Latest / Pharmacy Podcast Network / The New PBM Regulatory Landscape: Talking Enforcement Trends, Contracting Strategies, and Future Opportunities for Specialty Pharmacies | NA

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The New PBM Regulatory Landscape: Talking Enforcement Trends, Contracting Strategies, and Future Opportunities for Specialty Pharmacies | NA · Pharmacy Podcast Network

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  Speaker 1: You are listening to the global network of podcasters dedicated
• 0:09
  Speaker 1: to the pharmacy profession. Welcome to the Pharmacy Podcast Network.
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  Speaker 2: You're listening to the NASP Specialty Pharmacy Podcast, a collaboration
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  Speaker 2: between the National Association of Specialty Pharmacy and the Pharmacy
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  Speaker 2: Podcast Network. Each episode dives deep into trends, challenges, innovations,
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  Speaker 2: and patient centric practices shaping the future of this dynamic
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  Speaker 2: and rapidly evolving industry. Whether you're a pharmacist or healthcare provider,
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  Speaker 2: patient advocate, or industry leader, you'll hear expert insights, real
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  Speaker 2: world evidence, and thought provoking discussion that highlights all that
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  Speaker 2: makes specialty pharmacy special.
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  Speaker 3: In support of NASP's mission to empower specialty pharmacy stakeholders
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  Speaker 3: to advance the standard of patient care, NASP supports a
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  Speaker 3: free market healthcare system in which all specialty pharmacies compete
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  Speaker 3: on the same fare and level playing field, because that
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  Speaker 3: is in the best interest of the patients we collectively serve.
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  Speaker 3: NASP is committed to working with all stakeholders and policymakers
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  Speaker 3: to ensure that all patients have access to the life
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  Speaker 3: saving medications they need and the high touch patient care
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  Speaker 3: and support services they deserve from the pharmacy of their choosing.
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  Speaker 4: Hello. My name Mishila Arkatt and I am the President
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  Speaker 4: and CEO of the National Association of Specialty Pharmacy. I
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  Speaker 4: am delighted to welcome my special guests, Linda Clark and
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  Speaker 4: Brad Gallagher from Barkley Damon LLP to this episode of
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  Speaker 4: the NASP Podcasts to discuss the rapidly evolving PBM regulatory
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  Speaker 4: landscape and what it means for specialty pharmacies, from enforcement
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  Speaker 4: trends to contracting strategies in future opportunities. Linda Clark and
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  Speaker 4: Brad Gallagher are co leaders of Barclay Damon's Healthcare Controversies
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  Speaker 4: and Pharmacy Teams London. Brad, thanks so much for joining
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  Speaker 4: me today. Can you briefly introduce yourselves and review your
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  Speaker 4: work with specialty pharmacies and PBM related manager.
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  Speaker 5: Sure, Sheila, I'll kick it off. It's Linda Clark here
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  Speaker 5: from Barkley Damon and it's been my pleasure to work
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  Speaker 5: with you and AMP for many years and the Legal
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  Speaker 5: Committee on all kinds of issues related to specialty pharmacy.
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  Speaker 5: And I'm the co leader of the Pharmacy Team along
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  Speaker 5: with Brad who's with us today as well, and the
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  Speaker 5: co leader of the group of the firms Healthcare Controversies Group,
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  Speaker 5: which is really healthcare litigation. So that means that you know,
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  Speaker 5: our group has some depth in not only pharmacy law
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  Speaker 5: and health care law, but we're also experienced litigators and
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  Speaker 5: we bring that to the table in reviewing the kinds
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  Speaker 5: of problems that specialty pharmacy face, and we find that
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  Speaker 5: an effect of combination that I'm almost unfortunately is really
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  Speaker 5: necessary these days. So that's how we come to these issues.
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  Speaker 5: A huge part of my practice is dedicated to pharmacy,
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  Speaker 5: and I've been doing that kind of work for almost
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  Speaker 5: fifteen years now.
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  Speaker 6: Yeah, so Pratt Aler from Barclay Damon. Linda gave me
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  Speaker 6: a nice in Chile, but gave me this introduction as well. Already,
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  Speaker 6: my practice has kind of evolved over the last decade
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  Speaker 6: and I've kind of more described myself as an industry
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  Speaker 6: attorney at this point, and we represent independent pharmacies, including
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  Speaker 6: specialty pharmacies across the country. While I'm on the Controversies
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  Speaker 6: team as well, co leaders with Linda represent pharmacies in
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  Speaker 6: a number of issues with regard to enrollments and terminations
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  Speaker 6: and investigations and audits both by PBMs and government agencies.
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  Speaker 6: I also have a transactional practice as well, where we
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  Speaker 6: represent pharmacies in buying and selling pharmacies across the country
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  Speaker 6: as well, and that you know, been doing that and
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  Speaker 6: perform farming due diligence and the controversies litigation sides gives
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  Speaker 6: gives me a unique insight into, you know, structuring those
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  Speaker 6: deals and doing due diligence in them, so it's been
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  Speaker 6: very helpful. And then you know, we also represent represent
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  Speaker 6: planned sponsors as well as other third party entities that pharmacies,
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  Speaker 6: including specialty pharmacies contract with, whether they're tech companies or
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  Speaker 6: other type of vendors that work with and doing some
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  Speaker 6: of their structuring and contracts and things like that. So overall,
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  Speaker 6: we kind of represent everybody bought PBMs, I would say, right, Linda.
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  Speaker 5: That's right. We've kept the lane clear over the years,
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  Speaker 5: seeing how this uh, this entire into vertical integration issue
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  Speaker 5: with PBMs has been developing, We've kept the lanes clear
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  Speaker 5: in terms of conflicts, UH, and so we're able to
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  Speaker 5: stay on the uh you know, mostly on the provider
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  Speaker 5: side of these issues when it comes to large scale insurers,
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  Speaker 5: for example, and that's been an important part of our
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  Speaker 5: practice because so many firms are conflicted.
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  Speaker 7: Sure, I can imagine.
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  Speaker 4: So we've seen several state level enforcement actions like you
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  Speaker 4: were just talking about against PBMs in recent months. Can
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  Speaker 4: you give us an overview of what's happening and what
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  Speaker 4: does this mean for specialty pharmacies?
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  Speaker 5: Sure, Brad, Do you want to dive in there and
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  Speaker 5: I'll talk a little bit about the federal tide.
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  Speaker 7: Yeah, yeah, I guess.
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  Speaker 6: Just to kick off, I mean, this is like hot
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  Speaker 6: off the press, because this just happened yesterday. So even
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  Speaker 6: before we get to the state level stuff, is that
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  Speaker 6: the FTC administrative action and complaint against the three largest
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  Speaker 6: PBMs has been obviously ongoing with express Scripts entering consent agreement.
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  Speaker 6: You know, about a month ago now yesterday we saw
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  Speaker 6: a motion to withdraw filed by the FTC and care
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  Speaker 6: Mark indicating, well, I guess in the papers indicating that
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  Speaker 6: care Mark is entered to consent agreement as well. Now
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  Speaker 6: with the FTC, those terms have not been released. It's
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  Speaker 6: subject to the final approval still by Commissioner Ferguson so
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  Speaker 6: we'll be expecting to see that consent agreement come in
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  Speaker 6: the coming weeks, and I expect we'll see optum you know,
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  Speaker 6: shortly thereafter as well, presumably among a very substantial So
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  Speaker 6: the express Scripts one, so just on a federal level,
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  Speaker 6: that's that's kind of hot off the press shield.
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  Speaker 4: Can you explain bread would that means a consent agreement?
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  Speaker 4: Because I mean, I guess I can kind of hypothesize
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  Speaker 4: what I think it is, but could you just explain it?
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  Speaker 6: Yeah, I mean it's the easiest way to explain is
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  Speaker 6: that it's it's like a settlement agreement, and you know
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  Speaker 6: between two parties, and this being the FTC and a PBM,
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  Speaker 6: and there's the major PBMs as well as their GPOs
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  Speaker 6: in a couple of their cases. So but in essence,
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  Speaker 6: for example, we can take the express Scripts one, because
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  Speaker 6: that one's public is that it throughout that agreement. Express
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  Speaker 6: Scripts is basically promised over the next few years to
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  Speaker 6: take certain actions within within its operations and a lot
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  Speaker 6: of the lot of the things that are contained in
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  Speaker 6: that agreement address you know, rebates and pricing, transparency, as
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  Speaker 6: well as standardizing some network terms, you know, with regard
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  Speaker 6: to its standard networks, and I think that's critical to
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  Speaker 6: you know, our audience here today.
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  Speaker 7: With specialty pharmacies is that.
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  Speaker 6: That is really focused more on retail pharmacy, but it
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  Speaker 6: still may have an impact on specialty pharmacy and specialty
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  Speaker 6: pharmacy contracting. Given some of the requirements and pricing transparency
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  Speaker 6: requirements that are there, I would expect to see, you know,
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  Speaker 6: some some changes across the board, and it certainly can
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  Speaker 6: be used. I know we can talk about this later
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  Speaker 6: today as well, just in contract negotiations specialty pharmacies.
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  Speaker 7: Have with their payers. Okay, thank you.
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  Speaker 6: So yeah, I guess just turning back to what's going on.
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  Speaker 7: In the States, right, which is where where we were.
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  Speaker 6: Kind of where we were trying to go. Yeah, So
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  Speaker 6: the in the States, we've seen a lot of action, right,
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  Speaker 6: There's been a lot of new bills being passed, Builds
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  Speaker 6: are on the book that are suddenly being enforced you know,
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  Speaker 6: or actively being enforced by various attorney generals and state
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  Speaker 6: departments of insurance or here in New York we have
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  Speaker 6: Department of Financial Services, which you know has PBM oversight,
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  Speaker 6: and so we've been we've seen a major uptick in
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  Speaker 6: not only having conversations with those departments, the Commissioners and
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  Speaker 6: insurance or the Attorney General's office in various states saying yes,
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  Speaker 6: we're interested in, you know, preserving fairness and price transparency
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  Speaker 6: and helping consumer commer's patients as well as independent pharmacies
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  Speaker 6: and protecting them. Going from that conversation to now what
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  Speaker 6: we're seeing is you know, action, right. So we're seeing
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  Speaker 6: states like Oklahoma and Tennessee, West Virginia, Louisiana just in
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  Speaker 6: the last few months with those states issuing fines for
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  Speaker 6: PBM behaviors that were not in line with state laws.
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  Speaker 6: You know, whether it's been on reimbursements, whether it's been
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  Speaker 6: on networking issues or price transparency issues, you know, those
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  Speaker 6: things have happened. And then you know, just with regard
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  Speaker 6: to some pending legislation, you know that has been kind
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  Speaker 6: of I guess anti PBM and more focused like in
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  Speaker 6: Louisiana and now Tennessee on some other states. Even New
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  Speaker 6: York has a bill that's pending where a PBM can't
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  Speaker 6: own pharmacies in that state, right, So that's you know,
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  Speaker 6: you're really looking at CBS, right, and CBS has been
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  Speaker 6: very in Louisiana.
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  Speaker 7: Did some things that were.
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  Speaker 6: Not kosher with with the state and was just buying
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  Speaker 6: forty five million dollars for you know, using its patient
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  Speaker 6: data at the pharmacies to basically lobby against legislation in Louisiana,
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  Speaker 6: and it result in the forty five million dollar fine.
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  Speaker 6: Just yesterday a getting hot off the press Louisiana. One
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  Speaker 6: of the representatives of Louisiana, because Louisiana has a similar bill,
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  Speaker 6: has asked the Attorney General's office in Tennessee to investigate
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  Speaker 6: CVS for the similar conduct in this state, you know,
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  Speaker 6: with regard to text messaging patients and lobbying, you know,
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  Speaker 6: basically lobbying against the bill. So, you know, these states
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  Speaker 6: I think you're seeing, you know, these states really start
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  Speaker 6: aggressively enforcing you know, they're the laws that are on
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  Speaker 6: the books or happen on the books for a while,
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  Speaker 6: are now getting traction and willing to come out and
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  Speaker 6: start doing things to ensure that competition is fair and
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  Speaker 6: consumers are getting prices, that pharmacies are being adequately and
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  Speaker 6: reimbursed in those states that have those have those laws
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  Speaker 6: in the books about reimmersement practices.
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  Speaker 4: Awesome, with all this activity, it appears that contracts are
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  Speaker 4: becoming even more critical, right the contract language I'm assuming too,
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  Speaker 4: given the reform environment and increased enforcement, how should specialty
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  Speaker 4: pharmacies approach negotiating PBM contracts today?
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  Speaker 5: And I'll jump in there just as a prelude to
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  Speaker 5: a bad discussion about some you know, some very practical tips.
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  Speaker 5: But you know, the problem that we're dealing with here
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  Speaker 5: is that this is almost a quilt of regulation and
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  Speaker 5: reform right, very very difficult to track. You know, we
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  Speaker 5: have things popping now every day in multiple states on
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  Speaker 5: the federal level, and you know, we talked a little
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  Speaker 5: bit about the state reforms, but it dovetails also with
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  Speaker 5: some of the federal reforms that we're seeing that will
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  Speaker 5: be rolled out with respect to all part D business
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  Speaker 5: over the next couple of years, and and those are
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  Speaker 5: very critical too, and that will be an overlay there
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  Speaker 5: are any willing pharmacy requirements that will apply to standard
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  Speaker 5: contract terms. There will be uh, you know, anti retaliation provisions.
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  Speaker 5: And you know, Sheila, what we've been waiting for a
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  Speaker 5: long time is is some development of the terms reasonable
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  Speaker 5: and relevant that have supposed to be they're supposed to
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  Speaker 5: be applied to Part D and we're finally going to
• 12:49
  Speaker 5: get some clarity on that, and clarity is critical to enforcement.
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  Speaker 5: You can't force something that's not clear. So when you're
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  Speaker 5: contracting and figuring out what your strategies going to be,
• 13:01
  Speaker 5: how this is all going to fit together, you have
• 13:05
  Speaker 5: to take a look at that angle as well as
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  Speaker 5: some new developments from the Department of Labor. So we
• 13:12
  Speaker 5: have the state level reforms that Brad talked about. We
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  Speaker 5: have these extensive federal reforms that will apply across the
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  Speaker 5: board to all party dollars and business. But now we
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  Speaker 5: also have the Department of Labor chiming in and putting
• 13:28
  Speaker 5: a lot of pressure on plans and sponsors to really
• 13:35
  Speaker 5: take the reins back of those PBM contracts, creating standards
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  Speaker 5: for fiduciary activity and oversight of what the PBMs are doing,
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  Speaker 5: and that is huge. There's going to be a very
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  Speaker 5: deep disclosure of where the money is going, including affiliates
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  Speaker 5: such as brokers, et cetera. It seems to be a
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  Speaker 5: very broad definition affiliate. These are pending rules right now,
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  Speaker 5: they haven't gone into effect yet, but you know, I
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  Speaker 5: think something like this will ultimately pass. And this is
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  Speaker 5: this is really important to spend a little bit of
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  Speaker 5: gap in in the afficacy at times. And so the
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  Speaker 5: process of sort of full plug and play with a
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  Speaker 5: PBM or a major sponsor and you know, take your
• 14:24
  Speaker 5: hands off the of the wheel uh and uh and
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  Speaker 5: not worry about too much scrutiny. Uh. Those days may
• 14:32
  Speaker 5: may well be over. And so you really need to
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  Speaker 5: understand that that entire you know, what might be a
• 14:38
  Speaker 5: three legged stool in order to figure out and calculate
• 14:42
  Speaker 5: and execute your business plan and your contracting plans going
• 14:47
  Speaker 5: forward as all of this uh takes shape, and how
• 14:51
  Speaker 5: you might be able to take advantage of it, how
• 14:53
  Speaker 5: it could negatively impact you so that you can uh
• 14:57
  Speaker 5: you know shift uh and mitigate any of the negative
• 15:01
  Speaker 5: impacts here and so uh, you know, we're doing a
• 15:05
  Speaker 5: lot of that with our clients right now, looking ahead,
• 15:07
  Speaker 5: understanding what all this means and how it's going to
• 15:11
  Speaker 5: shake out at a practical level. So, Brad, in response
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  Speaker 5: to Sheila's question, you know, you and I have been
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  Speaker 5: talking about almost immediately how we're seeing some of these
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  Speaker 5: developments uh and have an immediate effect on relationships with PBMs.
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  Speaker 5: Can you describe that a little bit.
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  Speaker 6: Yeah, so with the recent you know, and Linda, you
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  Speaker 6: mentioned the Department of Labor, you know, the Department of
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  Speaker 6: Labor issues that have recently come out at the FTC settlement.
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  Speaker 6: You know that we've been discussing a little bit here
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  Speaker 6: as well as some of the other reforms, so you know,
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  Speaker 6: and represent we represent employers as well on the employer side,
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  Speaker 6: who usually use brokers who done contracts with you know,
• 15:55
  Speaker 6: PBMs and health lands. You know, we've we've seen already
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  Speaker 6: a fact from these agreements and been able to use
• 16:04
  Speaker 6: these agreements in these rules and you know, kind of
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  Speaker 6: these recent developments use them in their current negotiations. So
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  Speaker 6: even though they haven't become effective yet, we've seen and
• 16:15
  Speaker 6: been able to negotiate you know, better terms for our
• 16:19
  Speaker 6: clients already on that side of things. And and that's
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  Speaker 6: just in you know, the last couple of weeks. So
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  Speaker 6: the brokers and the PBMs are aware of these things
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  Speaker 6: that are happening that are likely to be effective, you know,
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  Speaker 6: in the coming years. And some of these contracts are
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  Speaker 6: multi year contracts, so you know, if we know something
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  Speaker 6: is likely to be implemented, we can definitely use that
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  Speaker 6: as a negotiation standpoint now knowing that the contract is
• 16:46
  Speaker 6: going to be effective later and that those things you
• 16:48
  Speaker 6: know are obviously especially if they're coming from the federal government.
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  Speaker 6: You know, I'm kind of some of the messaging that's
• 16:54
  Speaker 6: coming out of there. You know, you can use that
• 16:56
  Speaker 6: now to negotiate your terms now. And we're doing that,
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  Speaker 6: and we've had effective, effective changes for our clients already
• 17:05
  Speaker 6: using that, using those strategies, you know, on the pharmacy side. Uh,
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  Speaker 6: you know, we'll see what effect they have. I mean,
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  Speaker 6: there's there's still some stuff out there. I suspect that,
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  Speaker 6: you know, you're going to see some changes in some
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  Speaker 6: of the provider manuals with some of the bigger PBMs
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  Speaker 6: coming out of this. There's certainly going to be more
• 17:25
  Speaker 6: more transparency, and that's that's really I think what we're
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  Speaker 6: seeing most out of a lot of a lot of
• 17:30
  Speaker 6: what's being done is more transparency, more everything being done,
• 17:34
  Speaker 6: more at point of sale, so that you have a
• 17:36
  Speaker 6: realistic idea of what you're paying and what you're paying
• 17:39
  Speaker 6: for and who's profiting along the way. And so I
• 17:43
  Speaker 6: think those are kind of like what you're seeing as themes.
• 17:49
  Speaker 6: But in I guess contracting and negotiating contracts and reviewering signs,
• 17:54
  Speaker 6: reps the extent that some of these contracts are you know,
• 17:56
  Speaker 6: taking and leave it, you know, as we've seen over
• 18:00
  Speaker 6: the years. But you still can look at those contracts
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  Speaker 6: and while they may not negotiate, you know, a PDM
• 18:06
  Speaker 6: may not sit there and negotiate every single term in
• 18:10
  Speaker 6: the agreement that you're signing with them, especially the major ones,
• 18:13
  Speaker 6: because all of that's in the provider manual.
• 18:15
  Speaker 7: They're not really going to do one offs.
• 18:17
  Speaker 6: But they will negotiate on certain certain terms and conditions,
• 18:21
  Speaker 6: including you know, the pricing and you know what you're getting,
• 18:25
  Speaker 6: you know, how you know, are you going to get
• 18:27
  Speaker 6: your acquisition costs plus a dispensing fee? Like those sorts
• 18:30
  Speaker 6: of things are you can get some movement on. And
• 18:33
  Speaker 6: I think that you can effectively use some of the
• 18:36
  Speaker 6: things that are coming out, you know, such as in
• 18:38
  Speaker 6: the appropriate you know, the PBM reforms coming out of
• 18:42
  Speaker 6: the Appropriations Act with the definition of what an essential
• 18:45
  Speaker 6: pharmacy is.
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  Speaker 7: I think you can use that.
• 18:48
  Speaker 6: You can use some of this Part D stuff that's
• 18:50
  Speaker 6: going to be coming out of HHS as a result
• 18:52
  Speaker 6: of this. You can use the FTC consent agreement. You
• 18:55
  Speaker 6: can certainly use your state laws to negotiate, you know,
• 19:00
  Speaker 6: how pricing is done into contract to the extent your
• 19:05
  Speaker 6: state has those types of laws. So I think just
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  Speaker 6: in reviewing it and negotiating those contracts is looking at
• 19:15
  Speaker 6: them closely to make sure that the reimbursement language aligns
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  Speaker 6: with the federal and state laws that are being passed,
• 19:22
  Speaker 6: making sure like that the definitions in the contract about
• 19:27
  Speaker 6: you know, dispensing fees, clawbacks, costs, like those definitions are
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  Speaker 6: clear and the methodology as to how they're being calculated
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  Speaker 6: is clear. I think that is certainly a place that
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  Speaker 6: you can have some discussions with you know, at least
• 19:44
  Speaker 6: some of the PBMs, some of the payers, as well
• 19:47
  Speaker 6: as your other third party contracts. Looking at you know,
• 19:50
  Speaker 6: transparency provisions and audit rights and data that's being provided
• 19:55
  Speaker 6: back to you, I think is something that you can
• 19:57
  Speaker 6: clearly look at, negotiate and that they have an obligation
• 20:01
  Speaker 6: to provide. And then you know, just tracking I guess
• 20:06
  Speaker 6: requirements and enforcement trends in your state, particularly because that's
• 20:11
  Speaker 6: where you may see more more enforcement actions and oversight,
• 20:16
  Speaker 6: and in using those things to your advantage in your
• 20:20
  Speaker 6: negotiations so I think that's all all helpful, and I
• 20:25
  Speaker 6: think you know not to I guess self promote attorneys here,
• 20:29
  Speaker 6: but like having attorneys look at your contracts before you
• 20:32
  Speaker 6: sign them, and at least going through them and explaining
• 20:35
  Speaker 6: what your rights are under that contract or what your
• 20:38
  Speaker 6: what your risks or exposures are from a legal perspective,
• 20:41
  Speaker 6: and what your rights may be if something goes wrong.
• 20:44
  Speaker 6: And understanding those things I think is critically important, not
• 20:49
  Speaker 6: only on the pharmacy side, but you know, on the
• 20:51
  Speaker 6: employer side too, which we deal with both sides. You know,
• 20:55
  Speaker 6: those sorts of things are very critical to understanding what
• 20:58
  Speaker 6: can happen if something goes wrong on either side of
• 21:01
  Speaker 6: the relationship, what your rights are to you know, perhaps
• 21:04
  Speaker 6: get out of that contract, or you know, file a
• 21:07
  Speaker 6: dispute notice or whatever, you know, whatever the mechanism is
• 21:13
  Speaker 6: for a resolution if there's a disapuity.
• 21:16
  Speaker 4: Sure so, even with strong contracts, though, audits and investigations
• 21:20
  Speaker 4: are on the rise. So how should specialty pharmacies be
• 21:23
  Speaker 4: adjusting their workflows and audit readiness given the increase frequency
• 21:28
  Speaker 4: and audits, investigations and network terminations.
• 21:31
  Speaker 5: Sure so, I can I can start with sort of
• 21:34
  Speaker 5: a reminder that while we're focused here on you know,
• 21:39
  Speaker 5: PDM contracts and those kinds of audits, UH, we should
• 21:45
  Speaker 5: also be on the lookout for much more activity on
• 21:50
  Speaker 5: enforcement from the state and federal level. Right there's a
• 21:53
  Speaker 5: tremendous amount of pressure right now on the state medicaid
• 21:58
  Speaker 5: programs for example. You can see, for example, the ripples
• 22:02
  Speaker 5: just from you know what is alleged to have happened
• 22:06
  Speaker 5: in Wisconsin and help in home care for example. Well,
• 22:10
  Speaker 5: I think we're going to see uh, that kind of
• 22:13
  Speaker 5: uh attention come to all states as there's this rising
• 22:20
  Speaker 5: focus on at least perceive fraud in high dollar areas
• 22:26
  Speaker 5: of Medicare and Medicaid, and so as we're looking at
• 22:31
  Speaker 5: contracting and the kinds of audits that that Brad's going
• 22:36
  Speaker 5: to be talking about, you know, within the plans, we
• 22:39
  Speaker 5: really need to be very cognizant of those dynamics as well.
• 22:44
  Speaker 5: The state state attorneys general, UH, they're going to be
• 22:48
  Speaker 5: very active in their medicaid fraud programs. Also, the the
• 22:52
  Speaker 5: omigs of the country, the inspectors general in each state
• 22:58
  Speaker 5: are going to be very vigilant and they'll have a
• 23:01
  Speaker 5: lot of pressure on them from the federal government to
• 23:04
  Speaker 5: be recouping. So that's one layer you don't want to
• 23:07
  Speaker 5: lose track of either. And that's an area sometimes where
• 23:10
  Speaker 5: we see that clients don't understand the difference and the
• 23:15
  Speaker 5: significance sometimes of those kinds of audits versus plan internal audits.
• 23:20
  Speaker 5: They're all important, it can all lead to difficult situations.
• 23:25
  Speaker 5: But if you get something from the OEG or from
• 23:28
  Speaker 5: the one of your Medicaid Inspectors General or the Medicaid
• 23:32
  Speaker 5: fraud unit of your AG's office in your state, that
• 23:36
  Speaker 5: is something that really needs immediate attention. And if we
• 23:40
  Speaker 5: find that when we get involved early, we can really
• 23:43
  Speaker 5: have a bigger impact. When it comes to us late
• 23:46
  Speaker 5: in the process, it's just much more difficult. Rad Do
• 23:48
  Speaker 5: you want to talk a little bit about the more
• 23:50
  Speaker 5: routine audit experiences that we're having within plans and how
• 23:55
  Speaker 5: those are going and what providers can do to manage them.
• 24:00
  Speaker 6: To just step back for a second and comment a
• 24:01
  Speaker 6: little bit, lind on what you were just saying too
• 24:03
  Speaker 6: about you know, state medicaid programs.
• 24:06
  Speaker 7: I can you know, say, like in New York especially like.
• 24:11
  Speaker 6: It's it's not even the audits and investigations, I mean
• 24:13
  Speaker 6: we're seeing issues with pharmacies in New York trying to
• 24:17
  Speaker 6: enroll in the New York Medicaid program and that process
• 24:20
  Speaker 6: becoming more and more difficult.
• 24:23
  Speaker 5: You know.
• 24:24
  Speaker 6: My assumption is, and I is that some of this
• 24:28
  Speaker 6: is due to the politics that's going on in New
• 24:32
  Speaker 6: York has obviously been targeted by the Trump administration as
• 24:37
  Speaker 6: as being one of the Medicaid overspenders right and not
• 24:40
  Speaker 6: having control over its program. And so I think, you know,
• 24:44
  Speaker 6: in pharmacy in New York, especially in the Medicaid program,
• 24:47
  Speaker 6: we've seen a tightening enrollments and more difficulty getting into
• 24:53
  Speaker 6: the New York Medicaid program.
• 24:55
  Speaker 7: As a as a provider, we've.
• 24:57
  Speaker 6: Seen you know, Medicaid denials based on and you know,
• 25:01
  Speaker 6: cost optimization right now, and we're you know, we're dealing
• 25:05
  Speaker 6: with that actively where New York Medicaid is citing pharmacies
• 25:10
  Speaker 6: that are trying to get into the program when they
• 25:12
  Speaker 6: look at their dispensing histories and records and what drugs
• 25:15
  Speaker 6: they're dispensing. You know, if they're dispensing drugs even though
• 25:19
  Speaker 6: they're not any Medicaid program, if they're dispensing drugs that
• 25:22
  Speaker 6: are on the cost optimization list, which is kind of
• 25:26
  Speaker 6: New York's equivalent to the CBS a parrant list. Right,
• 25:31
  Speaker 6: if you're dispensing too much of those drugs that New
• 25:34
  Speaker 6: York's Medicaid program believes that there's cheaper alternative, cost effective
• 25:38
  Speaker 6: alternatives for if you're doing too much of that, they're
• 25:41
  Speaker 6: not letting you in. And while you can appeal that
• 25:45
  Speaker 6: and there may be ways to effectively do that, you
• 25:49
  Speaker 6: know that is that is an issue and how your pharmacy.
• 25:52
  Speaker 6: And I think this goes to the PBMs as well,
• 25:54
  Speaker 6: because you know, optim has a rule now twenty five
• 25:57
  Speaker 6: percent rule care markets, the barent list, and we certainly
• 26:01
  Speaker 6: know that express scripts target certain high cost drugs that
• 26:05
  Speaker 6: they think, you know, they being the PBMs and Medicaid
• 26:09
  Speaker 6: believe generally have a limited efficacy or lower cost alternatives.
• 26:15
  Speaker 6: Those things are very well and focused now for cost
• 26:18
  Speaker 6: containment purposes.
• 26:19
  Speaker 7: And if there's not a real medical necessity for those drugs, you.
• 26:25
  Speaker 6: Know, if they're continuing to be used and that's not
• 26:29
  Speaker 6: a documented medical necessity, is for them requiring it. It
• 26:32
  Speaker 6: is it's drawing audits, it's drawing investigations, it's drawing network denials.
• 26:37
  Speaker 7: As we just talked about with Medicaid.
• 26:41
  Speaker 6: Certainly, it's it'd be looked at in enrollment considerations if
• 26:44
  Speaker 6: you're trying to get into.
• 26:45
  Speaker 7: A PBM network.
• 26:47
  Speaker 6: So those are all things just generally, as Linda was
• 26:50
  Speaker 6: pointing out, with just cost containment, generally, with audits and
• 26:56
  Speaker 6: investigations generally. Yeah, we've we've continued to see an uptick
• 27:02
  Speaker 6: in that there's continued pressure on pharmacies. And I'd say
• 27:07
  Speaker 6: the thresholds which you know pharmacies, I think have routinely
• 27:12
  Speaker 6: thought that there's this magic number that if I'm below.
• 27:14
  Speaker 7: That number, I won't be terminated.
• 27:18
  Speaker 6: And maybe there was some truth to that, like ten
• 27:22
  Speaker 6: years ago, that if you're below a certain number, if
• 27:25
  Speaker 6: you have findings like that, maybe you could stay in
• 27:28
  Speaker 6: the network. I think that conception misconception is big now
• 27:36
  Speaker 6: and we're seeing pharmacies being terminated for very very low
• 27:40
  Speaker 6: dollar amounts, you know, with what historically would have resulted
• 27:45
  Speaker 6: in you know, either not being contacted or you know,
• 27:49
  Speaker 6: at worst having a corrective action plan and you being
• 27:51
  Speaker 6: allowed to stay in network. We're saying terminations from those
• 27:55
  Speaker 6: things now, and the standard and getting those terminations is overturned.
• 28:00
  Speaker 6: It's very hard and going out and getting an injunction.
• 28:03
  Speaker 6: It's very hard, and so I think just overall taking
• 28:09
  Speaker 6: audits extremely seriously when you get them, and being organized
• 28:14
  Speaker 6: and your responses and you know, if you have an
• 28:18
  Speaker 6: issue at addressing that issue and fixing it like now
• 28:23
  Speaker 6: right and not waiting until you get a termination notice.
• 28:27
  Speaker 6: That's all part of like an effective strategy. And it's
• 28:29
  Speaker 6: part of an effective compliance plan quite honestly, Like you know,
• 28:34
  Speaker 6: and we can kind of talk about that too, but
• 28:37
  Speaker 6: you know, audits and being ready for audits and handling audits,
• 28:42
  Speaker 6: like you should really have a dedicated person on your
• 28:44
  Speaker 6: team like that that's their job and it's going to
• 28:47
  Speaker 6: kind of go through one person and that person knows
• 28:51
  Speaker 6: how to handle that and organize the documents and things
• 28:55
  Speaker 6: like that. But you know, there's there's a strong focus
• 28:58
  Speaker 6: obviously on prescription documentation, on delivery verification, you know, communications,
• 29:05
  Speaker 6: you know, depending on you know, what the issues are
• 29:08
  Speaker 6: and what the drugs are. You know, what are the
• 29:09
  Speaker 6: communications between the provider and the pharmacy, like especially when
• 29:14
  Speaker 6: you're getting into some of these drugs that clearly payers
• 29:18
  Speaker 6: don't like but are on formula. So like, I think
• 29:23
  Speaker 6: all of those things as far as audit readiness is
• 29:26
  Speaker 6: what you need to look at. But I think there's some,
• 29:28
  Speaker 6: you know, there's some things that you should be doing
• 29:32
  Speaker 6: in your workflow. I guess just generally so that when
• 29:35
  Speaker 6: you do have an audit that you can get through
• 29:38
  Speaker 6: it cleanly and probably sleep better and have a lot
• 29:41
  Speaker 6: less stress that if you're just doing beforehand, I think,
• 29:46
  Speaker 6: you know, kind of helps you. And you know, some
• 29:49
  Speaker 6: of that is making sure your staff is trained right,
• 29:52
  Speaker 6: that they know how to document a transfer prescription that
• 29:57
  Speaker 6: they're tracking in. You know, you're when you're ordering inventory
• 30:01
  Speaker 6: that you're you know, ordering from, you know, depending on
• 30:06
  Speaker 6: the PBM, making sure that they're n a BP accredited,
• 30:09
  Speaker 6: making sure that they're licensed in that state. If you're
• 30:13
  Speaker 6: buying you know, certain OTC or diabetics supplies that they're
• 30:16
  Speaker 6: authorized distributors and with certain PBMs can they have to
• 30:20
  Speaker 6: be licensed and accredited. So making sure that you're you know,
• 30:24
  Speaker 6: your policies and procedures, that you have been sure that
• 30:27
  Speaker 6: you're doing things they're not. It's not necessarily a legal issue,
• 30:30
  Speaker 6: it's a contractual issue. And making sure that your practice
• 30:35
  Speaker 6: is whether it's inventory, whether it's copayment collection, whether it's
• 30:38
  Speaker 6: you know a mailing and delivery issue. Making sure that
• 30:42
  Speaker 6: your policies and procedures address what's required in your PBM
• 30:47
  Speaker 6: contracts right as well as by law, will help you
• 30:54
  Speaker 6: be prepared for be prepared for an audit and and
• 31:00
  Speaker 6: you know that'll that'll get you through it cleaner with
• 31:03
  Speaker 6: less issues. And even if there is an issue, I know,
• 31:06
  Speaker 6: from a legal perspective, you know, when we're involved and
• 31:09
  Speaker 6: have to go to dispute meeting process and or a
• 31:14
  Speaker 6: termination hearing and things like that, all or you know,
• 31:16
  Speaker 6: on our arbitration and litigation, documentation is critical, right and
• 31:21
  Speaker 6: what you can prove contemporaneously, not after the fact, but
• 31:25
  Speaker 6: contemporaneously of what you did and the steps you took
• 31:29
  Speaker 6: is certainly helpful to establishing. Look, at the end of
• 31:32
  Speaker 6: the day, the pharmacy did the right thing. The patient
• 31:34
  Speaker 6: got the drug. It was a very you know, authentic,
• 31:37
  Speaker 6: verified prescription of a drug that was medically necessary, and
• 31:41
  Speaker 6: we took the steps and we did you know, we
• 31:44
  Speaker 6: completed the process. And maybe there's a technical, very technical violation,
• 31:49
  Speaker 6: missed something small that was not material, but giving us
• 31:52
  Speaker 6: the ability to make those legal arguments really starts with
• 31:56
  Speaker 6: did you were you doing all these things upfront in
• 31:58
  Speaker 6: your compliance program.
• 32:01
  Speaker 4: So, stepping back of bed, let's talk about the bigger picture.
• 32:04
  Speaker 4: So how are we going to measure whether all this
• 32:07
  Speaker 4: oversight is actually working? What do you both see as
• 32:11
  Speaker 4: the key indicators of whether PBM oversight is actually effective
• 32:16
  Speaker 4: over the next couple of years.
• 32:19
  Speaker 5: Sure, I'll jump in their bread just at the at
• 32:21
  Speaker 5: the macro level, you know, the the enforcement mechanisms are
• 32:27
  Speaker 5: are critical. I mean, you can have great rules on
• 32:30
  Speaker 5: the books in a given state, but if it's if
• 32:33
  Speaker 5: it's not enforced, then there's no private right of action
• 32:37
  Speaker 5: on the part of the pharmacies. Then that, you know,
• 32:39
  Speaker 5: that doesn't announce to much. And the the PBMs often
• 32:44
  Speaker 5: know which states are tough and which states don't have
• 32:49
  Speaker 5: strong enforcement, and they will certainly, you know, work those
• 32:53
  Speaker 5: dynamics when they can. And but then you have the
• 32:57
  Speaker 5: practical side, which is, uh know what Brad has been
• 33:01
  Speaker 5: talking about, uh taking advantage of these provisions even now
• 33:05
  Speaker 5: for renewing contracts.
• 33:07
  Speaker 6: UH.
• 33:08
  Speaker 5: For example, the new California Reform Bill has a provision
• 33:12
  Speaker 5: that says that even even during the rollout period, which
• 33:15
  Speaker 5: is over a couple of years, that expiring contracts, that
• 33:19
  Speaker 5: are being renewed have to comply with the new law,
• 33:23
  Speaker 5: and then all contracts have to apply. So knowing that
• 33:26
  Speaker 5: gives you the power to look at your contracts, look
• 33:30
  Speaker 5: at the requirements of UH of those state laws, not
• 33:33
  Speaker 5: to mention the federal UH changes that we've been talking
• 33:36
  Speaker 5: about with the STC, the kins had orders, the federal
• 33:41
  Speaker 5: laws and the UH and the state laws and the
• 33:46
  Speaker 5: you know, the whole package we've been talking about, and
• 33:48
  Speaker 5: figure out how you can harness the power of those
• 33:54
  Speaker 5: reforms yourself and your negotiating terms. So and you know, Brad,
• 33:58
  Speaker 5: you've you've been talking a little bit about that already.
• 34:01
  Speaker 5: I mean, that's where the rubber meets the road, right, Yeah, yeah.
• 34:06
  Speaker 6: I mean I think, like, how do you measure effectiveness?
• 34:08
  Speaker 7: Is? Is you need that oversight?
• 34:12
  Speaker 6: And you know, Linda, to your point, I think that,
• 34:15
  Speaker 6: you know, we need to see the attorney generals and
• 34:19
  Speaker 6: you know, departments of insurance enforcing their rules and in
• 34:24
  Speaker 6: order to do that, and I think in our conversations
• 34:27
  Speaker 6: with with those you know, various government agencies, it's always
• 34:30
  Speaker 6: been clear, as you know, they're willing to do that
• 34:33
  Speaker 6: and willing to step in, but they need data, right
• 34:36
  Speaker 6: A lot of times.
• 34:37
  Speaker 7: In order to do that, they need.
• 34:38
  Speaker 6: Examples, not just you know, saying that something's wrong, but
• 34:42
  Speaker 6: actually showing them that something's wrong. And I think we've
• 34:46
  Speaker 6: seen that now in Oklahoma. I mean Oklahoma. You know,
• 34:50
  Speaker 6: they're attorney general is now returning they did an auditive claims.
• 34:54
  Speaker 6: They're returning seventy five percent of the recovery that they
• 34:57
  Speaker 6: had back to pharmacies.
• 34:59
  Speaker 7: But how are they able to to do that?
• 35:00
  Speaker 6: They were able to do that by looking at actual
• 35:02
  Speaker 6: data and reimbursements and seeing that the pharmacies weren't being
• 35:06
  Speaker 6: reimbursed properly. So that's an effective PBM overset, right. But
• 35:12
  Speaker 6: you know, so making sure you're working with your states,
• 35:14
  Speaker 6: making sure you're seeing particular and reimbursement, rebates, pricing practices,
• 35:21
  Speaker 6: those things where you kind of see and have data
• 35:23
  Speaker 6: because you can see what you're paid, you can see
• 35:25
  Speaker 6: what your contract says, like. That's kind of an easier
• 35:28
  Speaker 6: thing to do because you have the data, so you
• 35:31
  Speaker 6: can monitor compliance and effectiveness. And you know, if your
• 35:34
  Speaker 6: state allows for a private right of action, which I
• 35:37
  Speaker 6: know Linda mentioned and I know we've we've talked about before,
• 35:41
  Speaker 6: you know, you have those opportunities, and you can bring
• 35:44
  Speaker 6: bring certain lawsuits or arbitrations if you need them or
• 35:47
  Speaker 6: just it's usually really effective even to go to a
• 35:50
  Speaker 6: dispute notice process through them when the law is on
• 35:54
  Speaker 6: your side, and if they continue to not comply with
• 35:59
  Speaker 6: the law. You know in your state may not have
• 36:01
  Speaker 6: a private rate of action but does have a law
• 36:04
  Speaker 6: on the books that allows it's attorney general of the
• 36:06
  Speaker 6: Department of Insurance to enforce those things. You know, going
• 36:11
  Speaker 6: to them and they will help you if you have
• 36:14
  Speaker 6: the data right and you if you have the facts
• 36:16
  Speaker 6: and the data, we will see. We have seen action
• 36:20
  Speaker 6: by states, particularly on reimbursement issues.
• 36:24
  Speaker 7: Where that's been effective.
• 36:29
  Speaker 4: So despite the challenges, this environment also creates opportunities during.
• 36:34
  Speaker 7: The reform environment.
• 36:35
  Speaker 4: What opportunities do you see for specialty pharmacies going forward, Brad,
• 36:41
  Speaker 4: you got to kick it off, sure, yeah, I think,
• 36:44
  Speaker 4: you know, I think.
• 36:45
  Speaker 6: The greatest opportunity is some of the greatest opportunities are
• 36:48
  Speaker 6: one is again you know, we I mean keep coming
• 36:52
  Speaker 6: back to transparency, but transparency in pricing and removing some
• 36:57
  Speaker 6: of the.
• 36:57
  Speaker 7: Games that are being played.
• 36:59
  Speaker 6: I'm sure there's going to new games being played, because
• 37:01
  Speaker 6: that's that seems to be how it has always worked.
• 37:03
  Speaker 6: But in the context of we're getting more towards a
• 37:08
  Speaker 6: transparent environment, we're getting rid of some of the rebates,
• 37:11
  Speaker 6: we're getting more pricing information. So I think again on
• 37:15
  Speaker 6: the specialty on the pharmacy side of things, I think
• 37:17
  Speaker 6: that's going to better help you negotiate your contracts and
• 37:21
  Speaker 6: your pricing. I think that's that's clearly an opportunity. I
• 37:25
  Speaker 6: think there's a lot of opportunity that there's there's obviously,
• 37:28
  Speaker 6: you know, even in the past few weeks there's a
• 37:30
  Speaker 6: lot of federal and state reform going on. An opportunity
• 37:36
  Speaker 6: in order to keep that momentum going, I think that
• 37:40
  Speaker 6: you know, pharmacies in particular need to continue to interact
• 37:43
  Speaker 6: with their their legislatures, you know, inviting your representatives to
• 37:48
  Speaker 6: your pharmacy, inviting you know, your your insurance commissioner, the
• 37:52
  Speaker 6: Attorney General's office to your pharmacy and letting them see
• 37:56
  Speaker 6: what you do right and how you help your patients
• 37:59
  Speaker 6: and what you're doing and you know, if you're having
• 38:02
  Speaker 6: an issue, how you're being treated unfairly and how that
• 38:05
  Speaker 6: affects your business, like let them meet your employees, let
• 38:09
  Speaker 6: them see your pharmacy, and all these great things that
• 38:11
  Speaker 6: you do for the community, like getting them to feel
• 38:14
  Speaker 6: that and have that interaction with you, will continue to
• 38:17
  Speaker 6: lead to more momentum, right and more fairness, more transparency.
• 38:22
  Speaker 7: You know, down the road.
• 38:24
  Speaker 6: And then I think the other two big areas of
• 38:27
  Speaker 6: opportunity under the current you know, where we're currently going,
• 38:31
  Speaker 6: and I think this is particularly true for specialty pharmacy
• 38:35
  Speaker 6: is I think there's a lot of opportunity for you know,
• 38:37
  Speaker 6: some innovative contract models and value based care, particularly for
• 38:42
  Speaker 6: specialty pharmacies, where they can integrate with other providers, the
• 38:46
  Speaker 6: community and things like that to really improve healthcare on
• 38:50
  Speaker 6: outcomes interactions with patients. I think we're seeing some states,
• 38:53
  Speaker 6: you know, expanding the scope of what a pharmacist can do,
• 38:56
  Speaker 6: and I think that's great in the sense of being
• 39:00
  Speaker 6: able to kind of get those better care models and
• 39:03
  Speaker 6: more touches with patients. You know, a lot of times
• 39:06
  Speaker 6: it's a lot easier to go into your pharmacy or
• 39:08
  Speaker 6: get an appointment at your pharmacy than your your physician.
• 39:11
  Speaker 7: And if you're doing something.
• 39:13
  Speaker 6: Like diabetic you know, you have diabetes and you need monitoring,
• 39:15
  Speaker 6: test strips and help help with doing some of those
• 39:18
  Speaker 6: things or nutrition programs with the JLP ones. I think
• 39:22
  Speaker 6: there's a lot of things that pharmacy can do. Pharmacists
• 39:25
  Speaker 6: can do if they're allowed, and you know, in states
• 39:29
  Speaker 6: that have these collaborative practice agreements and you know, expanded
• 39:33
  Speaker 6: scopes of pharmacy, I think there's gonna be opportunities there.
• 39:38
  Speaker 7: Uh.
• 39:38
  Speaker 6: And then you know, even coming back to the FTC
• 39:40
  Speaker 6: agreement with express Scripts, I mean, there is a provision
• 39:44
  Speaker 6: in the consent order that talks about you know, being
• 39:46
  Speaker 6: compensated or non dispensing services, So that would be clinical
• 39:51
  Speaker 6: services like immunizations and medication management and some things that
• 39:55
  Speaker 6: you know, specialty pharmacies are already doing that you know,
• 40:00
  Speaker 6: may provide opportunities for revenue streams, but even more importantly
• 40:05
  Speaker 6: improving patients.
• 40:06
  Speaker 7: In their lives. So I think those are some of
• 40:08
  Speaker 7: the emerging opportunities. I know that, I say, when then
• 40:11
  Speaker 7: I don't fee have anything else?
• 40:13
  Speaker 5: Yeah, I think that's absolutely right. I think everybody's interested too,
• 40:17
  Speaker 5: and how this is going to affect, you know, pricing, right,
• 40:20
  Speaker 5: I think that's a little bit of an open question
• 40:22
  Speaker 5: because let's remember we're we're taking the pb MS out
• 40:26
  Speaker 5: of the equation by eliminating spread pricing in all, you know,
• 40:31
  Speaker 5: you know, in the Ceteral Act, and I believe in
• 40:34
  Speaker 5: the consent orders, et cetera, and a lot of state
• 40:37
  Speaker 5: reforms that takes them right out of the ability to
• 40:41
  Speaker 5: exercise leverage with manufacturers, et cetera, to negotiate on price.
• 40:49
  Speaker 5: And if they're going to be left with a truly
• 40:51
  Speaker 5: administrative role and truly administrative cees for for that function,
• 40:58
  Speaker 5: then there's you know, some of us are talking thing
• 41:00
  Speaker 5: about what the incentive might be for the PBMs to
• 41:04
  Speaker 5: be driving the bus on on pricing and negotiations with
• 41:08
  Speaker 5: the manufacturers. So well, you know, there's some areas here
• 41:12
  Speaker 5: that are clearer than others, and that's one that I'm
• 41:16
  Speaker 5: anxious to see play out.
• 41:17
  Speaker 4: Interesting. Linda brad Any final thoughts.
• 41:21
  Speaker 6: Yeah, I think, you know, just overall, I think pharmacies,
• 41:25
  Speaker 6: you know, should should be given the environment and how
• 41:28
  Speaker 6: much has even happened already in twenty twenty six. I
• 41:31
  Speaker 6: think that you know, monitoring the legal and regulatory you know,
• 41:35
  Speaker 6: changes and developments, uh, and how you know, even though
• 41:38
  Speaker 6: some of these things aren't effective now today, you know,
• 41:42
  Speaker 6: how are they going to come into effect, and how
• 41:44
  Speaker 6: can you use those changes now, even if they're not effective,
• 41:48
  Speaker 6: to maybe better position your business and you know, whether
• 41:52
  Speaker 6: it's contract negotiations or providing additional services, you know, kind
• 41:57
  Speaker 6: of being forward looking, uh, based on on the momentum
• 42:01
  Speaker 6: and changes. So I think, you know, trying to stay
• 42:04
  Speaker 6: up to date on that, and I know you know
• 42:06
  Speaker 6: a lot of firms incluting ours. You know, Linda and
• 42:09
  Speaker 6: I are very active on LinkedIn a lot of firms,
• 42:12
  Speaker 6: including ours, put out legal alerts and things like that,
• 42:14
  Speaker 6: making sure you're actually reading those and understanding those, you know,
• 42:17
  Speaker 6: burching out if you have any questions, I know I'm
• 42:20
  Speaker 6: always and Wind is always more than happy to to jump.
• 42:23
  Speaker 7: On a call and talk with you.
• 42:24
  Speaker 6: I mean, we're very passionate about this and you know,
• 42:27
  Speaker 6: to me, it's it's fun to do it so and
• 42:30
  Speaker 6: it's I love helping helping the businesses, so like I
• 42:33
  Speaker 6: think that's one thing, but also just making sure from
• 42:37
  Speaker 6: a compliance and audit standpoint that you're ready that your
• 42:40
  Speaker 6: staff knows what they're doing performing you know self audits
• 42:45
  Speaker 6: is certainly going to help you later on, whether it's
• 42:48
  Speaker 6: a government auditor or a PBM auditor, investigation, like just
• 42:51
  Speaker 6: being ready for it, making sure your employees are ready
• 42:54
  Speaker 6: for it, whether it's an on site or a desktop,
• 42:56
  Speaker 6: you know, making sure that they know how to handle it,
• 43:00
  Speaker 6: you know, so that it's routine, it's part of the job, right,
• 43:02
  Speaker 6: and you don't get caught off guard. And then you know,
• 43:06
  Speaker 6: I guess in investing, you know, in knowing your data
• 43:10
  Speaker 6: right and your patients and the services that you can provide,
• 43:14
  Speaker 6: I think is going to help you with some of
• 43:16
  Speaker 6: these reimbursement issues and drug transparency and pricing, you know,
• 43:20
  Speaker 6: kind of really digging into that and knowing whether or
• 43:22
  Speaker 6: not what you're getting is what you're supposed to be getting,
• 43:27
  Speaker 6: you know. I think that's that's part of where we
• 43:29
  Speaker 6: see a lot of issues.
• 43:30
  Speaker 7: I mean, we do a lot of.
• 43:32
  Speaker 6: Reimbursement disputes for not only you know, pharmacies and specialty pharmacies,
• 43:37
  Speaker 6: but across the board with healthcare providers, where we see
• 43:40
  Speaker 6: that reimbursements just aren't right and you know, you don't
• 43:45
  Speaker 6: know that unless you're looking at your data and monitoring
• 43:47
  Speaker 6: it and you know, doing true ups and having somebody
• 43:50
  Speaker 6: kind of dedicated to doing that. So I think that's
• 43:52
  Speaker 6: part of the key I think key takeaways from what
• 43:55
  Speaker 6: we've I think been discussing today.
• 43:58
  Speaker 5: Yeah, I think so too. There's a lot of other
• 44:01
  Speaker 5: factors out there that could influence all of that, including
• 44:05
  Speaker 5: AI restrictions on AI uh, you know, data privacy. All
• 44:10
  Speaker 5: those other things have to be added to this already
• 44:14
  Speaker 5: super complicated UH equation.
• 44:17
  Speaker 6: Uh.
• 44:17
  Speaker 5: There may be room here for the emergence of other entities.
• 44:21
  Speaker 5: Right if the PBMs are rolled back and they can't
• 44:24
  Speaker 5: do it directly or indirectly, that should be interesting. There
• 44:29
  Speaker 5: may be more of an opportunity here for specialty pharmacies
• 44:32
  Speaker 5: to have communication and influence with with sponsors, right if
• 44:39
  Speaker 5: it if it pdms are more limited, and that could
• 44:42
  Speaker 5: affect your marketing strategy. So it's really exciting interesting times.
• 44:46
  Speaker 5: I see this all as a you know, a pretty
• 44:49
  Speaker 5: big positive here. So we're excited about working with everyone
• 44:54
  Speaker 5: to uh seize those opportunities and and you know, really
• 45:00
  Speaker 5: see what happens when you even the playing field.
• 45:05
  Speaker 4: Well, awesome, it's always nice to have good news, right
• 45:08
  Speaker 4: for a change. For so long it seems like they
• 45:09
  Speaker 4: are being beaten down, So it's awesome to have something
• 45:13
  Speaker 4: positive to talk about. Well, I want to thank you
• 45:16
  Speaker 4: both so much for chatting with me and sharing this
• 45:18
  Speaker 4: valuable information, as I'm sure our listeners kind of test.
• 45:22
  Speaker 4: We are so fortunate to be able to work closely
• 45:24
  Speaker 4: with you and to have you as part of the
• 45:27
  Speaker 4: NSP family. You're so willing to share, and like Brad said,
• 45:29
  Speaker 4: help and jump on a call. He usually answers me
• 45:31
  Speaker 4: in twenty two seconds when I send him a question,
• 45:34
  Speaker 4: and it's just so so appreciated. So I want to
• 45:37
  Speaker 4: thank both of you. Yeah. As a reminder, NSP corporate
• 45:44
  Speaker 4: members are invited to be my guest on one complimentary
• 45:46
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• 45:49
  Speaker 4: NASP membership benefits and events, please feel free to reach
• 45:53
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• 45:58
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• 46:01
  Speaker 4: A S P N E T O r G. Until
• 46:04
  Speaker 4: next time, have a great day.
• 46:21
  Speaker 3: M hmm