In October 2022, Pennsylvania’s former Governor Tom Wolf, before leaving office, signed House Bill 1630 (“HB 1630”) into law. HB 1630 grants the Pennsylvania Auditor General authority to audit pharmacy benefit managers (“PBMs”) that... Read More
As previously discussed in our article in June 2022, the New York Department of Health (“NYDOH”) has taken the position that community pharmacies that have dual enrollment with Medicare as both a pharmacy provider (through CMS-855B enrollment)... Read More
The Court of Appeals for the Third Circuit recently issued its decision in the consolidated cases of drug manufacturers Sanofi, Novo Nordisk, and AstraZeneca ruling in the drug manufacturers favor versus the Department of Health & Human Services... Read More
A staple of Medicare and False Claims Act (“FCA”) law – the so-called “Overpayment Rule” – may soon be undergoing a dramatic shift, and doing so in a way that could increase liability for healthcare providers while potentially reducing... Read More
Frier Levitt Partner Jason N. Silberberg was quoted in a Modern Healthcare article, “More MA Insurer Audits Mean More Scrutiny on Providers” by Lauren Berryman. The Final Rule set to be implemented on February 1, 2023 is likely to increase the... Read More
Earlier this month, the Centers for Medicare and Medicaid (“CMS”) released a Memorandum overviewing next steps in the federal government’s implementation of the Medicare Drug Price Negotiation Program. Though CMS has only just “set the... Read More
On September 23, 2022, the Fourth Circuit issued a per curiam opinion upholding the dismissal of a 2014 qui tam suit against Forest Laboratories, LLC while vacating both the district court and subsequent Fourth Circuit panel opinions. Although the... Read More
Pharmacy benefits manager (PBM) Caremark has now placed Trimester 1 Reports for year 2022 in the Caremark Provider Portal. Caremark provides its summaries of Direct and Indirect Remuneration (DIR) Fees paid by participating pharmacy providers for... Read More
On May 9, 2022, the Centers for Medicare and Medicaid Services (CMS) released a Final Rule (Final Rule) entitled, “Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs.” ... Read More
The New York Department of Health (NYDOH) has promulgated enrollment requirements for pharmacies seeking to participate in the Medicaid program which are unrelated to many of the actual operations of pharmacies within the state of New York.... Read More