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
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As part of an invoice reconciliation audit, Pharmacy Benefit Managers (“PBMs”) routinely request pharmacies to provide documents pertaining to pharmacy-to-pharmacy drug transfers.  These documents include invoices and/or purchase summaries from... Read More
Articles | Community, Retail Pharmacies | Defending Pharmacies in PBM Audits | Life Sciences | Pharmacy Law

The current United States marketplace for the regulation of pharmacy benefits is a patchwork of inconsistent (and in some cases non-existent) state laws, state and federal agency regulations, agency manuals and federal laws. Uniform state laws would... Read More
Articles | Defending Pharmacies in PBM Audits | Life Sciences | Plan Sponsor PBM Contract Services

Value Based Care is the future of the United States healthcare system and the Office of the Inspector General (OIG) for the US Department of Health and Human Services is in full agreement. The OIG recently issued a Notice of Proposed Rulemaking that... Read More
Life Sciences | Pharmaceutical Wholesalers | Pharmacy Law | Physician Dispensing | Value Based Care

In a recent but aggressive trend, Express Scripts, Inc. (ESI) – the nation's largest Pharmacy Benefits Manager (PBM) – has begun auditing and recouping large sums of money from pharmacy providers stemming from drug purchases made from allegedly... Read More
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