Lexology January 23, 2025
Mintz

The Federal Trade Commission (FTC) Office of Policy Planning released a second “Interim Staff Report” as part of its inquiry into PBMs on January 14, 2025, titled Specialty Generic Drugs: A Growing Profit Center for Vertically Integrated Pharmacy Benefit Managers (the “Second Report”)–quieting rumors that the “final” PBM report would not be released prior to the end of Chair Lina Khan’s tenure at the helm of the agency. The Second Report reflects additional work the FTC completed since it released the July 2024 Interim Staff Report (the “First Report”), which we covered here. Most notably, the Second Report includes the empirical analysis the First Report was criticized for lacking.

The Second Report focuses on reimbursement of specialty drugs and is...

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