They negotiate rebates with drug manufacturers, essentially offering preferential placement on formularies (lists of covered drugs) in exchange for discounts. However, critics argue that these rebates are often kept secret, and the benefits are not always passed on to patients at the pharmacy counter.
In the case of insulin, the FTC alleged that PBMs were incentivized to include higher-priced insulin products on formularies because they generated larger rebates, even if lower-cost alternatives were available. This practice effectively forced patients to pay more for their medication, even if they had insurance coverage. The agency’s complaint detailed how these practices impacted individuals with both Type 1 and Type 2 diabetes, potentially leading to serious health consequences for those unable to afford their insulin.
Impact on Patients and Future Implications
The proposed settlement with CVS Caremark, and the finalized agreement with Express Scripts, could lead to changes in how PBMs negotiate drug prices and manage formularies. While the specific details of the settlements remain confidential pending final approval, experts anticipate they will include provisions aimed at increasing transparency and ensuring that patients benefit from negotiated rebates and discounts.
“This is a step in the right direction, but it’s not a complete solution,” said Dr. Robert Gabbay, chief science and medical officer at the American Diabetes Association, in a statement following the Express Scripts settlement. “We need comprehensive reforms to address the root causes of high insulin prices and ensure that everyone with diabetes has access to affordable medication.”
The FTC’s ongoing investigation into UnitedHealth’s OptumRx remains active. The agency is continuing to gather evidence and assess whether OptumRx engaged in similar practices. The outcome of this investigation could further reshape the PBM landscape and lead to additional regulatory changes.
For patients struggling to afford insulin, several resources are available. The American Diabetes Association offers information on financial assistance programs and affordable insulin options: https://www.diabetes.org/diabetes-care/cost-care. Many insulin manufacturers offer patient assistance programs that can help reduce out-of-pocket costs.
The FTC is expected to release the final terms of the CVS Caremark settlement in the coming weeks. The agency will then begin the process of implementing the agreement and monitoring its impact on insulin prices and patient access. This case underscores the growing pressure on PBMs to address concerns about drug pricing and transparency, and it signals a potential shift towards greater regulation of this powerful industry.
The next step in this ongoing effort will be the FTC’s review of the proposed settlement with CVS Caremark, followed by the conclusion of the investigation into OptumRx. These actions will likely shape the future of insulin pricing and access for millions of Americans living with diabetes.
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