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ERISA Preemption Reaffirmed: Tenth Circuit Limits State PBM Regulation

On August 15, 2023, the Tenth Circuit issued its much-anticipated decision in PCMA v. Mulready, rejecting Oklahoma’s position that its pharmacy network requirements were not preempted by ERISA. Mulready has been closely...more

Data Marketing Poses Significant Implications for Health Plans Regulation

Data Marketing Partnership, LLP (“Data Marketing”) offers a health insurance plan to individuals that download an app that tracks phone usage. The company treats such persons as “partners” in their business. The result is...more

Surprise! Tri-Agencies Meet Deadline with First Set of Surprise Billing Rules, With More to Come

On July 1, 2021, the Office of Personnel Management, Department of the Treasury, Department of Health and Human Services (“HHS”), and Department of Labor (“DOL”) (collectively, the “Departments”), released the interim final...more

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