Broker Regulation

Although Horizon says it now has 20 drugs under development, in its 15 years of existence it has yet to license a product it invented.

The article argues that, given the federal government's endorsement of RBP and its proven efficacy in reducing employer costs and expanding participant options, it is now virtually impossible for a plan fiduciary to lawfully discharge their duties in accordance with ERISA without at least considering the implementation of RBP.

Employers, brokers and TPAs need to calibrate their expectations for how Humira biosimilars will impact the cost of prescription drugs for groups and members.

In terms of the illegal act exclusions, it is vital that plan administrators use their discretionary authority to regularly assess the applicability of these exclusions.

In finalizing its payment policies, CMS has bumped up payments to Medicare Advantage plans to 3.3% in 2024, slightly above the 1% raise that it proposed.

Health plans should be mindful of how they interpret certain provisions in light of the lack of guidance.