Pharmacy network protections and anti-steering

They also have the option for health plan members to fill 90-day prescriptions at retail locations instead of requiring the use of the mail-order service.

Recorded reference: Page 10

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Published rationale. The memorandum notes that members may fill 90 day prescriptions at retail rather than being pushed into mail order, and the packet prices a 90 day retail network on pages 10 and 11, which is a mild protection against steering into a single channel. Page 10 also describes a network of more than 67,000 retail pharmacies contracted directly rather than rented. None of the other network protections in the model contract are present, including finality of adjudicated claims, a bar on retroactive clawbacks, a rule against conditioning reimbursement on volume and an any willing pharmacy right.

No evidence quotation was recorded for this finding.

Recorded reference: No page reference recorded

Published rationale. The text notes the PBM contracts directly with pharmacies but the executed contract is needed to verify protections like any willing pharmacy and anti-steering rules.

“Not addressed” is this published review’s conclusion about the produced text, not proof that a provision is absent from every version or withheld document.

They also have the option for health plan members to fill 90-day prescriptions at retail locations instead of requiring the use of the mail-order service.

Recorded reference: Page 10

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Published rationale. Allowing 90-day retail fills avoids one form of mandatory mail steering and preserves member choice. The packet does not prohibit retroactive pharmacy clawbacks, volume-conditioned reimbursement, steering to any related pharmacy, or exclusion of willing pharmacies. Those broader network protections are not visible because the executed agreement is absent.

They also have the option for health plan members to fill 90-day prescriptions at retail locations instead of requiring the use of the mail-order service.

Recorded reference: Page 10

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Published rationale. Page 10 says Envision has over 67,000 retail pharmacies, contracts directly rather than using rental networks, and lets members fill 90-day prescriptions at retail instead of requiring mail order. Those are network access points, but the backup has no claims-final rule, no ban on retroactive clawbacks, and no any-willing-pharmacy term. It also does not forbid steering to a preferred mail or specialty pharmacy such as the Costco partnership described on that page.

They also have the option for health plan members to fill 90-day prescriptions at retail locations instead of requiring the use of the mail-order service.

Recorded reference: Page 10

Page navigation follows the recorded reference; check printed numbering against the PDF.

Published rationale. The 90-day retail fill option is an affirmative protection against steering members into mail order, and page 10 notes Envision contracts directly with pharmacies rather than using rental networks. But the backup says nothing about final adjudication, retroactive clawbacks, volume-conditioned reimbursement, or any willing pharmacy participation. Those network terms would be in the executed agreement or the network manual, which are not in the file.