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ERIC Comment Letter to California State Assembly Appropriations Committee: Proposal Regulating PBM Network Practices Raises ERISA Preemption Concerns (PDF)
The ERISA Industry Committee [ERIC] 
[Opinion] Aug. 13, 2024 "As currently drafted, SB 966 would create a range of compliance requirements for PBM services offered under health care service plans and health insurance policies.... [T]he bill expressly states, ... that 'Any activity conducted by a pharmacy benefit manager, as defined in this division, shall be construed as the business of insurance.' ... State regulators could interpret this provision to include self-insured ERISA plans, jeopardizing the plans' control over the design and administration of plan benefits and potentially sparking legal challenges." MORE >> |
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