Independent pharmacies don’t have the luxury of using mergers to offset the PBM power imbalance. In fact, when states proposed letting independents form their own pharmacy networks, the FTC argued against it, warning that it would “impair the ability of prescription drug plans to negotiate the best prices with pharmacies.”

When I read this it makes me question the legitimacy of the regulatory organization. It makes me couple this with the instance of 'bill mills' alleged to exist currently in both state and federal legislature.

EDIT: I say alleged because getting concrete documentation on the subject is suppressed.

"These middlemen manage prescription drug benefits for health plans, contracting with drug manufacturers and pharmacies in a multi-sided market. Over the past 30 years, PBMs have evolved from paper-pushers to significant controllers of the drug pricing system, a black box understood by almost no one. Lack of transparency, unjustifiable fees, and massive market consolidations have made PBMs among the most profitable corporations you’ve never heard about."