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California Establishes Extensive Rules for Pharmacy Benefit Manager Conduct
Duane Morris LLP 
[Guidance Overview] Oct. 23, 2025 "[K]ey provisions ... include: [1] an 'any willing provider' requirement; [2] a prohibition on spread pricing; [3] a requirement to use a passthrough business model; and [4] a general prohibition on retroactive payment reductions and payment reductions through a reconciliation process. Effective dates vary, with many of the provisions applying to any contracts from January 1, 2019, or later and other provisions applying to contracts beginning January 1, 2026, or 2027." MORE >> |
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