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Dossier04 source register

FTC insulin complaint announcement, 20 September 2024

FTC allegations; approximately 80% of US prescriptions administered by Big Three; not a final liability finding.

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FTC Docket 9437 / status checked 24 October 2026

Pending docket; ESI settlement announced February 2026; Caremark agreement July 2026; Optum withdrawn from adjudication June 2026 for consideration of proposed consent. Do not call these final judgments.

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FTC second interim staff report, January 2025

Selected specialty generic study, 2017–2022: more than $7.3B dispensing revenue above estimated acquisition cost; not net profit or all drugs.

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FTC specialty generic report and methodology

NADAC is a benchmark; reimbursement, affiliated pharmacy concentration and spread pricing are distinct measures.

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Senate Finance bipartisan insulin investigation, January 2021

Historical documents and contract incentives; not a current retail price list.

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FDA Generic Drug Facts

Same active ingredient, strength, dosage form, route and required performance; prescriber/pharmacist assesses suitability.

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CMS rights when not using insurance

Good faith estimate scope; not an automatic right to rewrite every bill.

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CMS patient-provider dispute resolution

Uninsured/self-pay eligibility, at least $400 above provider estimate, 120-day window, $25 fee; verify current rules.

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Medicare Part D costs

Plan stages and cost sharing vary; cash purchases and plan accumulators must be checked separately.

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Respondents’ position in FTC-filed collateral complaint, November 2024

Respondent filing disputes FTC theory, emphasizes manufacturer list-price setting and negotiated concessions. It is an advocacy filing, not an agency finding.

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FTC first interim PBM staff report, July 2024

Concentration, parent/affiliate map, formulary and independent-pharmacy contract concerns; staff findings, not a final liability judgment.

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