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New Jersey Has Revamped the LLC Law: Is Your New Jersey LLC Ready for the Changes?

On September 19, 2012, the Governor signed into law the New Jersey Revised Uniform Limited Liability Company Act (the "RULLA"). RULLA replaces the current NJ LLC Act, making substantial changes to the laws governing limited liability companies (“LLCs”) in New Jersey. These changes will have a substantial effect on all NJ LLCs and their members. In order to avoid the pitfalls and dangers, your NJ LLC must be aware of...

Prime Therapeutics May Not Be Reimbursing Compounders for All Ingredients Since Transition to D.0

Has your reimbursement for compounds been drastically reduced by Prime Therapeutics following the transition from NCPDP 5.1 to D.0? Prime requires pharmacies to submit all compound ingredients at the point-of-sale (“POS”). Prime does not usually “reject” the ingredients identified at the POS. This may create the false impression that Prime has “accepted” and agreed to reimburse for such ingredients. However, Prime has not been paying compounders for all of the...

OIG Report on Test Strips and Lancets Forecasts Increased Auditing of Pharmacy/DME Suppliers

On June 13, 2012, the OIG issued a report following its review of four contractors that processed claims for test strips and/or lancets. The report concludes that the Medicare contractors improperly allowed for payment of a total of approximately $271 million in claims that the OIG identified as high utilization claims. The OIG estimated that the contractors improperly paid $209 million to pharmacies/DME suppliers. This is a summary of the...

Are PSAOs Looking Out for Your Pharmacy’s Best Interests? A Request for Pharmacy Feedback

A pharmacy owner recently lamented that she experienced a sudden and significant reduction in reimbursement rates for compounds dispensed to patients whose insurance coverage had not changed. The decrease in reimbursement began immediately after a particular insurance plan switched from managing its own pharmacy benefit, to using a PBM. The pharmacy client wondered why its reimbursement for a given compound would change drastically when the PBM entered the picture. The answer to...

Q&A Regarding Copay Reimbursement Programs

We see a significant “chatter” within our pharmacy client base regarding copay reimbursement programs. The legality of these programs and how the pharmacy may/should treat copay cards and/or coupons is at issue. The following Q & A is intended to provide pharmacies with useful guidance. Are Copay Reimbursement Programs (“CRP”), such as Pfizer’s Lipitor for You® copay card program, legal? Or, are the copayments illegal “kickbacks” by manufacturers? The legality of...