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PBM Enrollment Denials for Common Association Regardless of Acquisition Structure

In the world of Pharmacy Benefit Manager (PBM) enrollment, guilt by association is one of the most common reasons PBM’s deny new pharmacy owners network access.  Boesen & Snow often represents new clients who come to the firm with PBM enrollment denials due to alleged common associations with persons or entities with significant audit findings …

Boesen and Snow Secures Back-to-Back PBM Network Termination Reversals.

In successive weeks, Boesen and Snow has obtained two favorable decisions through a PBM’s Appeal Hearing Process that reversed Network Terminations due to audit findings.  The firm collaborated with each client to prepare thorough responses to initial and final audit findings and termination appeal hearing presentations that convinced the PBM to quickly rescind the decisions …

PBM Audits Move Fast. Start Preparing Your Defense Today!

Don’t Wait! Build a relationship with an Experienced Pharmacy Law Team One of the more stressful parts of going through Pharmacy Benefit Manager (PBM) audit is that, by the time the average pharmacy hires experienced pharmacy law attorneys to defend their business, there may only be two weeks or less to formulate a successful response.  …

Scrutiny of PBMs Continue (And It’s About Time)…

Both federal and state authorities are increasing the scrutiny and regulation of Pharmacy Benefit Managers (“PBMs”). In the U.S. Senate, Senator Chuck Grassley (R – Iowa) and Senator Maria Cantwell (D – Washington) have sponsored the Pharmacy Benefit Manager Transparency Act of 2022. The bipartisan bill would empower the Federal Trade Commission to increase drug …

FTC Reverses Previous Deadlock in Pivotal Vote to Probe Pharmacy Benefit Managers’ Practices

On June 7, 2022, in a unanimous 5-0 vote, The US Federal Trade Commission reversed a previous 2-2 deadlock vote that will result in the commissions probe of pharmacy benefit managers including the top six PBMs; CVS Caremark, Express Scripts, Inc. OptumRx, Inc., Humana Inc., Prime Therapeutics LLC and MedImpact Healthcare Systems, Inc. After the …

Board of Pharmacy Investigations: How Your PBM Audit May Put You in Hot Water with The State Boards of Pharmacy

PBM Audits commonly review prescription hard copies, signature/delivery logs, drug invoice purchases, proof of copayment collection, proof of prescriber/patient relationship, patient consent to fill, and non-resident state licensure. PBM Audits are just one of the many hurdles your pharmacy will inevitably face while you strive to serve patients. Poor audit findings lead to extensive financial …

How to Respond to a PBM Audit Notice

Pharmacies are plagued by the burdens of addressing the terms of their pharmacy benefit manager (PBM) agreements, whether those terms are reasonable or not.  Pharmacies are dogged with PBMs wielding their power by initiating a PBM audit – sometimes to root out actual discrepancies, sometimes to injure your business in favor of the PBM’s own affiliated …