On February 9, 2023, the Centers for Medicare and Medicaid Services (“CMS”) released a memorandum (the “Memorandum”) setting forth CMS’s proposed methods for calculating so-called “Inflation Rebates” as mandated by the recent Inflation... Read More
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
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
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
The New York State Department of Financial Services’ recently established Pharmacy Benefits Bureau (“Bureau”) has requested additional Public Comments regarding Pharmacy Benefit Managers (“PBMs”) in New York. The Bureau, as an... Read More
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
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
After a PBM terminated our pharmacy client from its pharmacy Network, Frier Levitt successfully reversed the termination following an appeal and communication with the PBM. The PBM sent a Notice of Termination our client alleging that the pharmacy... Read More
“DIR” Fees and “clawbacks” are major buzzwords among independent pharmacies and other providers, and even among legislators, as the rising cost of prescription drugs is an ever-present topic in politics. Although Frier Levitt has discussed... Read More
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
