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
Antitrust Review and Compliance | Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Biotech Companies | Chain Pharmacies | Clinically Integrated Networks (CINs) | Community Oncology Practices & Other Dispensing Physician Practices | Community, Retail Pharmacies | Defending Pharmacies in PBM Audits | Digital Pharmacies | DIR Fees | Dispensing Physician Practices and Dispensing Physicians | Fertility Pharmacies | Hospitals and Healthcare Systems | Integrated Delivery Network | Integrated Delivery Network and Hospital System Pharmacy | Long-Term Care Pharmacies | Manufacturers | Outsourcing Facilities (503B) | PBM Qui Tam Lawsuits | Pharmaceutical Manufacturers | Pharmaceutical Wholesalers | Physician Dispensing | Plan Sponsor PBM Contract Services | Specialty Pharmacies | Supermarket Pharmacies | Traditional Compounding Pharmacies (503A) | Urologist | Veterinary Compounders

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
Antitrust Review and Compliance | Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Chain Pharmacies | Clinically Integrated Networks (CINs) | Community Oncology Practices & Other Dispensing Physician Practices | Community, Retail Pharmacies | Defending Pharmacies in PBM Audits | Digital Pharmacies | DIR Fees | Dispensing Physician Practices and Dispensing Physicians | Fertility Pharmacies | Home Infusion Providers | Hospitals and Healthcare Systems | Integrated Delivery Network | Integrated Delivery Network and Hospital System Pharmacy | Long-Term Care Pharmacies | Medical Spas and Cosmetic Services | News | Outsourcing Facilities (503B) | PBM Qui Tam Lawsuits | Physician Dispensing | Plan Sponsor PBM Contract Services | Specialty Pharmacies | Supermarket Pharmacies | Traditional Compounding Pharmacies (503A) | Urologist | Veterinary Compounders

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
Antitrust Review and Compliance | Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Biotech Companies | Chain Pharmacies | Community, Retail Pharmacies | Defending Pharmacies in PBM Audits | Digital Pharmacies | Fertility Pharmacies | Integrated Delivery Network and Hospital System Pharmacy | Long-Term Care Pharmacies | Specialty Pharmacies | Supermarket Pharmacies | Traditional Compounding Pharmacies (503A) | Uncategorized

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
Antitrust Review and Compliance | Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Biotech Companies | Chain Pharmacies | Community, Retail Pharmacies | Defending Pharmacies in PBM Audits | Digital Pharmacies | Fertility Pharmacies | Integrated Delivery Network | Integrated Delivery Network and Hospital System Pharmacy | Long-Term Care Pharmacies | Payor Network Access and Defense of Network Terminations | Specialty Pharmacies | Supermarket Pharmacies | Traditional Compounding Pharmacies (503A)

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
Antitrust Review and Compliance | Articles | Federal and State Fraud and Abuse Counseling | Federal and State Fraud and Abuse Counseling | Regulatory Compliance, including FDA, DEA and HIPAA | Traditional Compounding Pharmacies (503A) | White Collar Criminal Defense & Government Investigations

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
Antitrust Review and Compliance | Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Chain Pharmacies | Community, Retail Pharmacies | Defending Pharmacies in PBM Audits | Digital Pharmacies | Fertility Pharmacies | Life Sciences | Long-Term Care Pharmacies | News | Pharmacy Law | Specialty Pharmacies | Supermarket Pharmacies | Traditional Compounding Pharmacies (503A)

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
Antitrust Review and Compliance | Articles | Life Sciences | Pharmacy Law