On January 14, 2025, the Federal Trade Commission (FTC) Office of Policy Planning released a second Interim Staff Report titled Specialty Generic Drugs: A Growing Profit Center for Vertically Integrated Pharmacy Benefit Managers (the Second Report). The Second Report reflects additional work the FTC has completed since it released the July 2024 Interim Staff Report, and, most notably, includes the empirical analysis the agency’s first report on the topic was criticized for lacking. Mintz’s Health Law and Antitrust teams actively monitor federal and state regulatory and legislative developments in the PBM space, including those from the FTC. In this Special Edition of the PBM Policy and Legislative Update, the Mintz Health team partnered with our Antitrust colleagues to analyze the FTC’s Second Report.
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