This article examines Pharmacy Benefit Manager’s (“PBM”) “rebate walls” and the impact on the United States drug supply chain.  The Federal Trade Commission head, Commissioner Rohit Chopra, recently issued a report on PBM rebate walls,... Read More
Blogs & Articles | Community, Retail Pharmacies | Defending Pharmacies in PBM Audits | Life Sciences | Pharmacy Law | Plan Sponsor PBM Contract Services

The United States drug supply chain is dominated by three vertically integrated Pharmacy Benefit Managers (“PBMs”) that are owned under the same corporate umbrella as the largest insurance companies, specialty pharmacies and chain pharmacies. ... Read More
Blogs & Articles | Life Sciences | Pharmacy Law | Plan Sponsor PBM Contract Services

The FDA has delayed the verification of salable returns requirement under the Drug Supply Chain Security Act (DSCSA) until November 27, 2023. On October 22, 2020, FDA released a Guidance delaying enforcement of the provision that requires wholesale... Read More
Blogs & Articles | Life Sciences | Pharmacy Law | Regulatory Compliance, including FDA, DEA and HIPAA

On April 30, 2020, the Food and Drug Administration (FDA) issued new guidance relaxing certain requirements under the Drug Supply Chain Security Act (DSCSA) for COVID-19 related drug products.  In the guidance, FDA explained that under the DSCSA... Read More
Blogs & Articles | Chain Pharmacies | Community, Retail Pharmacies | COVID-19 Resources | Life Sciences | Pharmacy Law | Physician Dispensing | Specialty Pharmacies