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Search the News Archive
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27 Matching News Items |
| 1. |
Wiley Rein LLP
Oct. 30, 2025
"[1] Choosing your contracting approach ... [2] Industry context: evolving models and oversight ... [3] Practical steps for plans."
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| 2. |
Wiley Rein LLP
Mar. 2, 2025
"While the extent of the impact of the EO is difficult to surmise at this stage, particularly given the previous lack of enforcement of the health care price transparency requirements by federal agencies, the EO signals that health care price transparency is a priority for the Trump Administration."
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| 3. |
Wiley Rein LLP
Dec. 2, 2024
"As a result of the growing scrutiny of PBMs by regulators, litigation involving PBMs has only increased.... [It] is important for plans to be aware of their fiduciary obligations under ERISA as it relates to their pharmacy programs. [This article provides] concrete steps plan sponsors and plan administrators can take now that can curtail any resulting liability arising from this litigation or any subsequent actions that follow."
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| 4. |
Wiley Rein LLP
Nov. 20, 2024
"There are many new models of pharmacy program service delivery under consideration and their number and design are limited only by creativity. [This article discusses] three such models ... [1] Product/service disaggregation, [2] Program segmentation, and [3] Industry disruption."
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| 5. |
Wiley Rein LLP
Oct. 18, 2024
"The Pilot Program is the latest effort by DOD to expand the defense industrial base and promote the utilization of small businesses (many of which are owned in whole or in part by ESOPs).... ' It is unclear how many contractors may be considered qualified businesses for purposes of the final rule (only eight businesses have participated in the pilot program's initial phase). Only COs, not contractors themselves, may submit applications for participation in the Pilot Program[.]"
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| 6. |
Wiley Rein LLP
Sept. 26, 2024
"[D]espite the continued consolidation and vertical integration of PBMs, health plans may minimize any adverse impact by contractually limiting the rights and responsibilities of PBM-affiliated organizations.... To protect against PBMs steering prescription drugs toward their affiliated pharmacies via formulary changes, health plans may maintain leverage over their formularies by exercising final approval rights over the content, form, format, and/or frequency of their formularies and formulary changes under their PBM contracts."
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| 7. |
Wiley Rein LLP
Aug. 20, 2024
"The negotiated prices range from 38% to 79% discounts off the 30-day supply list prices.... CMS commented that if the new prices had been in effect last year, Medicare would have saved an estimated $6 billion, or approximately 22%, across the 10 Selected Drugs.... CMS has until March 2025 to publish an explanation for the negotiated prices for each Selected Drug that go into effect on January 1, 2026. By February 2025, CMS will select up to 15 more drugs covered under Part D for negotiations for 2027."
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| 8. |
Wiley Rein LLP
July 7, 2024
"By holding that accrual occurs when the party seeking to challenge final agency action is first injured by it, the Court has opened the courthouse doors to parties who have been newly injured by old regulations ... This means that regulations that are reviewable under the APA may always be subject to direct, facial challenge, so long as someone has newly experienced an injury from the regulation." [Corner Post v. Bd. of Gov. of the Federal Reserve System, No. 22-1008 (S. Ct. Jul. 1, 2024)]
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| 9. |
Wiley Rein LLP
June 14, 2024
"[M]any issues of 'high value' to a health plan (both operationally and financially) are either not addressed in the PBM's template contract, or are addressed in a manner that fails to adequately serve the health plan's functional, regulatory, or competitive needs.... ... [1] Your PBM as your competitor ... [2] Segmenting your pharmacy program (modular contracting) ... [3] Defined terms ... [4] Financial terms."
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| 10. |
Wiley Rein LLP
May 14, 2024
"[GAO] published a report examining the regulation of pharmacy benefit managers (PBMs) in five states.... [HRSA] issued a final rule for the 340B Program's administrative dispute resolution process.... Senate Finance Committee Chairman Ron Wyden (D-OR) and Ranking Member Mike Crapo (R-ID) released a quite ambitious draft legislative proposal to address prescription drug shortages.... [CMS] issued new draft guidance for the second cycle of negotiations for the Medicare Drug Price Negotiation Program established by the Inflation Reduction Act of 2022."
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