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.
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?
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.
- 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
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.
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.
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.