"ERIC recommends that the Department go even further in final regulations.... [T]he Department must clearly state that GPOs must disclose the compensation they receive in connection with providing 'pharmacy benefit management services' to a self-insured plan.... [T]he Department must also specifically enumerate a list of entities that would be subject to these proposed regulations through their affiliation with offshore GPOs ... In short, each and every entity woven into this type of structure must be listed as an entity that is subject to the proposed Compensation Disclosure requirements."  MORE >>