PBM Legislation and the PBM-affiliated GPOs | AMCP 2024

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Ross Margulies, J.D., M.P.H., a partner at the Foley Hoag law firm, discusses whether proposed transparency rules in the pharmacy benefit manager (PBM) legislation that Congress is considering might apply to the PBM-affiliated group purchasing organizations.

The pharmacy benefit manager (PBM) bills that Congress is currently considering include a variety of new transparency and reporting rules. Whether those rules would apply to the group purchasing organizations (GPOs) affiliated with the major PBMs is an open question

Ross Margulies, J.D., M.P.H., a partner at Foley Hoag, a law firm headquartered in Boston, discussed PBMs and the PBM legislation today at the 2024 annual meeting of the Academy of Managed Care Pharmacy (AMCP).

In an interview with Managed Healthcare Executive prior to the meeting, Margulies said that most of the bills under consideration have provisions aimed at "affiliated entities" that might include the group purchasing organizations (GPOs).

Margulies also noted that the term PBM is not currently defined in most statutes and that the some of the definitional language in the current bills “could reach affiliated, PBM-owned GPOs.”

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