Ownership and affiliate disclosure exhibit

Upon Employer request (not more than once per calendar year), Claim Administrator will provide a list of such entities to Employer.

Recorded reference: Page 12

Published rationale. Section 6.2 on page 12 acknowledges that the Claim Administrator or its subsidiaries or affiliates may hold ownership interests in providers and in vendors serving the agreement, and offers a list of such entities on request no more than once a year. Page 28 discloses ownership of a significant portion of Prime's equity and says mail order and specialty pharmacies may be operated by an affiliate of or partially owned by Prime, and page 43 repeats the Prime ownership statement. The model asks for a signed exhibit naming every owner, parent, subsidiary, affiliate, GPO, rebate aggregator, mail order and specialty pharmacy, refreshed within thirty days of any change. Here there is no exhibit, the list is only available on request, it is limited to once a year, and no refresh obligation exists, so the protection is present but materially weaker than the model.

Upon Employer request (not more than once per calendar year), Claim Administrator will provide a list of such entities to Employer.

Recorded reference: Page 12

Published rationale. On Page 12, Section 6.2 acknowledges that the Claim Administrator and its affiliates may hold ownership interests in healthcare providers and service vendors, and promises to provide a list of those entities upon written request no more than once per calendar year. While this provides some transparency, it falls short of the model contract published by Mark Cuban and collaborators, which requires a comprehensive signed exhibit detailing all parents, subsidiaries, affiliates, GPOs, rebate aggregators, and mail or specialty pharmacies, along with a mandatory 30 day update requirement.

Upon Employer request (not more than once per calendar year), Claim Administrator will provide a list of such entities to Employer.

Recorded reference: Page 12

Published rationale. Page 12 acknowledges possible ownership interests in providers and vendors and offers a list upon request, limited to one request each calendar year. Pages 28 and 43 disclose significant equity ownership of Prime, and page 28 says the mail or specialty pharmacy operator may be an affiliate of, or partly owned by, Prime. That is meaningful but far weaker than a signed comprehensive exhibit of every owner, parent, subsidiary, affiliate, purchasing organization, rebate aggregator and related pharmacy. The text imposes no automatic update within 30 days of an ownership or control change. The page 12 list is discretionary to request, relates to the administrator's described entities, and does not establish a complete Prime ownership map.

Claim Administrator or its subsidiaries or affiliates may also have ownership interests in certain Providers who provide Covered Services to Covered Persons, and/or in vendors or other third parties who provide services related to this Agreement or provide services to certain Providers.

Recorded reference: Page 12

Published rationale. There is no signed ownership exhibit. Page 12 discloses that Claim Administrator or its subsidiaries or affiliates may have ownership interests in providers, vendors, or other third parties, and that a list will be provided on request, not more than once per calendar year. Page 28 says Claim Administrator owns a significant portion of the equity of Prime, and that mail and specialty pharmacy may be operated by a third party that may be an affiliate of or partly owned by Prime. No group purchasing organization is named. No parent, subsidiary, rebate aggregator, or specialty pharmacy is listed in an exhibit. There is no duty to refresh the list within thirty days of a change in ownership or control. The model contract calls for a signed exhibit of every related entity, refreshed within thirty days of a change in control. What is here is an annual list on request plus a narrative note on the Prime stake. That is partial.

Claim Administrator or its subsidiaries or affiliates may also have ownership interests in certain Providers who provide Covered Services to Covered Persons, and/or in vendors or other third parties

Recorded reference: Page 12

Published rationale. The model term wants a signed exhibit listing every owner, parent, subsidiary, affiliate, group purchasing organization, rebate aggregator, mail order and specialty pharmacy tied to the PBM, refreshed within 30 days of any change. No such exhibit exists here. What exists instead is section 6.2 on page 12, which acknowledges the Claim Administrator or its affiliates may own stakes in providers and vendors and will furnish a list on request, but not more than once per calendar year, and pages 27, 28 and 43, which disclose the significant equity stake in Prime and that mail and specialty channels may be run by Prime affiliates or part-owned third parties. There is no signed ownership exhibit, no list of GPOs or rebate aggregators, and no refresh obligation on change of control. Some ownership information is reachable, but only on request and at most once a year, so this is present but materially weaker than the model.