Relating to the relationship between pharmacists or pharmacies and health benefit plan issuers or pharmacy benefit managers.

Contracts

• Eliminate Unilateral Amendments: You must strip provisions allowing you to alter fee schedules or network tiers via simple notice. The law requires affirmative written agreement from the pharmacy for any "adverse material change."
• Embed Financial Terms: You may no longer incorporate fee schedules by reference to external documents. All reimbursement rates and calculation methodologies must be explicitly contained within the contract text.
• Anti-Steering/Tying: Remove any clauses that condition participation in one network on participation in another; these are now prohibited.
• Notice Periods: Redraft notice provisions to align with the statutory 90-day notice for non-adverse changes and the 120-day implementation lag for agreed-upon adverse changes.

Hiring/Training

• Audit Teams: Retrain auditors immediately. They must distinguish between "clerical errors" and "fraud/substantive errors." Recouping the full cost of a drug for a clerical typo is now illegal; you may only recoup the dispensing fee.
• Provider Relations: Staff must be trained to manage the new "opt-out" process. Silence from a pharmacy regarding a proposed contract change can no longer be interpreted as acceptance.

Reporting & Record-Keeping

• Secure Portal: You must maintain a secure, password-protected portal containing all active contracts, addendums, and provider manuals.
• Comparison Logic: When proposing non-adverse changes, you must provide a description that allows the pharmacy to compare new terms against old terms within the portal.
• Agreement Logs: You must implement a system to archive the specific "written agreement" obtained from pharmacies regarding adverse changes to defend against future breach of contract claims.

Fees & Costs

• Fee Ban: You are prohibited from charging application, credentialing, or participation fees *prior* to disclosing all material contract terms and financial provisions.
• Recoupment Revenue Loss: Budget for a reduction in audit recoveries due to the ban on recouping drug costs for clerical errors.