"Payers and PBMs do not fit the definition of being in a
position to 'induce or reward the referral of federal health care program
business' since rebates are not paid by manufacturers on federal program
transactions."
— Bill Sullivan, principal consultant at Specialty Pharmacy
Solutions LLC, questioning how the Trump administration could use the federal
Anti-Kickback Statute to restrict rebates, in an interview with Radar on Specialty Pharmacy
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