OptumRx, Caremark, Express Scripts, Humana, Prime — and every major PBM.
PBM audits can lead to devastating recoupments, network termination, and criminal prosecution. Our attorneys - former federal prosecutors and senior PBM executives - know exactly how to protect your business and your livelihood.
Speak directly with a former prosecutor
Dept. of Justice
FBI
HHS-OIG
IRS
NAMFCU
DEA
McKesson
OptumRx
Former federal prosecutor and senior executive at United Health/OptumRx. Anthony has personally overseen more than 1,500 pharmacy audits and brings rare cross-training in both government enforcement and PBM operations.
A seasoned healthcare defense attorney with deep expertise in PBM audit defense, regulatory compliance, and government investigations. Diana represents pharmacies nationwide in complex audit disputes and enforcement matters.
Without experienced counsel, pharmacies face consequences that can threaten their entire livelihood. A strategic response from day one is critical.
PBMs can demand repayment of hundreds of thousands, even millions, in reimbursements, often based on flawed audit methodologies and extrapolated findings that inflate alleged overpayments. Demand letters routinely cite disputed MAC pricing benchmarks, contested signature logs, and aggressive readings of the provider manual.
Losing your PBM network participation means losing the ability to serve the majority of your patients. For most pharmacies, a network termination is effectively a death sentence for the business.
PBM audits can trigger referrals to federal and state prosecutors, FBI, HHS-OIG, and DEA. What begins as a billing review can escalate into a criminal healthcare fraud investigation.
Every day without legal counsel is a day the PBM builds its case.
Protect Your Pharmacy Now →From the moment you receive an audit notice through appeals and final resolution, our team provides strategic legal counsel at every stage.
Free initial strategy session to assess risk exposure and develop an action plan to protect your pharmacy from the moment you receive notice.
We construct a comprehensive factual narrative, challenge every questionable finding, and identify weaknesses in the PBM's audit methodology.
Tailored legal responses rooted in federal and state pharmacy law, contractual provisions, and regulatory frameworks that challenge unfair findings.
Deep knowledge of PBM internal processes allows us to drive the full audit appeal sequence, negotiate reduced recoupments, reverse network terminations, and fight for the best outcome.
We design internal audit protocols, improve documentation practices, and provide ongoing compliance guidance to reduce future audit risk.
If your audit escalates to a government investigation, our former federal prosecutors provide experienced criminal defense representation.
Our attorneys include former federal prosecutors, government regulators, and senior PBM executives who understand the system from the inside out.
A former prosecutor, a former DEA Diversion Program Manager, and senior healthcare-industry executives who know exactly how enforcement agencies build their cases - and how to dismantle them.
Our founding partner served as a senior executive at United Health/OptumRx. We understand PBM audit tactics, internal processes, and settlement leverage firsthand.
Over 1,500 pharmacy audits overseen, 2,500+ clients represented, and documented wins including dismissed federal charges and reversed network terminations.
Allegation: $6.5M inventory shortfall in compound cream APIs
Agencies: U.S. Attorney's Office, FBI, HHS-OIG
Federal prosecutors declined criminal charges. Settlement at $2.5M - just 40% of claimed loss.
Allegation: 25,000 unit Zegerid discrepancy
At stake: Criminal prosecution, network exclusion
State dropped all charges before trial. No admission, no exclusion, no sanctions.
Allegation: $600,000 inventory shortfall
At stake: Criminal charges against owner personally
State declined criminal charges against the owner. Personal liability eliminated entirely.
Every day without legal representation is a day the PBM builds its case against you.
Free, confidential - we respond within hours