The deal mandates that Caremark, which includes its pharmacy benefits and affiliated businesses, facilitate up to $8.5 billion in consumer savings through 2034. A substantial portion of this—roughly $4.5 billion—is expected to stem from point-of-sale rebates. The FTC, which sued the industry’s three largest managers earlier this year, alleged that Caremark, Express Scripts, and OptumRx artificially inflated insulin prices through anticompetitive rebate schemes.

To satisfy the regulators, Caremark Rx and Zinc Health Services will overhaul their business operations. CVS committed to aligning member cost-sharing with the net price of medicines, simplifying pricing models, and increasing disclosure regarding broker compensation. Furthermore, the company will decouple manufacturer payments from list prices and transition independent retail pharmacies to an acquisition-based reimbursement model to better reflect actual drug costs. Purchases made under the TrumpRx program will now count toward patient deductibles and out-of-pocket maximums.