In part one of this article series, Frier Levitt dissected the May 9, 2022, Centers for Medicare and Medicaid Services (CMS) Final Rule (Final Rule) entitled, “Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare... Read More
340B Covered Entity and Contract Pharmacy Regulatory and Contract Support | Administrative and Insurance Defense Law | Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Healthcare Law | Life Sciences

On Friday, June 17, 2022, the House Committee on Education and Labor (the Committee) issued a letter (the Letter) requesting the Hon. Gene L. Dodaro, U.S. Comptroller General and head of the Government Accountability Office (GAO) to conduct a study... Read More
Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Life Sciences | Pharmacy Law | Plan Sponsor PBM Contract Services

Recent CMS agency rulemaking has essentially eliminated pharmacy Direct and Indirect Remuneration (DIR) fees beginning in Plan Year 2024.  Providers “in the know,” however, are not cheering.  Our more technical article on the rulemaking is... Read More
340B Covered Entity and Contract Pharmacy Regulatory and Contract Support | Administrative and Insurance Defense Law | Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Healthcare Law | Life Sciences

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
All types of single and multi-specialty medical practice groups | Articles | Community Oncology Practices & Other Dispensing Physician Practices | Community, Retail Pharmacies | Digital Pharmacies | DIR Fees | Dispensing Physician Practices and Dispensing Physicians | Healthcare | Healthcare Law | Healthcare Practice Compliance | Life Sciences | Medicare and Insurance Audits | Medicare Audit Appeals | Medicare, Medicaid, and Other Commercial Payor Audits & Appeals | Pharmaceutical Wholesalers | Physician Dispensing | Physician Dispensing | Physicians and Medical Practices of all Specialties | Specialty Pharmacies | Supermarket Pharmacies | Traditional Compounding Pharmacies (503A)

Last week, the FTC announced an investigation of six large PBMs in the U.S., sending orders for information and records on business practices. The study will focus on a series of practices used by PBMs and their role in the drug system. The agency... Read More
Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Defending Pharmacies in PBM Audits | DIR Fees | Life Sciences | News | Pharmacy Law

On Monday, June 6, 2022, the Federal Trade Commission (FTC) voted unanimously to approve a “6(b)” study into the anti-competitive and abusive practices of Pharmacy Benefits Managers (PBMs), a move that has the potential to lead to significant... Read More
Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Chain Pharmacies | Community, Retail Pharmacies | Defending Pharmacies in PBM Audits | DIR Fees | Life Sciences | Pharmacy Law | Specialty Pharmacies

On April 14, 2022, the Federal Trade Commission (FTC) and Department of Justice (DOJ) held a public forum to hear from stakeholders about the effects of mergers within the health care industry and the effects of consolidation on healthcare workers,... Read More
Antitrust Tools Available to Combat PBM Abuse of Pharmacies | Articles | Defending Pharmacies in PBM Audits | DIR Fees | Healthcare | Life Sciences | Physicians and Medical Practices of all Specialties

Pharmacy Benefits Managers (PBMs) often make changes to their contracts with pharmacies through notice alone that does not require a signature from the pharmacy.  At least one PBM recently issued such a notice to pharmacies regarding a new Medicare... Read More
Articles | Defending Pharmacies in PBM Audits | DIR Fees | Life Sciences | Medicare, Medicaid, and Other Commercial Payor Audits & Appeals | Pharmacy Law

On March 7, 2022, Senator Vin Gopal introduced Senate Bill 2221 (“S2221”) with the goal of establishing transparency standards and licensing requirements for pharmacy benefit managers (“PBMs”) operating in New Jersey. Senate Bill S2221... Read More
Articles | Chain Pharmacies | Community, Retail Pharmacies | Digital Pharmacies | Life Sciences | Maximum Allowable Cost Pricing & Appeals | Pharmacy Law | Plan Sponsor PBM Contract Services