The short version: a pharmacy built on dispensing volume is easy to exploit and hard to defend, and enforcement actions and CMS quality measures already reward outcomes over counts. The pharmacy of the future will be paid for moving patients successfully through therapy, through benefits navigation, adherence support, care coordination and real-world evidence. Dispensing alone will price like a commodity.
Pharmacies have been measured by prescriptions filled, and that measure is now working against them. It is easy to exploit, hard to defend, and it describes none of the work that actually keeps a patient on therapy. Reimbursement is already moving toward the work that does.
A Volume Model Is Easy to Exploit
Start with the uncomfortable part. When the unit of value is the prescription rather than the patient, the system becomes straightforward to game, and a small number of actors do exactly that. In June 2026, the Justice Department announced its largest coordinated health care fraud action by participation in the department's history. Four hundred fifty-five defendants were charged across 56 federal districts and 45 states and territories, involving more than $6.5 billion in alleged false claims, with 50 state Medicaid Fraud Control Units taking part. Ninety of the defendants were licensed medical professionals, pharmacists among them. The prior year's takedown had alleged $14.6 billion in intended loss. The pharmacy-specific allegations are worth reading closely, because every one of them describes a dispensing transaction detached from a patient outcome.Alleged in the 2026 takedown
In New Jersey, a pharmacy owner allegedly paid providers to write prescriptions for high-reimbursement medications the pharmacy itself selected, causing roughly $20.7 million in losses to Medicare and Medicaid.
In New York, pharmacies allegedly received more than $12 million for prescriptions that were never dispensed, or were filled using product obtained from unlicensed black-market suppliers.
In Hawaii, a pharmacy allegedly billed Medicare for drugs it did not dispense and could not support with inventory.
Extraction Is Not Always Criminal
The larger issue is not fraud. It is that value can be extracted from a dispensing-based system entirely lawfully. The FTC's second interim staff report on pharmacy benefit managers examined 51 specialty generic drugs dispensed between 2017 and 2022. It found that the three largest PBMs marked up numerous drugs at their affiliated pharmacies by hundreds and in some cases thousands of percent above estimated acquisition cost. One pulmonary hypertension generic was marked up more than 7,700 percent for commercial payers in 2022. Across the set, affiliated pharmacies generated over $7.3 billion in dispensing revenue above acquisition cost, growing at a 42 percent annual rate, with an additional $1.4 billion attributed to spread pricing. The share of specialty generic dispensing revenue going to affiliated pharmacies rose from 54 percent in 2016 to 68 percent in 2023. CVS has disputed the analysis, calling it a selective reading of outliers and noting that specialty generics were under 1.5 percent of its clients' total drug spend across the period. Take the dispute at face value and the underlying point survives. When margin depends on which pharmacy fills the script and at what markup, the economics reward capturing the transaction. Nothing in that structure rewards whether the patient started therapy, stayed on it, or got better.Dispensing Alone Is No Longer a Differentiator
If the pharmacy of the future does not create measurable value for patients, providers, manufacturers, and payers, we will continue to see the market evolve toward alternative models. Direct-to-patient distribution. Manufacturer-supported fulfillment. Cash-pay channels, wherever they offer a better experience. Dispensing medication alone is becoming less of a differentiator. Creating a better patient journey is.What the Pharmacies That Thrive Will Actually Do
The pharmacies that thrive will be those that become active partners in healthcare, by helping to:Navigate benefits verification and prior authorization
Improve affordability
Increase adherence and persistence
Generate meaningful real-world evidence
Identify patients at risk of discontinuing therapy
Coordinate care across the healthcare ecosystem
That is where I believe the opportunity lies.They will not simply move products. They will move patients successfully through therapy.
This Is Not a Prediction. It Has Already Started.
Here is the part I think gets underweighted in this conversation. Value-based payment tied to pharmacy performance is not something the industry is waiting on. It is already the single largest lever in Medicare Advantage plan economics. CMS Star Ratings include three Part D medication adherence measures, covering diabetes medications, blood pressure medications, and statins. Each has historically been triple-weighted, carrying three times the influence of an ordinary measure. Together they have accounted for roughly a third of a plan's Part D summary rating. Plans reaching four stars overall become eligible for a five percent quality bonus payment. Read that again in commercial terms. A plan's bonus payment turns substantially on whether patients have their medication on hand at least 80 percent of the days they should. That is not a dispensing metric. It is a patient journey metric. And the pharmacy is the entity closest to it.Worth tracking: for measure year 2026 CMS temporarily reduced the three adherence measures to single weight while it phases in sociodemographic risk adjustment, with a return to triple weighting expected for the 2027 Star Ratings. CMS also stopped excluding inpatient and skilled nursing days from the adherence calculation. The weighting moved. The direction did not.
The Debate Is Not Independent Versus Integrated
As someone who has spent nearly two decades working across commercialization, patient access, and healthcare finance, I do not think the future debate is about independent pharmacy versus integrated pharmacy. It is about which pharmacy models create the greatest value.The shift
Reimbursement will increasingly follow value.
Value will not be measured by how many prescriptions leave the shelf.
It will be measured by how many patients achieve better outcomes.
That is the future I believe our industry should be designing. And the infrastructure to pay for it already exists.
Sources and Notes
2026 enforcement action: U.S. Department of Justice, "National Health Care Fraud Takedown Results in 455 Defendants Charged in Connection with Over $6.5 Billion in Alleged Fraud," announced June 24, 2026. Cases in 56 federal districts and 45 U.S. states and territories, with 50 state Medicaid Fraud Control Units participating, the most in department history. Ninety of those charged were licensed medical professionals. More than $182 million in assets was seized.
Pharmacy-specific allegations: DOJ case summaries as reported in Buchanan Ingersoll & Rooney, "DOJ's 2026 Health Care Fraud Takedown: Why Pharmacies Should Act Before an Audit Becomes an Investigation," June 2026. All matters described are allegations. Defendants are presumed innocent unless and until proven guilty.
2025 comparison figure: DOJ, 2025 National Health Care Fraud Takedown, June 30, 2025. Charges against 324 defendants involving over $14.6 billion in intended loss, the largest such action in DOJ history at the time. CMS separately reported preventing over $4 billion in payments on false or fraudulent claims and suspending or revoking billing privileges for 205 providers.
PBM markups and affiliated pharmacy steering: Federal Trade Commission, "Specialty Generic Drugs: A Growing Profit Center for Vertically Integrated Pharmacy Benefit Managers," second interim staff report, January 14, 2025. Analysis covered 51 specialty generic drugs and 882 National Drug Codes dispensed 2017 to 2022 under commercial and Medicare Part D plans managed by Caremark, Express Scripts, and OptumRx. Findings include over $7.3 billion in dispensing revenue above National Average Drug Acquisition Cost, a 42 percent compound annual growth rate, roughly $1.4 billion attributed to spread pricing, and a rise in affiliated-pharmacy share of specialty generic dispensing revenue from 54 percent in 2016 to 68 percent in 2023.
Industry response: CVS Health has publicly disputed the FTC analysis, characterizing it as drawing broad conclusions from selected outliers and noting that specialty generics represented under 1.5 percent of Caremark clients' total drug spend over the study period. The FTC reports are staff reports and remain contested. Readers should weigh both.
Star Ratings and adherence: CMS Medicare Part D Star Ratings include three medication adherence measures for diabetes medications, RAS antagonists, and statins, scored on Proportion of Days Covered with an 80 percent adherence threshold. These measures have historically been triple-weighted and have contributed approximately 31 percent of a plan's Part D summary rating. Plans achieving an overall rating of four stars or higher are eligible for a five percent quality bonus payment. For measure year 2026 CMS temporarily reduced the three measures to single weight while phasing in sociodemographic status risk adjustment, with a return to triple weighting expected for the 2027 Star Ratings, and discontinued the exclusion of inpatient and skilled nursing facility days from the adherence calculation. Weighting varies by rating year; confirm the applicable year in the CMS Star Ratings Technical Notes.
Views expressed here are my own. Nothing in this piece is legal, investment, or clinical advice.
About the Author
Patrick R. Coyle is the originator of the Patients + Profitability™ philosophy and the frameworks built on it, including The 10 Exits of Therapy™ and the Five Layers of GTN™. He previously served as VP & CFO of Eisai Americas, GTN Practice Lead at IQVIA, and Managing Director of GTN Risk Advisory at Baker Tilly, with senior finance and commercial roles at Novartis, Insmed, and Bayer. He is the Founder and CEO of Novus Proximus LLC.
More frameworks, guides, and tools in the Resource Library. Reach him at hello@patrickrcoyle.com.
The views expressed are my own and are not made on behalf of any current or former employer. All trademarks belong to their respective owners.
The patient-side view of the same ten exits is at Where did your treatment stop?