July 30, 2014

Moran Company — Since the enactment of the Medicare Modernization Act (MMA) in 2003, the Part D statute has required prescription drug plans to offer standard contracts to any pharmacy willing to enter into such a contract. Drug plan sponsors may, however, contract with pharmacies willing to offer additional pricing concessions to participate in a “preferred network,” whose member pharmacies Part D beneficiaries are encouraged to use because of materially lower cost sharing at the point of sale.