Dae Y. Lee @LifeScienceLaw

Pharmacy owners are facing a rapidly changing legal and reimbursement environment. In our May 2026 Pharmacy Insights Newsletter, the Pharmacy Practice Group covers several developments that pharmacy stakeholders should be watching closely, including: • Pharmacy change of ownership transactions and why CHOW must be handled correctly • New Jersey’s Patient and Provider Protection Act targeting PBMs • Tennessee’s FAIR Rx Act and the continuing escalation of state PBM reform • DEA investigations and the evolving responsibilities of pharmacists • No Surprises Act and IDR risks for providers • Recent media coverage on PBM reform and peptide regulation Pharmacies that wait until there is an audit finding, termination notice, Board inquiry, DEA visit, or failed CHOW transition are often already behind. Read the May 2026 Pharmacy Insights Newsletter here: lnkd.in/eG9s_qCQ #PharmacyLaw #PBM #IndependentPharmacy #PharmacyCompliance #DEA #HealthcareLaw #PBMReform #PharmacyOwners

TN's FAIR Rx Act may become one of the most closely watched state PBM reform laws in the country. In our latest article, Emily Carey and I explain why this law matters not only for pharmacies but also for plan sponsors and other pharmacy-industry stakeholders. Read the article here: bipc.com/tennessees-fai… #PBMs #Pharmacies #PBMReform #PharmacyLaw #PharmacyLawyer

The April 2026 Pharmacy Insights Newsletter is out (click the link below) lnkd.in/eqQBus2J This issue covers several developments that pharmacy stakeholders and plan sponsors should be watching closely: • FDA’s latest peptide action and what it really means for compounding pharmacies • Why “PBM transparency” is not always what plan sponsors think it is • The continued regulatory scrutiny around peptides and Category 2 substances • Ohio’s new PBM reform law and what it may signal for other states • Recent PBM settlement developments and their impact on health plans • Upcoming pharmacy industry events where Lucas Morgan and I will be speaking or attending For compounding pharmacies, the peptide issue remains one of the most important regulatory developments to monitor. Opportunity still exists, but the compliance line is getting sharper. For plan sponsors, the OPM OIG audit of CVS Caremark is another reminder that “pass-through” and “transparent” PBM arrangements should not be accepted at face value. Contracts, claims data, audit rights, rebate treatment, administrative fees, and affiliate arrangements all need to be tested carefully. And for pharmacies, PBM reform continues to move at the state level, with Ohio’s new law adding to the growing patchwork of PBM licensing, transparency, and operational requirements. As always, the goal is simple: help pharmacies, plan sponsors, and industry stakeholders understand where the legal and business risks are heading next. #PBM #PharmacyLaw #CompoundingPharmacy #PlanSponsors #HealthcareLaw #Peptides #PBMReform

Lucas Morgan and I discuss the recent developments in the peptide world. Check out our article here. bipc.com/what-fda%E2%80… #Peptides #FDA #PharmacyLaw #PharmacyLawyer

Glad to contribute to Noah Tong's recent article, "PBM oversight gaps widen as violations persist," published in Modern Healthcare. #PBMs #PBMReform #FiduciaryDuty #Pharmacies #PharmacyLaw #PharmacyLawyer modernhealthcare.com/politics-regul…

CVS accused of overbilling feds $600M in scheme. Very troubling findings. The same or more egregious findings can be expected in the commercial sector aka self-funded plans. Take a look at my article. #PBMs #PBMReform #OIGAudit #PharmacyLaw #PharmacyLawyer bipc.com/the-illusion-o…

Glad to share that I will be speaking at Benefits Symposium hosted by Kelly Benefits Strategies on fiduciary duty and PBMs. #PBMs #PBMReform #FiduciaryDuty #PharmacyLaw

Proud to be quoted in PLANADVISER’s latest piece: Increased Scrutiny of Health Plans Leaves Advisers Racing to Keep Up The reality is simple, i.e., PBMs are no longer operating in the shadows. With new transparency requirements coming out of Congress and the Department of Labor, plan sponsors are now firmly in the crosshairs. What I emphasized in the article and what every employer needs to understand is this: If you are not actively reviewing your PBM contract, auditing performance, and tightening the gaps, you are exposing your plan to real fiduciary risk and potential litigation. Plan sponsors need to act accordingly. Happy to connect with any employers, advisers, or consultants trying to get ahead of this shift. planadviser.com/exclusives/inc… Special thanks to James Van Bramer! #PBMs #ERISA #HealthPlans #PlanSponsors #Compliance #PBMReform

Proud to share our latest newsletter focused on where the pharmacy and PBM landscape is heading next. If you’re a pharmacy owner or a plan sponsor, these are real issues impacting reimbursement, audits, and network participation right now. Take a look at our Pharmacy Insights Newsletter and Sign up: connect.bipc.com/cv/c92d34337f4… #Pharmacies #PBMs #PBMReform #PharmacyLaw #PharmacyLawyer

New episode on "Pharmacy Law Lowdown" is available on Drug Topics! In this episode, Lucas Morgan and I cover #FTC and #ESI settlement, and the positive impact upon the pharmacy industry. drugtopics.com/view/pharmacy-… #FTC #ExpressScripts #EverNorth #Cigna #ESI #PBMs #PBMReform

CAA 2026 is going to be a great tool for Plan Sponsors and Independent Pharmacies. Check out my article below. bipc.com/the-consolidat… #PlanSponsor #CAA #ConsolidatedAppropriationsAct #PBMReform #PBMs #FiduciaryDuty

Another major win for an independent pharmacy. Kelly Reynolds and I successfully secured a complete reversal of an OIG-driven retrospective payment review that sought to recoup significant funds from our pharmacy client. These retrospective reviews are not routine audits. They are aggressive, document-intensive investigations that often look years back and rely heavily on technical interpretations of billing, documentation, and regulatory compliance. In this case, the review centered on alleged discrepancies that, at first glance, appeared difficult to overcome. But as is often the case, the government’s conclusions did not tell the full story. We dug into the records. We challenged the assumptions. We reframed the narrative. The result: 100% reversal. No recoupment. This is exactly why pharmacies should not accept audit findings or payment demands at face value. If your pharmacy is facing an OIG review, audit, or any form of retrospective payment scrutiny, how you respond in the early stages will dictate the outcome. We deal with these issues every day. #OIG #Pharmacies #PharmacyLaw #PharmacyLawyer

Join me, Lucas Morgan and Nicolette Mathey for an upcoming webinar (hosted by ATRIUM24) discussion on the legal and regulatory considerations surrounding peptides including FDA regulatory categories, key compliance risks for pharmacies, and how pharmacies can prepare as this area continues to evolve. Pharmacies across the country are receiving more questions about peptides from both patients and providers. Understanding the regulatory landscape now is critical as scrutiny in this space continues to increase. Register here: us02web.zoom.us/webinar/regist… #Peptides #Compounding #CompoundingPharmacy #FDA #PharmacyLaw #PharmacyLawyer

MAJOR DEVELOPMENT IN ERISA HEALTH PLAN LITIGATION. SEE MY ARTICLE BELOW. bipc.com/jp-morgan-eris…

State Enforcement Against Pharmacy Benefit Managers Intensifies: Lessons from Louisiana and West Virginia bipc.com/state-enforcem…

Buchanan Life Sciences Team Secures Seven-Figure FDA User Fee Waiver for Manufacturer bipc.com/buchanan-life-…

Pleased to be quoted in a recent Bloomberg Law article discussing the emerging TrumpRx discount platform and the uncertainty it may create for pharmacy reimbursement. news.bloombergtax.com/employee-benef… #Pharmacies #DTC #TrumpRx #PBMReform #PBMs #PharmacyLaw

📬 Our February Pharmacy & PBM Newsletter Is Out. If you operate a pharmacy, advise plan sponsors, or deal with PBMs in any capacity, this month’s issue is worth your time. We cover: • Federal and state PBM reform developments impacting the pharmacy industry. • Enforcement and audit trends that are tightening across the country. • GLP-1 and compounding scrutiny where things stand and where they’re headed. • Legislative updates that will directly affect reimbursement, transparency, and fiduciary exposure. • Strategic insights for pharmacies and employers navigating today’s drug spend landscape. There’s a lot of noise in this space. We focus on the regulatory shifts, structural risks, and practical steps stakeholders should be taking now. If you’re not reading these updates, you’re reacting instead of preparing. lnkd.in/e4f-Fgsq

Buchanan Life Sciences Team Closes a 9-Figure Cross-Border Transaction. Very proud of this result. bipc.com/buchanan-life-…

My latest article was published in BenefitsPro on a subject that continues to reshape the pharmacy landscape: PBM pharmacy audits. These audits are no longer routine claim reviews. They have become aggressive financial tools. In the piece, I outline three core points. First, the scope of audit continues to expand. PBMs are digging into invoice reconciliation, copay collection, documentation technicalities, source of Prior Authorizations and applying extrapolation methods that can turn minor discrepancies into substantial recoupment demands. Second, the fallout goes beyond money. Audit findings are increasingly being used to justify network suspension or termination, sometimes affecting affiliated locations. For an independent pharmacy, that can threaten the entire business overnight. Third, preparation matters. Pharmacies that understand their contracts, maintain disciplined documentation, and respond strategically to findings are in a far stronger position than those reacting under pressure. For plan sponsors and benefits professionals, audit activity should also prompt a larger conversation about oversight, reimbursement integrity, and network stability. The audit climate is not easing. The financial exposure is real. If you operate a pharmacy or oversee pharmacy benefits, this is an area that deserves close attention now and not after a notice lands on your desk. #Pharmacies #PharmacyBenefits #PlanSponsors #PBMs #FiduciaryDuty #ERISA #HealthBenefits #PharmacyLaw #PharmacyLawyer benefitspro.com/2026/02/17/3-t…