The Fiduciary Blind Spot: Why Employer Health Plans Are Not Actually Managed Like Retirement Plans
The legal framework for ERISA fiduciary duty does not distinguish between retirement plans and health plans. Both are employee benefit ...
Self-Funded and Exposed: How Employers Lost Control of Their Own Pharmacy Spend
The self-insured employer is, in theory, the most sophisticated buyer in American healthcare. It bears the full financial risk of ...
Rebate Aggregators and the New Intermediary Problem in Drug Pricing
Every system generates the consultants it deserves. The pharmaceutical rebate system — opaque, bilateral, and structured to reward information asymmetry ...
The IRA’s Drug Negotiation Mechanism Meets the Rebate Industrial Complex
The Inflation Reduction Act's drug negotiation provision represents the federal government's most direct intervention into pharmaceutical pricing since the creation ...
Medicaid’s Best Price Rule and the Perverse Geometry of Drug Discounts
The Medicaid best price rule is an elegant policy mechanism with an unintended consequence that has become inseparable from its ...
The Deferred Promise of Point-of-Sale Rebate Reform
The idea is simple enough to fit on an index card: instead of manufacturer rebates flowing to pharmacy benefit managers ...
The Rebate Wall: Why High List Prices Are a Feature of Drug Markets, Not a Flaw
Call it the rebate wall: the financial barrier that branded pharmaceutical manufacturers have erected around their formulary positions, built from ...
The Rebate as Architecture: How Drug Pricing Became a System That Nobody Designed and Everyone Defends
The pharmaceutical rebate system was not designed. It accumulated. Over three decades of regulatory responses, bilateral contractual innovations, and competitive ...
The Payer’s Dilemma: Choosing Between Negotiation Intelligence and Market Disclosure
The request-for-proposal processes that large health plans run for analytics vendors share a recurring structural problem: they ask MedPricer and ...
The Intelligence Gap: What MedPricer and Turquoise Health Each Know That the Other Does Not
There is a category error embedded in most comparisons of MedPricer and Turquoise Health — the implicit assumption that both ...
Two Platforms, Two Theories of Change in Hospital Pricing
Two platforms, two theories of change. That is the cleanest way to frame a comparison between MedPricer and Turquoise Health ...
Transparency Without Accountability: The Quiet Limits of the Price Disclosure Movement
The price transparency movement in American healthcare carries a foundational assumption that has never been adequately tested: that revealing prices ...
FDA Evaluation of Certain Bulk Drug Substances in Compounding: Clinical Interpretation
Clinicians increasingly encounter patients using or requesting peptide-based therapies sourced through compounding pharmacies. The U.S. Food and Drug Administration has identified a subset of bulk drug substances, including certain peptides, that may present significant safety risks when used in compounded formulations. The clinical question is whether these regulatory signals reflect meaningful patient-level risk and how they should influence prescribing behavior. This matters because compounded peptides often sit outside traditional approval pathways, creating uncertainty around quality, dosing consistency, and safety. Understanding...
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