A Legal Perspective on PBM Reform and FTC Enforcement

In this episode of Prescription for Better Access, we’re joined by William (Bill) Sarraille, a legal expert on drug access and reimbursement. He discusses two developments shaping the pharmacy benefit landscape: the FTC’s enforcement action involving Express Scripts and PBM reforms in the Consolidated Appropriations Act of 2026. Bill explains what these policy changes could mean for benefit design, drug coverage, employer-sponsored plans, and transparency in the PBM market. We also explore potential impacts on formularies, utilization management, contracting practices, and patient out-of-pocket costs, along with possible unintended consequences for employers, manufacturers, and patients seeking timely and affordable access to medicines.

• William (Bill) Sarraille, University of Maryland School of Law
• LinkedIn
• Pharmacy Benefit Managers (PBMs)
• FTC Settlement
• 2024 Administrative Complaint
• Cigna Healthcare
• Fair Market Value in Healthcare
• Consolidated Appropriations Act of 2026
• Part D Plan
• PBMs No Longer Profit From Rebates But Plans Benefit – Pink Sheet
• TPA (Third Party Administrators)
• DOL Proposal
• Copay Accumulators and Maximizers
• Amicus Brief, HIV and Hepatitis Institute

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