March 19, 2026

Oklahoma House of Representatives
2300 North Lincoln Boulevard
Oklahoma City, Oklahoma 73105

Dear Representative,

The House of Representatives may soon consider HB 3538.  On behalf of the 5,608 members and supporters of the Council for Citizens Against Government Waste (CCAGW) in Oklahoma, I urge you to oppose HB 3538, which would ban any pharmacy that has an affiliation with a pharmacy benefit manager (PBM) from doing business in the state.

PBMs save money for patients by negotiating lower prices on behalf of large groups.  Today, PBMs administer plans for more than 289 million Americans nationwide.  PBMs save payers and patients an average of $1,154 per person per year.  PBMs use various tools like rebates, pharmacy networks, drug utilization review, formularies, specialty pharmacies, mail-order, and audits to drive down drug costs, improve quality, increase patient medication adherence, and prevent fraud.  PBMs require pharmacies to compete on price, thus lowering costs for patients and for the various sponsors they serve including businesses, unions, state and local government, associations, and other organizations that provide health insurance to their employees or members.

HB 3538 would close more than 190 brick and mortar retail pharmacies across the state, eliminating cost-saving mail order and specialty pharmacy options for employers.  Because many independent pharmacies lack the logistical ability or expertise to handle the storage and transport requirements that some specialty medications require, this will put patients who rely on specialty pharmacies for the treatment of complex and serious conditions at severe risk of not being able to access their medications.  These government-mandated pharmacy closures would also put pharmacists and thousands of other people out of work, push providers out of the state, and put Oklahoma business owners at a competitive disadvantage by restricting the benefits they would be able to offer their employees.

For the above reasons, I urge you to oppose HB 3538 and protect Oklahomans from its destructive impact on pharmacy access and prescription drug costs throughout the Sooner State.

Sincerely,
Tom Schatz
President, CCAGW