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Theresa C. Carnegie

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[email protected]

+1.202.661.8710

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"Theresa has exceptional knowledge and expertise. She is creative and a highly effective negotiator."

— Health Care Client, Chambers USA 2025

Theresa is a nationally recognized health care and pharmaceutical supply chain attorney who advises clients on PBM strategy, drug pricing, and the regulatory and transactional issues shaping the pharmaceutical industry. With more than 25 years of experience, she combines sophisticated legal judgment with deep industry insight to help clients navigate complex commercial, regulatory, and policy environments.

Theresa has extensive experience structuring, drafting, and negotiating transactions across the pharmaceutical supply chain, including PBM service agreements, retail, mail, and specialty pharmacy arrangements, pharmaceutical purchase and distribution agreements, GPO arrangements, and rebate and value-based contracting models. She regularly advises clients on reimbursement structures, drug pricing strategy, and compliance with federal and state fraud and abuse laws.

Her practice spans health care transactions and investment matters, where she represents clients in mergers, private equity and venture capital investments, and strategic collaborations. Theresa supports regulatory diligence, licensing, change-of-ownership filings, and risk assessment across complex health care and pharmaceutical supply chain deals.

Theresa counsels PBMs, health plans, pharmacies, and distribution stakeholders on operational, regulatory, and compliance matters across commercial, Medicare Advantage, Part D, and multistate health care markets. She helps clients evaluate structural design considerations, policy developments, and business opportunities associated with innovation in drug delivery, reimbursement, and emerging service models.

Recognized as an industry thought leader, Theresa frequently communicates timely updates on regulatory, policy, and market developments affecting clients in the pharmaceutical supply chain. She is a regular author and speaker on health care regulatory and PBM-related issues.

Theresa is a member of the firm's Policy Committee.

Experience

  • Represented LucyRx, a Summit Partners portfolio company and next-generation pharmacy benefit manager, in connection with multiple strategic growth initiatives, including its strategic combination with Abarca Health, acquisitions of CerpassRx, Integrated Prescription Management (IPM), and HealthSmart’s PBM business, and a strategic PBM affiliation with CitizensRx.
  • Represented Cigna as health regulatory counsel in its acquisition of Express Scripts.
  • Represented Catamaran (f/k/a CatalystRx) in the structuring and negotiation of its PBM services arrangement with CIGNA.
  • Represented national worker’s compensation PBM in connection with multiple workers' compensation PBM acquisitions.
  • Represented a national specialty pharmacy provider in connection with an internal compliance audit and investigation and response to government investigation.
  • Advised national pharmacy chain in multiple specialty pharmacy and long-term care pharmacy acquisitions.
  • Represented SingleCare, a discount medical and pharmacy card operator (DMPO), in its contracting with pharmacies, providers, and other vendors.
  • Served as regulatory counsel to a consortium of investors led by TPG Capital and Welsh, Carson, Anderson & Stowe in their $4.1 billion acquisition of Kindred Healthcare, Inc. (NYSE: KND). The transaction was recognized by The Deal as the 2018 Private Equity Deal of the Year.
  • Advised a global health care company on a variety of issues in connection with its acquisition of several health plans and provider groups, including health care regulatory due diligence, health care regulatory advice regarding transaction structure and strategy, and preparation of regulatory notices and other filings.
  • Advised national pharmacy chain in connection with government agency arrangement to provide accessible COVID-19 testing.
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viewpoints

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Aging, Reimagined: Precision Medicine Meets Policy

October 26, 2026 | Blog | By Traci L. Vitek, Theresa Carnegie

Explore how Medicare, AI, GLP-1s, dementia policy, and precision medicine are reshaping aging, care delivery, and healthcare investment.

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Mental Health Parity Under the Trump Administration: Where DOL Is Headed and What Congress Is Doing About It

October 14, 2026 | Blog | By Traci L. Vitek, Rachel A. Alexander, Theresa Carnegie

Analysis of Trump-era mental health parity enforcement, DOL's narrowed MHPAEA focus, pending litigation, and bipartisan congressional action.

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Departments Finalize Transparency in Coverage Rules: What Health Plans and Issuers Need to Know

October 13, 2026 | Blog | By Rachel A. Alexander, Theresa Carnegie, Traci L. Vitek, Grace Callander, Margaret Collopy

On October 5, 2026, the Departments of Health and Human Services (HHS), Labor, and the Treasury (collectively, the Departments) announced changes to the Transparency in Coverage (TIC) final rules, overhauling the 2020 regulatory framework for group health plans and health insurance issuers.  The changes aim to standardize the TIC machine-readable files (MRFs) for greater accuracy and accessibility.  The rules take effect December 7, 2026, with requirements phased in through July 2028.

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340B Rebate Pilot — The Clock Starts Now

Ten Plans, 18 Drugs, One Deadline

October 7, 2026 | Blog | By Traci L. Vitek, Emmett R. Jamieson, Theresa Carnegie

HRSA’s 340B rebate pilot starts Jan. 1, 2027. Learn the approved plans, litigation risks, and readiness steps for health systems.

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The 340B Squeeze: Academic Medical Centers and Large Health Systems Have the Most to Lose

September 28, 2026 | Blog | By Traci L. Vitek, Theresa Carnegie, Brent Henry

Most of the 340B debate centers on rural hospitals and community health centers. The biggest dollars, however, sit with academic medical centers (AMCs) and large health systems, and that is where Washington’s next three moves converge.

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HRSA revives its 340B rebate pilot as the SUSTAIN 340B Act challenges the model, forcing health systems to prepare for three reform paths.
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Women's Health at a Turning Point: What Federal Policy Changes Mean for the FemTech Industry

August 4, 2026 | Blog | By Traci L. Vitek, Theresa Carnegie, Karen Lovitch , Daniel Cody

For decades women's health has too often been treated as a narrow policy category, despite affecting roughly half the population. That is changing. There is now an emerging category of medicine built around regulated software, biomarker-based decision-making, and new regulatory and reimbursement pathways. FemTech now spans menstrual health, fertility, pregnancy and postpartum care, pelvic and sexual health, menopause, contraception, and conditions that affect women differently or disproportionately. 

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FTC Reaches Second Insulin Pricing Settlement: Comparing the Caremark and ESI Orders

July 17, 2026 | Blog | By Rachel A. Alexander, Theresa Carnegie, Hassan Shaikh, Grace Callander

On July 14, 2026, the Federal Trade Commission (FTC) announced its settlement with Caremark Rx, LLC and Zinc Health Services, LLC (Caremark) to resolve claims from the FTC’s 2024 Complaint alleging Caremark, OptumRx, Inc. (OptumRx), and Express Scripts, Inc (ESI) used anticompetitive rebate schemes to artificially inflate insulin prices.

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State Regulation of PBMs Subject to Robust Legal Challenges

July 8, 2026 | Blog | By Rachel A. Alexander, Theresa Carnegie, Jacob Hupart, Emily K. Musgrave, Morgan E. Hill

There have been two major recent developments in the ongoing national struggle over the state regulation of pharmacy benefit managers (PBMs). On June 29, 2026, the Eighth Circuit Court of Appeals ruled in Flowers v. Caremark PCS Health, No. 25-3068, that a key element of an Arkansas statute designed to regulate PBMs is preempted by federal law. Three lawsuits have been filed in the United States District Court for the Middle District of Tennessee challenging Tennessee’s recently enacted Fair RX Act, a statute aimed squarely at curbing PBM ownership and control of pharmacies. The Fair RX Act, passed in May, prohibits PBMs from owning pharmacies

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On June 25, 2026, Senate HELP Committee Chairman Bill Cassidy (R-LA) released a sweeping legislative discussion draft titled the 340B Drug Pricing Integrity and Affordability for Patients Act. This proposal represents the most significant proposed overhaul of the 340B Drug Pricing Program in more than 15 years—and if enacted, it would have profound implications for every hospital, health system, and safety-net provider currently participating in the program.

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News & Press

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Member Theresa Carnegie was quoted by Law360 in an article about the unknowns of Robert F. Kennedy Jr.’s health policies following his nomination by President-elect Trump to head the Department of Health and Human Services. 

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BOSTON –Mintz announced today that 39 of its practices and 81 of its attorneys earned recognition in the 2023 edition of Chambers USA, a guide to the country’s leading law firms.

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podcasts

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Host Of Counsel Bridgette Keller invites the Mintz Health Law team to reflect on what they’re grateful for as they prepare for the year ahead. Hear from a dynamic group of Members, Of Counsel, and Associates as they share their perspectives on what’s coming up over the horizon.

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Mintz Health Law: What We Are Grateful For

January 11, 2023 | Podcast | By Bridgette Keller

Bridgette Keller speaks with the Mintz Health Law team about what they are grateful for as they look back on a year of client service, mentorship, and working together as a team.

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Events & Speaking

Speaker
Apr
28
2026

AHLA Health Plan and Managed Care Law Institute

Drug Pricing in 2026: Trump Rx and Other Developments

Virtual

Speaker
Jun
29
2020
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Speaker
Moderator
Chair
Speaker
Nov
13
2017

Pharmacy Benefits and Pharmaceuticals: State of the Industry Update

AHLA

Marriott Chicago Downtown, Magnificent Mile, Chicago, IL

Moderator
Speaker
Speaker
Nov
12
2015

4th Annual Pharmacy Benefit Oversight & Compliance Conference

CBI

16770 North Perimeter Drive Scottsdale, AZ

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Recognition & Awards

  • BTI Consulting Group: Client Service All-Star (2020)

  • Chambers USA: District of Columbia (Up and Coming) – Healthcare (2014, 2015); District of Columbia – Healthcare (2023 - 2026)

  • Legal 500 United States: Recognized for Healthcare: Service Providers (2024)

  • Nightingale’s Healthcare News: Outstanding Young Healthcare Lawyers (2005)

  • Phi Beta Kappa

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