"The CAA effectively federalizes PBM contracting, whereby the requirements of the CAA must be met in contracts between PBMs and GHPs and insurers (including contract extensions or renewals) as of the effective date of the CAA. While many customized/curated PBM agreements already address these required elements (and therefore will require only minor adjustments to capture some of the specific details), those PBM agreements that have used the PBM's own template contract as a base might require significant restructuring."  MORE >>