New York Proposes Regulations Expanding State’s Ability to Regulate PBMs

The New York State Department of Financial Services recently announced the publication of proposed regulations that would increase the state’s oversight of pharmacy benefit managers (PBMs). If enacted, the proposed regulations would create significant requirements for PBMs and would require prompt compliance by January 1, 2024. Comments on the proposed regulations are due October 16, 2023.

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Gregory Mitchell
Greg Mitchell works with healthcare payors and providers to meet the full spectrum of their managed care and reimbursement arrangement needs. He helps managed care organizations, third-party administrators, independent practice associations, risk-bearing entities, management services organizations, hospitals and health systems, digital healthcare providers, and other organizations both large and small negotiate and draft a range of managed care and value-based agreements. Greg has experience with a variety of arrangements and models, including fee-for-service, bundled payment, shared savings and shared loss models, gainsharing and capitation arrangements. Read Greg Mitchell's full bio.


Grayson I. Dimick
Grayson I. Dimick focuses her practice on regulatory and transactional matters affecting a wide range of clients across the health care industry. Grayson advises clients on a variety of issues, including the regulatory and compliance aspects of digital health. She also conducts due diligence on health care transactions. Read Grayson Dimick's full bio.


Benjamin Glass
Benjamin counsels private equity firms, portfolio companies, physician practices, and management services organizations on healthcare regulatory frameworks governing facility licensure and accreditation, clinical laboratory registration, corporate practice of healthcare professions, and changes of ownership and control over healthcare entities navigating physician practice management transactions. Read Benjamin Glass's full bio.

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