FTC Reaches Second Insulin Pricing Settlement: Comparing the Caremark…

The FTC settled its second major insulin pricing case against Caremark, requiring PBMs to delink rebates from formulary placement, cap patient out-of-pocket costs, and provide transparent cost reporting. The order mirrors an earlier ESI settlement but carves out Medicare, Medicaid, and Exchange plans from key requirements. If you sell pharmacy software, PBM automation, or transparency tools to commercial plans, the business model just changed - rebates are now a liability, not a lever, and every contract needs real-time cost reporting built in. The carve-out for Medicare and Medicaid means two separate tech stacks are now required.