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PBM Aberrant Product Lists: The Aberrant NDC and Percentage Billed Compared to Total Volume is Only Part of the Issue

Billing of Aberrant NDCs Beginning in January of 2020, at least one of the major PBMs began monitoring its network pharmacies for the billing of specific NDC numbers the PBM considered “Aberrant”. The list of NDCs was sent to network pharmacies in November of 2019 and has since been updated in November of 2020. The […]

Supreme Court Victory for States and Independent Pharmacies

With the national conversation discussing a Supreme Court of the United States (SCOTUS) that is often highly politicized and characterized as divided, it should be comforting to the independent pharmacy community to know that SCOTUS issued a unanimous, 8-0 (Justice Barrett did not participate in this decision) decision in the case of Rutledge v. PCMA. […]

What medical professionals should know about liability during a pandemic

The past weeks have left medical providers and health care professionals at risk in more ways than one. In addition to their exposure to contagion, our vital workers may be left exposed legally. Currently, medical providers are working under a patchwork of protections. The result? Ongoing uncertainty and potential for catastrophic and expensive legal suits. […]


www.covid19lawfirm.com Boesen & Snow is working with our clients regarding common pharmaceutical supply chain questions, pharmacy operations issues, and business continuity plans related to COVID-19. Please contact our attorneys about COVID-19 and your legal issues. Matters with which we are already engaged include: Properly documenting the usage of override codes for emergency fills (overuse will […]

Salespeople sue drug companies for whistleblower retaliation

A federal jury in Seattle recently awarded $5.8 million to a Tacoma-based pharmaceutical sales representative. She said her employer fired her to retaliate for her refusing to push a product’s off-label uses and for filing an ethics complaint with the company. Also, in Arizona and Florida, two former employees of another drug company recently filed […]

How can I avoid violating the anti-kickback statute?

The anti-kickback statute was passed in 1972 to prevent doctors or physicians from receiving and accepting a bribe to refer patients to certain facilities or programs. Congress also enacted this law to protect healthcare patients and government-run health programs and eliminate this type of abuse and fraud. Violating this law can have severe consequences and […]