The public record does not show how the FTC reached its $13 billion Caremark savings ceiling

The Federal Trade Commission announced on July 14 that a proposed settlement with CVS Health's Caremark pharmacy benefit manager and Zinc Health Services would lock in up to $8.5 billion in consumer savings and unlock up to $4.5 billion more over ten years. Those phrases matter. The agency described upper limits, not guaranteed payments, a fine or a forecast of the most likely outcome. [FTC announcement](https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-secures-major-settlement-caremark-resolving-antitrust-case-against-second-drug-middleman)

The settlement is also not final. The FTC accepted it for a 30-day public-comment periodpublic-comment periodA public-comment period gives interested people and organizations time to submit information before the FTC decides whether to withdraw, modify or finalize an order. [FTC analysis](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkSettlementAAPC.pdf) and said it would later decide whether to withdraw, modify or finalize the proposed order. A final order would carry the force of law for Caremark's future conduct. [FTC announcement](https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-secures-major-settlement-caremark-resolving-antitrust-case-against-second-drug-middleman) [FTC analysis](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkSettlementAAPC.pdf)

A policy's economic effect is not every benefit observed after it begins. It is the difference between what happens with the policy and a credible estimate of what would have happened without it. Evaluators call that second path the counterfactualcounterfactualA counterfactual is an estimate of what would have happened without the policy, allowing an evaluator to separate the policy's effect from other changes. [GAO](https://www.gao.gov/products/117387). The Government Accountability Office says program evaluation must compare observed outcomes with an estimate of the no-program outcome and distinguish program effects from competing causes. [GAO](https://www.gao.gov/products/117387)

Think of a shop that is already cutting electricity use before a new efficiency rule arrives. Counting every lower bill after the rule as a benefit would overstate the rule's effect. The relevant benefit is the additional reduction caused by the rule, plus any existing reduction that the rule genuinely prevents from disappearing.

That distinction is central here because CVS says the agreement reinforces changes it has already made, while the FTC says part of the total is being locked in. The documents therefore acknowledge that some claimed benefits precede the final order. Neither publication provides the baselinebaselineA baseline is the starting pattern of costs, enrollment and business practices against which a proposed policy is measured. [GAO](https://www.gao.gov/products/gao-18-151sp) needed to separate savings that would continue anyway from savings preserved because of the settlement. [CVS Health](https://www.cvshealth.com/news/company-news/cvs-caremark-announces-agreement-with-ftc.html) [FTC announcement](https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-secures-major-settlement-caremark-resolving-antitrust-case-against-second-drug-middleman)

The FTC says the settlement locks in up to $8.5 billion in savings over ten years. Its announcement does not identify the Caremark programs included, the current yearly savings, the number of covered members or the scenario in which Caremark would reverse those programs without the order. [FTC announcement](https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-secures-major-settlement-caremark-resolving-antitrust-case-against-second-drug-middleman)

The agency's six-page analysis explains the conduct required by the order but contains no $8.5 billion figure, annual schedule, model, formula, confidence range or probability of reversal. The proposed order supplies legal obligations but no financial model for this savings bucket. [FTC analysis](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkSettlementAAPC.pdf) [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

That does not show the preserved benefit is zero. Some provisions are concrete: the order restricts discrimination against qualifying low-list-price versions of drugs, limits how member payments may be calculated and requires access to specified affordability programs. The problem is narrower: the public cannot translate those obligations into $8.5 billion without assumptions the FTC has not published. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

CVS says greater client adoption of point-of-sale rebates and continued innovation should help clients generate an estimated $450 million in savings per year for each of the next ten years. Multiplying the stated annual estimate by the stated period produces $4.5 billion, exactly matching the FTC's additional-savings ceilingceilingA ceiling is the highest amount claimed under a set of assumptions, not necessarily the most likely result.. [CVS Health](https://www.cvshealth.com/news/company-news/cvs-caremark-announces-agreement-with-ftc.html) [FTC announcement](https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-secures-major-settlement-caremark-resolving-antitrust-case-against-second-drug-middleman)

That numerical match strongly suggests that CVS's annual estimate supplies the headline arithmetic for the FTC's second bucket. Neither source explicitly publishes a shared model, however, so the match should not be presented as proof that both organizations used identical underlying calculations.

The public documents do not disclose how many members are eligible, how many already receive point-of-sale rebates, which drugs and rebaterebateA rebate is a discount usually paid by a drug manufacturer after a prescription is filled rather than deducted from the published price in advance. [CBO](https://www.cbo.gov/publication/57772) amounts enter the model, how quickly sponsors are expected to adopt the offer or how savings are divided between Aetna and unrelated clients. Without those inputs, $450 million is an unsupported model output rather than a result an outside reader can reproduce. [CVS Health](https://www.cvshealth.com/news/company-news/cvs-caremark-announces-agreement-with-ftc.html) [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

The fact that most commercial sponsors may request customized terms does not mean the order lacks causal force. Caremark must make its standard offer available, disclose it in marketing and requests for proposals, avoid disparaging it and avoid coercing sponsors into different terms. A sponsor choosing another design must receive the standard offer and sign an acknowledgement. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

Caremark must also spend at least $10 million a year for five years advertising and promoting the standard offerings to plan sponsors and qualifying community pharmacies. Those requirements could change sponsor awareness and adoption even when the final choice remains voluntary. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

A defensible estimate would therefore compare adoption under the order with adoption expected without it. CVS attributes its annual forecast to greater client adoption, but neither CVS nor the FTC publishes the starting adoption rateadoption rateThe adoption rate is the share of eligible plan sponsors that choose the standard offering or a particular feature within it., the no-order trajectory or the order-driven trajectory. [CVS Health](https://www.cvshealth.com/news/company-news/cvs-caremark-announces-agreement-with-ftc.html) [GAO](https://www.gao.gov/products/117387)

Section II requires specified domestic fully insured Aetna plans to use protections that keep a member's payment no higher than the contracted amount minus the rebate and prevent the payment from being based on a higher list-price benchmark. The FTC analysis says the meeting competition exception does not apply to those Aetna protections. [FTC analysis](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkSettlementAAPC.pdf) [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

For other commercial sponsors, the standard offeringstandard offeringThe standard offering is the package of PBM terms Caremark must make available to commercial plan sponsors under the proposed order. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf) must be available, but Sections II, III, IV and V allow customized terms when the sponsor follows the written-request and acknowledgement process in Section XII. Section V is the provision that places applicable rebates or discounts at the point of salepoint of saleThe point of sale is the pharmacy-counter stage when a prescription is filled and the patient's payment is calculated. [CMS](https://www.cms.gov/newsroom/fact-sheets/medicare-part-d-direct-indirect-remuneration-dir), ends predetermined rebate guarantees in the standard offer subject to specified exceptions and prohibits spread pricingspread pricingSpread pricing occurs when a PBM charges a plan more for a prescription than it reimburses the pharmacy and retains the difference. [FTC analysis](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkSettlementAAPC.pdf) there. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

The definitions of member and plan sponsorplan sponsorA plan sponsor is an employer, insurer, union health plan or government employer that buys commercial pharmacy-benefit services for its members. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf) exclude Medicare, Medicaid and Exchange coverage. The standard commercial offer therefore cannot be treated as a universal prescription-drug benefit. A savings model needs enrollment for the covered groups and must avoid assigning direct benefits to excluded groups. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

Point-of-sale rebates can materially help people whose deductibles or coinsurancecoinsuranceCoinsurance is a patient's payment calculated as a percentage of the price used by the plan. [CBO](https://www.cbo.gov/publication/57772) are calculated from a price that does not reflect manufacturer rebates. The order's standard offering would instead cap payment using the client contracted amountclient contracted amountThe client contracted amount is the prescription cost calculated under the plan sponsor's Caremark contract before subtracting the member's payment. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf) after the applicable rebate. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf) [CBO](https://www.cbo.gov/publication/57772)

But there are two different questions. The first is who pays less at the pharmacy. The second is whether the plan and its members collectively spend less. CBO explains that insurers commonly use manufacturer rebates to support lower premiums or more generous benefits shared across all enrollees. Moving a rebate to the patient filling a prescription can therefore redistribute an existing discount rather than create a discount of the same size. [CBO](https://www.cbo.gov/publication/57772)

The redistribution may still be valuable: it can move help toward a patient facing a large immediate bill. But a complete economic model would show the pharmacy-counter reduction alongside any change in premiums, employer contributions, other benefits, drug use and manufacturer pricing. The FTC and CVS publications do not disclose those offsets for the $4.5 billion claim. [CBO](https://www.cbo.gov/publication/57772) [FTC announcement](https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-secures-major-settlement-caremark-resolving-antitrust-case-against-second-drug-middleman) [CVS Health](https://www.cvshealth.com/news/company-news/cvs-caremark-announces-agreement-with-ftc.html)

The proposed order defines the implementation date as the earlier of Caremark's certification that it has completed all requirements or January 1, 2027. Some provisions, including the point-of-sale rebatepoint-of-sale rebateA point-of-sale rebate applies a negotiated discount when the patient buys a medicine instead of using the rebate later to reduce broader plan costs. [CBO](https://www.cbo.gov/publication/57772) terms in Section V and the insulin program in Section IV, have deadlines no later than January 1, 2028. The order then remains effective for ten years after the implementation date. [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)

Neither the FTC announcement nor CVS statement says whether the savings totals are nominal dollarsnominal dollarsNominal dollars are future dollar amounts stated without adjusting them to remove inflation. [CBO](https://www.cbo.gov/publication/60815) or present valuepresent valuePresent value converts future amounts into one equivalent amount at a specified time, usually today. [CBO](https://www.cbo.gov/publication/60815), identifies a price year or supplies a discount ratediscount rateA discount rate is the rate used to translate future money into present value, reflecting that money available today can be worth more than the same amount received later. [CBO](https://www.cbo.gov/publication/60815). CVS's flat multiplication is consistent with an undiscounted ten-year sum, but the publications do not formally label it that way. [FTC announcement](https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-secures-major-settlement-caremark-resolving-antitrust-case-against-second-drug-middleman) [CVS Health](https://www.cvshealth.com/news/company-news/cvs-caremark-announces-agreement-with-ftc.html)

That choice matters because a dollar received later is not economically identical to a dollar received today. CBO explains that present-value calculations use a discount rate to translate future amounts into one value at a specified time and that the selected rate can materially change a long-term estimate. [CBO](https://www.cbo.gov/publication/60815)

• A yearly baseline showing current point-of-sale rebate use, affordability programs and affected patient payments.
• Eligible enrollment by plan type, including the contribution from domestic fully insured Aetna plans.
• The no-order scenario for programs classified as savings locked in, including the assumed probability and timing of reversal.
• Current and projected adoption rates for the standard offering, with and without the order.
• Drug-level or category-level prescription volumes, rebates and patient cost-sharing rules.
• The treatment of premiums, employer contributions, plan benefits, drug use and manufacturer responses.
• A check preventing the same benefit from appearing in both dollar buckets.
• The dollar basis, yearly schedule, discount rate and sensitivity analysis behind the ten-year totals.

GAO's economic-analysis framework emphasizes objective and scope, methodology, analysis of effects, transparency and documentation. Publishing the inputs above would not require the FTC to reveal patient identities. It would allow outside analysts to test the result, substitute alternative assumptions and see which assumptions drive the headline. [GAO](https://www.gao.gov/products/gao-18-151sp)

The public can reproduce $4.5 billion as ten times CVS's $450 million annual forecast and can add that amount to the FTC's $8.5 billion figure to reach $13 billion. It cannot reproduce the $450 million forecast, the $8.5 billion estimate or the portion of either amount caused by the order. [FTC announcement](https://www.ftc.gov/news-events/news/press-releases/2026/07/ftc-secures-major-settlement-caremark-resolving-antitrust-case-against-second-drug-middleman) [CVS Health](https://www.cvshealth.com/news/company-news/cvs-caremark-announces-agreement-with-ftc.html)

The auditable finding is not that the settlement produces no savings. It is that the disclosed evidence does not identify how much of the claimed $13 billion is incremental.

The order contains enforceable-looking mechanisms that could reduce some patients' immediate payments and influence sponsor choices if finalized. But mechanism is not magnitude. Until the FTC or CVS publishes the baseline, adoption path, covered enrollment and offset assumptions, $13 billion should be reported as the agency's upper-end claim rather than a verified estimate of economic benefit. [FTC analysis](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkSettlementAAPC.pdf) [Proposed order](https://www.ftc.gov/system/files/ftc_gov/pdf/CaremarkandZinc-DecisionandOrder.pdf)