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Mintz is pleased to present its quarterly publication, PBM Policy and Legislative Update. This edition builds upon prior issues and summarizes activity from October through December 2023 that affects the PBM industry and will specifically highlight (i) federal legislative and enforcement updates, (ii) state legislative updates and litigation, (iii) other industry news, and (iv) Inflation Reduction Act (IRA) updates.

We hope you find the PBM Policy and Legislative Update to be a useful resource. If you have any recommendations on additional content that would be helpful to see in future editions, please do not hesitate to reach out to our team to let us know.     

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Theresa advises clients on all aspects of the pharmaceutical supply chain, including counseling industry stakeholders on a range of business, legal, transactional, and compliance matters. She provides clients with strategic counseling and creative business modeling that considers legal restrictions and regulatory risk in light of innovation and business goals.
Tara advises managed care organizations, pharmaceutical services providers such as PBMs, and integrated delivery systems, and companies that invest in them, on matters relating to compliance with federal health care program regulations, federal and state fraud, waste and abuse laws and plan benefits.
Rachel A. Alexander, a Member at Mintz, is a seasoned health law attorney and litigator who represents health plans, payors, and managed care entities in all aspects of managed care and payor regulatory, transactional, and litigation matters. She has a specialized focus on pharmacy benefit and drug pricing–related issues. She is regularly called on to help clients navigate pharmacy benefit manager (PBM) contract negotiation, administration, and procurement matters and provide guidance on compliance with federal law.
Bridgette advises health care providers, ACOs, health plans, PBMs, and laboratories on regulatory, fraud and abuse, and business planning matters, applying her experience in health system administration and ethics in health care to her health law practice.
Madison M. Castle is an Associate at Mintz who focuses her practice on health care regulatory, transactional, and enforcement defense matters. She represents clients across the health care sector, including hospitals, physician organizations, and health care systems.
David R. Gilboa is an Associate at Mintz whose practice encompasses transactional, compliance, privacy, and regulatory matters. He represents a broad spectrum of health care clients, including health care systems, hospitals, digital health companies, clinical laboratories, nursing homes, home care agencies, physician practices, and pharmacies.
Xavier represents clients in the health care and life sciences fields on health care regulatory and fraud and abuse matters. He also handles Medicare and Medicaid reimbursement issues in transactions and business arrangements.
Abdie Santiago is an Associate at Mintz who represents life sciences and health care companies in a broad spectrum of regulatory, fraud and abuse, and transactional matters. He assists clients with government drug pricing mandates, Medicare and Medicaid coverage requirements, Anti-Kickback Statute and False Claims Act investigations, and due diligence for health care practice transactions.

Hassan Shaikh


Hassan advises a broad range of clients across the health care industry—including health care systems, pharmacies, and private equity firms investing in health care companies—in complex industry transactions and compliance and regulatory matters.

Sophia Temis


Sophia Temis is an Associate at Mintz who focuses her practice on health care transactions and advising health care organizations on a broad spectrum of regulatory and governance matters. She represents physicians, hospitals, ambulatory surgery centers, and other for-profit and nonprofit health care clients.