The move will be "devastating" for the recipients who have permission to receive them, says Nancy Altman.

“This is going to be a fundamental shift in the program, because we’re going to move away from that upfront discount program to a post-purchase rebate,” said Dr. Urshlila Shah, former chief pharmacy officer at St. Joseph’s Health in Paterson.

“We have seen a surge in federal agency enforcement, new rulemaking and litigation, as well as ongoing state developments that both challenge and reinforce these federal efforts,” Laura Hancock, ERISA compliance and state law attorney for Lockton, wrote in a new report.

About half of exchange users are self-employed or associated with small businesses.