The Government Accountability Office released a report on October 5, 2026, analyzing payments and contracts in vertically integrated Medicare Part D plans. The agency examined how insurance plan sponsors that provide Medicare Part D drug coverage have increasingly become vertically integrated with pharmacy benefit managers and pharmacies.
Payments to pharmacies included both reimbursement from plan sponsors and cost sharing paid by or on behalf of beneficiaries. Payments and cost sharing for at least 94 percent of the 100 most commonly used prescription drugs were lower at owned pharmacies than at non-owned pharmacies for a 30-day supply. The 100 drugs with the highest total utilization in 2023 were primarily generic drugs.
Average payments to owned and non-owned pharmacies for a 30-day supply of most of the 100 most commonly used prescription drugs were $10 or less. Cost sharing was up to about $340 higher at owned pharmacies for about half of the 20 drugs with the highest payments per 30-day supply. Medicare Part D spent $150 billion on prescription drug coverage for 54 million beneficiaries in 2025.
Timeline
For four large Medicare Part D plan sponsors, owned pharmacies received about 28 percent of total pharmacy payments in 2023. The four selected vertically integrated plan sponsors accounted for over 40 percent of total Part D enrollment in 2023.
What's New
The Office of Inspector General (OIG) found that 79% of Medicare Part D enrollees were in plans offered by vertically integrated sponsors in 2023, with three major organizations—UnitedHealth, CVS Health, and Humana—covering 57% of all enrollees. Vertically integrated Medicare Part D sponsors accounted for 82% of total Part D spending in 2023, with six organizations (UnitedHealth, CVS Health, Humana, Centene, Cigna, and Elevance Health) collectively responsible for $225.9 billion in gross spending. The Office of Inspector General (OIG) noted that vertically integrated sponsors recouped 34% of gross spending on Part D drugs through direct and indirect remuneration (DIR), compared to 29% for non-vertically integrated sponsors. Primary sources: oig.hhs.gov, oig.hhs.gov (2)
In 2023, 11 vertically integrated organizations accounted for 82% of $275.9 billion in Part D spending, according to a separate report by the Office of Inspector General (OIG) within the U.S. Department of Health and Human Services. A 2023 Medicare Payment Advisory Commission (MedPAC) report noted that vertically integrated pharmacies may not necessarily reduce costs. Primary source: oig.hhs.gov
Why It Matters
The scale of vertical integration in the Medicare Part D market is substantial, with 11 vertically integrated organizations managing prescription drug benefits for 79% of enrollees in 2023. These entities accounted for 82% of total Part D spending. UnitedHealth alone covered 24% of enrollees, and 33% of all pharmacies in the Part D market were owned by vertically integrated organizations. The Government Accountability Office has previously examined how vertical integration may affect competition in the Medicare Part D market, with concerns raised about potential anticompetitive behavior that could negatively impact independent pharmacies. Primary source: oig.hhs.gov
The financial mechanisms within these integrated systems involve complex payment structures. Vertically integrated sponsors recouped 34% of gross Part D drug spending through direct and indirect remuneration, compared to 29% for non-integrated sponsors. In 2023, vertically integrated sponsors paid their own pharmacies 4% less at the point of sale than unaffiliated pharmacies, but this did not account for later payment adjustments that typically reduced what pharmacies ultimately received. The Medicare Payment Advisory Commission noted that vertically integrated pharmacies may not necessarily reduce costs for beneficiaries. Primary source: oig.hhs.gov
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