Pharmacy Benefit Manager symbol intertwined with a supply chain link, against a backdrop of worried patients.

Drug Shortages: Are Pharmacy Benefit Managers Part of the Solution?

"Exploring the obligations and potential roles of Pharmacy Benefit Managers (PBMs) in mitigating serious prescription drug shortages for the benefit of clients and society."


Pharmacy Benefit Managers (PBMs) are essential to the American healthcare system, connecting approximately 215 million Americans with their prescribing physicians and retail pharmacies. Many PBMs operate large, sophisticated dispensing operations. These capabilities could be invaluable in managing and mitigating the impact of drug shortages, which have become an increasing concern in the United States.

Drug shortages can disrupt patient care, leading to the use of less effective treatments, treatment delays, and compromised supply chains. In severe cases, patients may be left without access to necessary medications. The current mechanisms for addressing these shortages are inadequate, demanding more proactive and effective strategies.

PBMs have the potential to play a significant role in these responses. By leveraging their extensive networks and dispensing capabilities, PBMs can help ensure that patients receive the medications they need, even when supplies are limited. While their primary obligation is to their clients, their unique position confers a broader responsibility to contribute to the public health.

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The Scale of Drug Shortages

ASHP reports 227 active drug shortages as of June 2026, marking a second consecutive quarterly increase, although the figure remains below the all-time high of 323 recorded in the first quarter of 2024. Chemotherapy shortages remain problematic, with ifosfamide identified as a particularly severe new shortage. ASHP also cautions that fewer shortages do not necessarily mean fewer patients are affected, because one shortage can affect large numbers of patients. USP identifies low prices, manufacturing complexity, geographic concentration, and quality concerns as interconnected drivers that increase supply-chain vulnerability.

Fragmented Shortage Management

Drug shortages create financial, logistical, and ethical challenges for healthcare institutions, but research has found limited data describing current shortage-management practices. Hospitals in the same state or region may use different approaches to managing shortages. PBMs are contracted by insurers to manage the pharmacy-benefit portion of healthcare benefits, partly because prescription-drug benefit management has become more complex. NAIC materials also identify gag clauses as contract provisions that can prevent pharmacists from informing consumers about alternative purchasing options.

PBMs: Public Health Problem Solvers?

Pharmacy Benefit Manager symbol intertwined with a supply chain link, against a backdrop of worried patients.

While commercial PBMs can significantly impact public health, they are not public institutions and do not have explicit societal obligations beyond their ordinary business activities, licensing requirements, and professional practice standards. Their primary obligations are to serve their clients’ objectives and their investors’ interests. However, there are circumstances where PBMs can incur implicit obligations to contribute to solutions for serious public health issues.

One such circumstance arises when these organizations reach a certain size and possess capabilities applicable to a particular public health problem, such as serious drug shortages. Some PBMs might address these issues based on their organizational ethos, while others may need to justify their involvement to their clients and investors on more concrete grounds.

Here are the Actions PBMs can take to prevent and ameliorate serious drug shortages:
  • Require manufacturers or drug distribution companies to provide alerts about potential shortages as part of contractual arrangements
  • Adopt predictive analytical methods to detect potential drug shortages and to identify the patients most likely to be adversely affected by them
  • Arrange for alternative manufacturers for critical drugs when more than one manufacturer exists
  • Alert FDA and established reporting systems of shortages detected or predicted through inventory management processes and predictive analytics
  • Alert manufacturers of predicted or observed increases in demand for critical drugs
  • Follow and react to shortage notices issued by manufacturers, FDA, and professional organizations
  • Alert pharmacists at time of dispensing and physicians at time of prescribing about drug shortage
  • Notify patients of drugs in short supply and advise them to contact their physicians
  • Provide a list to physicians of their patients on drugs in short supply with available alternatives
  • Provide lists to pharmacies of patients who have been receiving drugs from them that are in short supply
  • Notify payers about particular drug supply problems that will affect their plan members and the procedures put in place
  • Work with public health officials to establish and activate protocols that prioritize patients for distribution within and outside client network
  • Activate alternative supply procedures
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PBMs as Distribution Coordinators

Research on outpatient medication unavailability identifies PBMs as participants in drug-shortage management. Their mail-order and specialty-dispensing operations can distribute medications across all 50 states and may help manage remaining inventory during life-threatening shortages. Other literature identifies the PBM as an integrated provider structure within pharmaceutical leadership strategies. A review of the drug-shortage crisis also describes additional prior-authorization requirements as one possible action to ensure that patients meet predefined criteria for using a drug in short supply.

Obligations and Blind Spots

One analysis argues that PBMs' capabilities create obligations to address serious prescription-drug shortages not only for their clients but also for society more broadly. At the same time, the drug-shortage literature notes that the FDA does not investigate shortages expected to be temporary and self-limiting or those limited to a particular strength or package size. The cited rationale is limited agency resources and the transient nature of these shortages. Even such shortages can create significant problems for healthcare providers and facilities.

PBMs as Intermediaries

The available source describes PBMs as intermediaries between pharmacies, insurance companies or employers, and drug manufacturers. This position places PBMs within the operational chain connecting coverage, dispensing, and manufacturers. The source characterizes PBMs as playing a significant role in the delivery of pharmacy services. These materials do not, however, establish a comparative outcome showing that PBM involvement produces better shortage results than another prescription-management model.

One justification for PBM involvement stems from the requirement that PBMs hold a variety of licenses based on the services they provide and where they provide them. Most, for example, have licenses as third-party administrators, pharmacy benefit managers, and dispensing pharmacies. These licenses give them certain advantages via the higher barrier they create for potential competitors. In return, licensing agencies and the people they protect can expect PBMs to serve their interests.

Moving Forward: Collaboration and Clear Criteria

Life-threatening drug shortages are a public health problem that sometimes calls for health-care organizations and related industries to see themselves as public health agents and extend their capabilities beyond those that serve their ordinary constituencies. By establishing clear criteria and fostering collaboration, PBMs can play a crucial role in ensuring that patients receive the medications they need during times of shortage.

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A Changing Benefits Landscape

NFP's 2026 pharmacy-benefits outlook points to regulatory actions and market innovations as forces shaping the year ahead. A market-trends report says pharmacy benefit management has evolved from a back-end function focused on negotiating prices and processing claims into a broader part of healthcare cost management. Another forecast identifies increasing preference for generic and biosimilar drugs as a significant trend and reports that these products account for more than 85% of total prescription volumes. These sources describe market and regulatory direction but do not establish that any particular innovation will resolve drug shortages.

Access, Cost, and Coordination

Drug shortages are described as a growing challenge for health systems worldwide, with impacts on patient access and medication use. For PBMs and health plans, shortages can extend beyond supply-chain logistics by compromising patient care, increasing operational burdens, and driving unexpected cost increases. The cited response calls for coordination, transparency, and proactive strategy. Pharmacy Times likewise says that reforms should emphasize transparency, accountability, and patient-centered outcomes as specialty medications become more prevalent across therapeutic areas.

Supply-chain reports and shortage counts

  • 309; 320 active shortagesAt the end of the second quarter of 2023, 309 active shortages were reported, close to the then all-time high of 320.[1]

What PBM shortage proposals can-and cannot-show

The source presents PBMs as potential coordinators of access during shortages, but the cited proposals describe possible mechanisms rather than measured evidence that those mechanisms improve patient outcomes.[2]

Later accounts place PBMs within broader pharmaceutical leadership structures and discuss cautious responses to disruptions, including checking demand rather than allowing hoarding. This frames their role as operational, not as proof of comparative effectiveness.[3]

A conceptual analysis of PBMs and serious shortages

PopulationPharmacy benefit managers[4]
SettingUnited States[4]
Times cited5[4]

Later work extends the PBM discussion

A 2017 review describes possible collaboration between PBMs and larger health-care organizations, including integrated systems, insurers, pharmacy chains, wholesalers, and care networks, to extend access to potentially lifesaving therapies.[2]

That review also outlines mechanisms such as advance notice to suppliers about product preferences and access to alternatives at the usual copayment rate; it discusses prior authorization as one way to prioritize access.[2]

A separate leadership paper characterizes the PBM as an integrated provider structure, while recommending restrained responses to supply disruptions, such as validating patient demand through pre-authorization.[3]

About this Article -

Written with AI assistance from published research, and reviewed by the Mystum team. See our About page for more information.

This article is based on research published under:

DOI-LINK: 10.1038/clpt.2012.224, Alternate LINK

Title: Pharmacy Benefit Managers And Their Obligations During Serious Prescription Drug Shortages

Subject: Pharmacology (medical)

Journal: Clinical Pharmacology & Therapeutics

Publisher: Springer Science and Business Media LLC

Authors: J R Teagarden, R S Epstein

Published: 2013-02-01

Everything You Need To Know

1

What exactly are Pharmacy Benefit Managers (PBMs) and what do they do?

Pharmacy Benefit Managers, or PBMs, are organizations that manage prescription drug benefits on behalf of health insurers, employers, and other payers. They act as intermediaries between drug manufacturers, pharmacies, and patients, negotiating drug prices, creating formularies, and processing prescription claims. PBMs play a significant role in determining which drugs are covered by insurance plans and how much patients pay for their medications. Given their position they are able to impact the availability of drugs, in the context of drug shortages.

2

Why are drug shortages a problem?

Drug shortages are a significant concern because they can disrupt patient care, potentially leading to the use of less effective treatments, delays in necessary treatments, and compromises in the supply chain. In severe cases, patients might not have access to the medications they urgently need. The lack of adequate mechanisms to address these shortages necessitates more proactive and effective strategies to ensure a consistent and reliable drug supply for patients.

3

How can Pharmacy Benefit Managers (PBMs) help with drug shortages?

PBMs can leverage their extensive networks and dispensing capabilities to ensure patients receive necessary medications even when supplies are limited. Actions include requiring manufacturers to provide shortage alerts, using predictive analytics to detect potential shortages, arranging for alternative manufacturers, and alerting relevant parties like the FDA, pharmacists, physicians, and patients. Their involvement is critical due to their ability to influence the supply chain and ensure patient access to medications.

4

Do Pharmacy Benefit Managers (PBMs) have a responsibility to help solve public health problems like drug shortages?

While commercial PBMs primarily serve their clients' and investors' interests, they can also incur implicit obligations to address serious public health issues like drug shortages. This obligation arises when PBMs have the capabilities and reach to significantly impact such problems. Addressing these issues can be justified because PBMs hold licenses that create higher barriers for competitors, implying a responsibility to serve the broader interests of those protected by these licenses.

5

What specific steps can Pharmacy Benefit Managers (PBMs) take to prevent or reduce the impact of drug shortages?

PBMs can take several actions to prevent and alleviate serious drug shortages, including requiring manufacturers to provide shortage alerts, using predictive analytics to detect potential shortages, arranging for alternative manufacturers, and alerting relevant parties. They can also work with public health officials to prioritize patients for distribution and activate alternative supply procedures. These measures help ensure that patients receive the medications they need during times of shortage.

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