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Sidley Austin says it published an update on proposed Medicare Part D PBM reforms
Sidley Austin said it published an update on proposed Medicare Part D pharmacy benefit manager reforms, focusing on implications for pharmaceutical manufacturers. The firm’s article examined proposed compensation limits, rebate arrangements, reporting and federal oversight, distinguishing the Medicare proposals from separate changes affecting the commercial insurance market.
Key points
- Sidley Austin’s update discussed a proposed cost-plus standard for fair market value service fees.Sidley Austin
- The firm’s article examined full pass-through of manufacturer rebates to plan sponsors.Sidley Austin
- Sidley Austin’s update addressed proposed confidentiality and disgorgement requirements.Sidley Austin
- The firm’s article said comments were due December 15, 2026.Sidley Austin