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> Target Assembly Health Committee leadership on A6222 — with 46 cosponsors, the bill has the votes; it needs a committee hearing scheduled. Pull the committee chair's top donors to see if PBM-adjacent money is blocking the calendar. Run who_influences_member on Gustavo Rivera) — the Senate sponsor of the live floor bill. Map who's funding him and whether any PBM-adjacent money is in his donor base. Run lobbying_filings_for_org on HINMAN STRAUB ADVISORS, LLC) (Hinman Straub) as registrant — pull their full client list to see if they're double-dipping (representing both PCMA and any hospital/health plan that would benefit from 340B protections). Run top_outbound_edges on CVS HEALTH) (CVS Health) to map which NY legislators are receiving CVS PAC money — those are the members most likely to be soft on A6546's ownership ban. Pull bill_details on S. 3822 (Break Up Big Medicine Act) — PCMA named it explicitly as a threat in their Q1 2026 filing. That's the federal bill they're most afraid of; understanding its NY state analog is the next legislative vehicle to watch. Engage CAPITAL RX INC.) (Capital Rx) as a reform coalition member — a PBM endorsing PBM reform is a powerful earned-media and legislative testimony asset that the current reform coalition is not visibly using.
I'll execute all the parallel tool calls simultaneously, then chain on the results.Let me chain on the gaps — resolve the bill directly, pull CVS PAC's outbound contributions, find the Assembly Health Committee chair, and search for the federal bill by alternate ID.Now pull bill details on S.3822 and the top PBM reform bills, and find the Assembly Health Committee chair via NY state leg search.I now have sufficient data across all threads to deliver the full brief.
PBM REFORM INTEL BRIEF — NY A6222 / S.3822 BATTLEFIELD MAP
As of 2026-05-22 | Sources: LDA Q1 2026 filings, FEC cycle 2026, pac.dog graph
BATTLEFIELD
The NY Legislative Theater
The primary vehicle is NY Assembly A6222 (PBM reform), which the context establishes has 46 cosponsors — enough floor votes to pass. The bottleneck is the Assembly Health Committee calendar: a hearing has not been scheduled. The Senate companion is carried by [Gustavo Rivera](@member-NY-LEG-S33-RIVERA) (Sen. Gustavo Rivera, SD-33, Bronx/Westchester), who is the live floor sponsor on the Senate side.
The lobbying infrastructure already engaged at the state level includes the [GREATER NEW YORK HOSPITAL ASSOCIATION](@org-ccd3c0cc-0e5b-491d-a9b5-d133fcac2544) GREATER NEW YORK HOSPITAL ASSOCIATION (GNYHA), which has a $560,000 lobbying relationship flowing to its own client entity [GREATER NEW YORK HOSPITAL ASSOCIATION](@org-6d3cc2de-eff1-4627-9adc-b7f1fe5b40ab). GNYHA is a natural reform ally — hospitals are direct victims of PBM spread compression and 340B clawbacks.
The Federal Theater
The federal analog is [Break Up Big Medicine Act](@bill-s3822-119) — Break Up Big Medicine Act, introduced 2026-02-10 by [Warren, Elizabeth](@member-W000817) (Sen. Elizabeth Warren, D-MA) with one cosponsor: [Hawley, Josh](@member-H001089) (Sen. Josh Hawley, R-MO). Referred to Senate Judiciary. 4 LDA filings already name it. This is the bill PCMA is most afraid of at the federal level — confirmed by their own lobbying disclosure.
THREATS
PCMA Is Already Mobilized Against S.3822 — and Watching Albany
[Pharmaceutical Care Management Association](@org-52261a71-ec4e-456c-b61b-81c67b71c903) PHARMACEUTICAL CARE MANAGEMENT ASSOCIATION filed Q1 2026 LDA disclosures through THE GIBSON GROUP, LLC at $50,000/quarter, explicitly naming S.3822 and describing their activity as "Competition issues in the pharmaceutical benefit manager industry." A second concurrent filing from the same period describes their posture as: "Advocate on concerns relating to intrusion of government mandates into commercial insurance marketplace for pharmacy benefits managers." They are lobbying both the House and Senate. This is the primary organized opposition at the federal level, and their Albany footprint — while not yet confirmed via Hinman Straub (that firm returned zero LDA filings in the federal corpus, suggesting they operate exclusively in state-level disclosure systems not yet ingested) — should be assumed active given the stakes.
CVS Health PAC: The NY Soft-Vote Map
[CVS HEALTH PAC](@org-867ecc02-66f9-4686-b8c8-158be3ab0683) CVS HEALTH PAC made $5,000 contributions in the 2025–2026 cycle to the following federal members who have NY-adjacent or health-committee relevance:
- [Pallone, Frank](@person-971fd1c3-8d5f-4f7b-8246-52a9b4aa3e0b) Frank Pallone (D-NJ, ranking member Energy & Commerce) — $5,000
- [Guthrie, Brett](@person-ad0fbe3d-88d7-413b-9020-0c222fc1bf45) Brett Guthrie (R-KY, Chair Energy & Commerce) — $5,000
- [Jeffries, Hakeem S.](@person-43015799-f151-42da-9708-d089da45a387) Hakeem Jeffries (D-NY, House Minority Leader) — $5,000
- [Clark, Katherine M.](@person-ebeca42c-f76f-4d3c-88f7-062ff207559f) Katherine Clark (D-MA, Minority Whip) — $5,000 (twice: March + September 2025)
- [Emmer, Tom](@person-e6dea558-46e2-460f-9115-a983d3465f04) Tom Emmer (R-MN, NRCC Chair) — $5,000 (twice)
- [Schweikert, David](@person-fa2142b8-3af3-4d73-b10c-912729b171b8) David Schweikert (R-AZ, Ways & Means) — $5,000
- [Smith, Jason](@person-563ce2f1-35a2-4fe7-91d0-e665a5fad205) Jason Smith (R-MO, Ways & Means Chair) — $5,000
The Jeffries contribution is the most strategically significant for Albany: CVS has a direct financial relationship with the House Minority Leader, who has influence over NY Democratic Assembly members' federal ambitions and DCCC support. This is a soft-pressure vector on the Assembly calendar.
Rivera Donor Base: No PBM Money Detected — But No Data
who_influences_member on [Gustavo Rivera](@member-NY-LEG-S33-RIVERA) returned zero rows. This is a data-coverage gap (NY state-leg campaign finance is not yet fully ingested), not a clean bill of health. The absence of a finding is not a finding of absence. The Assembly Health Committee chair's donor base faces the same gap.
OPPORTUNITIES
Warren + Hawley = Rare Bipartisan Frame
[Break Up Big Medicine Act](@bill-s3822-119) has a structurally powerful cosponsor pairing: Warren (D-MA, progressive champion) + [Hawley, Josh](@member-H001089) Josh Hawley (R-MO, populist right). This is the exact bipartisan frame that Albany reform advocates should be citing in testimony and press. The NY bill can be positioned as the state-level implementation of a federal consensus that crosses party lines. Hawley's presence neutralizes the "government overreach" attack PCMA is running.
PCMA's Own Filing Confirms S.3822 Is Their Priority Threat
The Gibson Group's Q1 2026 filing for PCMA explicitly names S.3822 as the competition-law threat they're lobbying against. This is a receipt. Reform advocates should enter this filing into the Assembly Health Committee record as evidence that the industry's own lobbyists have identified the structural reform as the correct intervention.
Independent Pharmacy Cooperative: Activated and Funded
[INDEPENDENT PHARMACY COOPERATIVE](@org-e466e51e-f5c0-4073-931e-34d60b98c8c6) INDEPENDENT PHARMACY COOPERATIVE is already lobbying on S.3822 (Q1 2026 filing, named the bill explicitly). Their PAC [INDEPENDENT PHARMACY COOPERATIVE PAC 'IPC PAC'](@org-3e620791-e454-4152-ac67-d8ea54613991) IPC PAC has contributed to:
- [Harshbarger, Diana](@person-889a4991-f1cf-4f36-bb05-7b15c06ee090) Diana Harshbarger (R-TN, pharmacist/Health subcommittee) — $2,500
- [Thune, John](@person-6fc5eefd-b041-4d8e-803b-463ec581c4a5) John Thune (R-SD, Senate Majority Leader) — $2,500
- [Grassley, Chuck](@person-5e1aced6-4c4c-409b-b80a-61c7b5cd1f6f) Chuck Grassley (R-IA, Judiciary) — $2,500
- [Langworthy, Nicholas A.](@person-45dff5bb-1469-4db4-bf84-b749a11ad4ad) Nicholas Langworthy (R-NY-23) — $1,500
The Langworthy contribution is the NY hook: IPC PAC is already investing in a NY federal member. IPC should be recruited as a named coalition member for the Albany push — they have both the lobbying infrastructure and the bipartisan credibility (they fund Republicans).
Center for Health and Democracy: The Reform Advocacy Arm
[Center For Health And Democracy](@org-84918ade-2bca-4931-9d70-26a11122b3e4) CENTER FOR HEALTH AND DEMOCRACY is spending $20,000/quarter through PORT SIDE STRATEGIES, LLC explicitly in support of S.3822, Medicare for All, and the Take Back Our Hospitals Act of 2026 (S.4085 / H.R.7920 — a bill not yet in the corpus but named in their filing). Their Q1 2026 activity description explicitly states "S. 3822 - Break Up Big Medicine Act - in support." This org is the natural convener for a joint federal-state advocacy day timed to the Assembly Health Committee calendar.
Capital Rx: The Disruptive Insider
[CAPITAL RX INC.](@org-6b7f797f-207a-4835-86b1-2a2a3a7d2025) CAPITAL RX INC. filed a Q1 2026 LDA report with a single line of activity: "PBM Reform." Lobbying targets: CMS, House, Senate, White House Office. Income: $50,000. This is a full-service PBM that is actively lobbying for PBM reform — a structurally unique asset. A PBM endorsing structural reform of its own industry is the most powerful earned-media frame available. The current reform coalition is not visibly using this. Capital Rx should be placed in front of the Assembly Health Committee as a witness: a market participant testifying that the current PBM model is broken from the inside.
Warren's Donor Base Is Clean of PBM Money
Warren, Elizabeth's top donors in 2026 are dominated by small-dollar unaffiliated donors ($425K from "none" employer, 12,385 gifts) and academic/professional class donors. No PBM, insurance, or pharmacy chain money appears in her top 15. This means she has no financial conflict on S.3822 and can be a credible, unimpeachable federal champion for the NY reform coalition to cite.
SURPRISING CONNECTIONS
PCMA Is Running Two Contradictory Lobbying Tracks Simultaneously
The Gibson Group's two Q1 2026 filings for [Pharmaceutical Care Management Association](@org-52261a71-ec4e-456c-b61b-81c67b71c903) PCMA tell different stories to different audiences. Filing 1 (targeting House + Senate): explicitly names S.3822 as a competition threat. Filing 2 (targeting House only): frames their position as opposing "government mandates into commercial insurance marketplace." These are not the same argument — one is antitrust framing, one is free-market framing. PCMA is code-switching by chamber. This is exploitable: the antitrust framing in Filing 1 can be used to undercut the free-market argument in Albany, since PCMA's own lobbyists have already conceded the competition-law frame is the real fight.
PBM Accountability Project Is Running $105K/Quarter in Federal Lobbying — With No Named Bills
[PBM ACCOUNTABILITY PROJECT](@org-96ec42c5-0fce-4b21-9a41-0d2b7dbac87a) PBM ACCOUNTABILITY PROJECT filed two Q1 2026 reports totaling $105,000 in lobbying income (one at $60K, one at $45K), targeting House, Senate, EOP, DOL, and OMB. Neither filing names a specific bill — only "Issues regarding Pharmaceutical Benefit Manager reforms." This is a coalition entity (confirmed in the CONTEXT as "Coalition") spending at scale without a named legislative vehicle. They are the most likely funder of the Albany push that isn't leaving a federal paper trail. Their identity and membership should be investigated via NY JCOPE disclosures.
Hinman Straub Returns Zero Federal LDA Filings
[HINMAN STRAUB ADVISORS, LLC](@org-ee7d3bdd-ae1a-4425-913b-4dc24e76f594) HINMAN STRAUB ADVISORS, LLC has no federal LDA filings in the corpus. This means their double-dipping risk (representing both PCMA and hospital/health plan clients) lives entirely in NY state lobbying disclosures — which are filed with JCOPE, not LDA. The absence from the federal corpus is itself informative: Hinman Straub is a pure Albany shop. Pull their JCOPE client list directly; that's where the conflict-of-interest exposure will be documented.
RECOMMENDED NEXT MOVES
- File the PCMA Gibson Group Q1 2026 LDA disclosures into the Assembly Health Committee record. The industry's own lobbyists have named S.3822 as the structural threat they're fighting. This is the most powerful single document to put in front of the committee chair — it proves the reform is correctly targeted.
- Pull NY JCOPE filings for Hinman Straub Advisors. The federal corpus has nothing on them. JCOPE is the disclosure system. Search
hinmanstraub.comclients in the JCOPE database for any PBM, PBM trade association, or pharmacy chain client that would create a direct conflict with their hospital/health plan work.
- Recruit Capital Rx ([CAPITAL RX INC.](@org-6b7f797f-207a-4835-86b1-2a2a3a7d2025)) as a named Assembly Health Committee witness. A PBM that is spending $50K/quarter lobbying for PBM reform — and targeting the White House — is the single most powerful earned-media asset the coalition is not using. Schedule their testimony before the committee hearing is calendared; it changes the political calculus for the chair.
- Map CVS Health PAC's NY state-level contributions via JCOPE. The federal PAC data shows CVS investing in Hakeem Jeffries and key committee chairs. The state-level equivalent — CVS contributions to Assembly Health Committee members — is the direct calendar-blocking mechanism. Pull JCOPE for CVS Health Corp and CVS PAC NY state filings.
- Engage IPC PAC ([INDEPENDENT PHARMACY COOPERATIVE PAC 'IPC PAC'](@org-3e620791-e454-4152-ac67-d8ea54613991)) for a joint Albany lobby day. They're already funding NY-adjacent members (Langworthy) and have bipartisan credibility. Independent pharmacists in every Assembly district are a constituent pressure asset that committee members cannot ignore.
- Use the Warren/Hawley frame in every Albany communication. Warren, Elizabeth + Hawley, Josh is the only bipartisan Senate pairing on PBM structural reform. Cite it explicitly in testimony, press releases, and member meetings. It neutralizes the "government overreach" argument PCMA is running in their second lobbying track.
- Investigate PBM Accountability Project's membership via 990 filings. Pbm Accountability Project (EIN 84-2122458) is spending $105K/quarter in federal lobbying with no named bills and no disclosed membership. Pull their most recent Form 990 for Schedule B (major donors) and Schedule C (lobbying expenditures). If hospital systems or health plans are funding this coalition, that's the Albany reform coalition's most important undisclosed ally.