Lexology January 22, 2025
McCarter & English LLP

At a public meeting held on January 15, 2025, the Federal Trade Commission (FTC) summarized the Second Interim Staff Report (Second Report) stemming from its investigation into pharmacy benefit managers (PBMs) and their impacts on competition in the health care marketplace. The Second Report, released following a unanimous vote of the commissioners, expands on a prior interim report and focuses specifically on findings made related to the dispensing of specialty generic drugs. Below, we summarize the major findings from the Second Report, discuss potential next steps by the FTC (and others), and offer some key takeaways.

In the complex world of health insurance, PBMs are intermediaries tasked with processing and administering prescription benefits offered through health plans. PBMs are pivotal...

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