On January 15, 2023, the Vermont Department of Financial Regulation (the “Department”) issued a report titled “Act No. 131 (2022) Report: Pharmacy Benefit Management” (the “Report”). As the title suggests, the Department was required... Read More
Since being established in May 2022, New York’s Pharmacy Benefits Bureau (“Bureau”) has requested input from the public on six separate occasions regarding New York’s laws governing Pharmacy Benefit Managers (“PBMs”). The Bureau’s... Read More
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
In a recent trend, compounding pharmacies have been receiving notices of audit from the Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services (“HHS”). In the notice, OIG requests that the pharmacies submit... Read More
Pharmacy benefit managers (PBMs) regularly conduct audits on pharmacies to review their performance in relation to the PBM’s terms and conditions. There are several different types of compliance audits that PBMs may initiate, such as desktop,... Read More
*As seen in Medical Economics* There are some persuasive incentives for your practice to consider implementing or reviewing its antitrust compliance right now. Every four years, like clockwork, law firms feel the urge to remind their clients... Read More
In FTC v. Surescripts, the Federal Trade Commission (“FTC”) has sued Surescripts alleging illegal vertical & horizontal restraints to maintain monopolies over “e-prescribing” markets. The FTC alleges Surescripts’ imposition of... Read More
