This week, a new phenomenon began to emerge, impacting compounding pharmacies that previously received letters dated April 7, 2020 from Express Scripts, Inc. (“ESI”) initiating recoupment actions. At the request of the Defense Health Agency (“DHA”), ESI sent letters dated June 25, 2020 to some of the pharmacies within its network suspending the recoupment actions initiated on April 7, 2020 based on the lack of a Prescriber Patient Relationship, until...

At the request of the Defense Health Agency (“DHA”), Express Scripts, Inc. (“ESI”) has begun sending letters to some of the pharmacies within its network recouping on claims that had been submitted to TRICARE. This recent batch of letters is particularly notable because they focus on the results of DHA investigations – as distinct from an audit – a particularly powerful tool that enables ESI to evaluate and review claims...

The role of the pharmacist is continuously evolving. President Trump's October 2019 Executive Order 13890, which seeks to improve access to healthcare for Medicare patients, sparked arguments from the National Community Pharmacists Association ("NCPA") for the expansion of the pharmacist’s role. While Trump’s Order was made prior to the COVID-19 outbreak, the arguments made by the NCPA are particularly relevant in today’s climate. With the COVID-19 outbreak, many types of...