Legal Hot Topics in Oncology Pharmacy

Program Description

Community oncology practices face increasing legal and regulatory complexity in 2026, particularly related to pharmacy benefit manager (PBM) contracting and reimbursement. Underwater reimbursement continues to challenge practice sustainability across Medicare Advantage, Managed Medicaid, and commercial plans, while recent federal actions—including the Consolidated Appropriations Act of 2026, the Department of Labor’s proposed fiduciary rule, and the Federal Trade Commission settlement with Express Scripts—are reshaping the PBM regulatory landscape. At the same time, evolving cost-plus contracting models introduce both opportunities and risks, particularly for specialty oncology practices with significant non-dispensing responsibilities that may not be adequately reimbursed. In parallel, emerging state-level PBM reform laws provide new enforcement mechanisms, though many pharmacists are not fully aware of how to interpret or utilize these tools in practice. This activity is designed to address key knowledge and competence gaps by helping community oncology pharmacists understand recent federal and state policy changes, evaluate PBM contracting models, and identify appropriate legal and operational strategies to address below-cost reimbursement. Through this session, pharmacists will be better prepared to support practice-level decision-making, navigate evolving reimbursement models, and contribute to efforts that promote sustainable oncology care delivery and patient access.

Target audience: Oncology pharmacists
Type of activity: Application
Release date: May 29, 2026
Expiration date: May 28, 2027
Learner level: Foundational, Intermediate
Time to complete activity: 0.75 hour
Fee: Free

Educational Objectives

At the completion of this activity, participants will be able to:

1. Describe the key provisions of the Consolidated Appropriations Act of 2026, the Department of Labor proposed rule, and the Federal Trade Commission (FTC) settlement with Express Scripts, and how each impacts pharmacy benefit manager (PBM) contracting with oncology practices
2. Evaluate cost-plus contracting models currently being implemented by major PBMs, including their definitions of "cost," reimbursement structures, and potential weaknesses for specialty oncology practices
3. Apply federal and state legal strategies, including Centers for Medicare & Medicaid Services (CMS) complaints, FTC monitor filings, maximum allowable cost appeals to challenge below-cost PBM reimbursement in an oncology setting
4. Develop a practice-specific action plan for responding to PBM contract changes, tracking acquisition and dispensing cost data, and engaging in the CMS rulemaking process over the next 3 years

Accreditation

Pharmacy Times Continuing Education™ is accredited by the Accreditation Council for Pharmacy Education (ACPE) as a provider of continuing pharmacy education. This activity is approved for 0.75 contact hours (0.075 CEU) under the ACPE universal activity number 0290-0000-26-162-H03-P. The activity is available for CE credit through May 29, 2027.

Instructions for Completing the Activity and Receiving CPE Credit

To receive CPE credit, participants must complete the pretest, view the activity in its entirety, complete the posttest, and complete the online activity evaluation. After successful completion of the online activity evaluation, you can submit your credit to CPE Monitor. You may view your credit within 48 hours at www.mycpemonitor.net. All participants must request credit before the activity expiration date. CE credit will not be issued after this date.

Faculty

Jonathan E. Levitt, Esq, has no relevant financial relationships with ineligible companies to disclose.

Pharmacy Times Continuing Education™ Planning Staff—Jim Palatine, RPh, MBA; Rose Buszka, PharmD, BCPS, CHCP; Amy L. Morris, PharmD, BCOP; Daphne Davis, PharmD, BCOP; Emily Tyler; Susan Pordon; Brianna Winters; and Chloe Taccetta have no relevant financial relationships with ineligible companies to disclose.

At least one anonymous peer reviewer was used as part of content validation and conflict resolution. The peer reviewer has no relevant financial relationships with ineligible companies to disclose.

Educational Disclaimer

Continuing professional education activities are offered solely for educational purposes and do not constitute any form of professional advice or referral. Discussions concerning drugs, dosages, and procedures may reflect the clinical experience of the author(s) or be derived from the professional literature or other sources and may suggest uses that are investigational in nature and not approved by the labeling or indications. Participants are encouraged to refer to primary references or full prescribing information resources.

For questions about this internet CPE activity, please contact:
ceinfo@pharmacytimes.com
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