As the Pharmacy Benefit Managers (PBMs) prepare for the end-of-year “housekeeping”, pharmacies should be aware of the PBM audit trends and arm themselves with information necessary to preempt—and strategies to outright avoid—falling victim... Read More
As Pharmacy Benefit Managers (PBMs) review participation in their retail pharmacy networks, pharmacy providers find themselves at risk of termination over past audit results. We have recently seen a significant increase in a particular PBM... Read More
As Frier Levitt reported here, earlier this year, CVS Caremark (“Caremark”) implemented a notification requirement for pharmacies making bulk purchases. Pharmacies that were looking to make bulk purchases that exceeded a “30 day supply”... Read More
As a follow-up to our previous article on the CREATES ACT, other types of clinical trials for which we seek comparator drugs are mostly for head-to-head comparisons for new indications, or non-inferiority trials, and generally fall under 505(b)(1),... Read More
The refusal to provide comparator products violates federal and state antitrust laws and the CREATES Act. Although the Supreme Court has expressed caution about imposing antitrust liability based on a monopolist’s unilateral refusal to deal, the... Read More
As Coronavirus (COVID-19) cases continue to plateau and as the nation experiences the benefit of social distancing, the focus has quickly turned to the development of a vaccine. Promising Vaccines Despite the substantial cost of developing,... Read More
