A comprehensive audit by the Tennessee Department of Commerce and Insurance of CVS Caremark's 2024 operations in the state identified violations of Tennessee PBM requirements. The review documented 11 formal findings and five additional observations related to reimbursement, spread pricing, transparency, appeals, and network practices.
Key issues cited in the audit include:
- Drastically uneven reimbursements offering CVS-affiliated pharmacies rates as much as 16,510 percent higher than non-affiliated pharmacies;
- Continued spread pricing in contracts entered and renewed after Tennessee's spread pricing ban;
- Failure to pay required dispensing fees correctly for many low-volume and rural pharmacies;
- Statutory appeals process violations, including improper denials and untimely payments.
The outcome of this audit mirrors findings in other states and underscores the importance of strong PBM reform and consistent enforcement to prohibit spread pricing, improve transparency, and help ensure fair pharmacy reimbursement.
Read the audit report here.
NCPA
