PBM Audits & Defense
Network audits, recoupments, terminations, and appeals against Caremark, OptumRx, Express Scripts, and other PBMs.

Buying a Pharmacy With an Open PBM Audit
An open PBM audit does not have to sink a pharmacy sale, but it changes how the deal should be structured, priced, and documented.

PBM Onsite Audit: How to Prepare for the Auditor Visit
How pharmacies should stage documents, designate a point of contact, and control scope before and during a PBM onsite audit visit.

PBM Invoice Audit: Proving Your Purchases
Wholesaler invoice reconciliation, shortage findings, and extrapolation: how PBM audits weigh a pharmacy's proof of purchase, and…

Florida Attorney General Launches Investigation Into CVS Caremark: What It Means for Independent Pharmacies
Florida’s Attorney General issued a Civil Investigative Demand to CVS Health and Caremark, underscoring intensifying scrutiny of P…

Health Law Alliance Successfully Reverses PBM Network Termination for a California Independent Pharmacy
Health Law Alliance obtained a complete reversal of a PBM network termination for a California independent pharmacy, preserving it…

PBM Audit Defense Lawyer Insights: Avoiding the Top PBM Audit Traps That Lead to Network Termination
Six common PBM audit-response mistakes that can escalate into recoupment, network termination, or a broader government investigati…

When to Involve Counsel in a PBM Audit
The audit notice does not announce its own stakes. Which PBM audit decisions actually turn on counsel, and which ones turn on the…

What a PBM Audit Costs an Independent Pharmacy
Recoupment is only one line item. Staff hours, a mid-audit cash-flow offset, and a missed appeal deadline each add their own cost…

Usual and Customary Price Findings in PBM Audits
PBM auditors treat a pharmacy's usual and customary price as a real, enforceable number. Here is how the finding is calculated, tr…
