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ARTICLE · 23 JANUARY 2026

Recent Case Illustrates Challenges For Independent Pharmacies In Seeking Access To Largest PBM Networks

As the pharmacy landscape continues to consolidate, Pharmacy Benefit Managers (PBMs) continue to wield unprecedented influence over independent pharmacies and their ability to serve patients.

United StatesAntitrust/Competition Law

As the pharmacy landscape continues to consolidate, Pharmacy Benefit Managers (PBMs) continue to wield unprecedented influence over independent pharmacies and their ability to serve patients. A recent federal case, Rx Solutions, Inc. v. Caremark, LLC, spotlights the steep hurdles independent pharmacies face when seeking access to the largest PBM networks and reveals how PBMs monitor common ownership and common association affiliations for network participation.

Background: The Case at a Glance

Rx Solutions, a Mississippi-based independent pharmacy, sought to gain access into Caremark's PBM network. Caremark is positioned as one of the largest PBMs in the nation. Caremark is owned by CVS Health Corporation. After the Pharmacy's application was denied, Rx Solutions sued Caremark and CVS, alleging antitrust violations and state law claims. Rx Solutions tried to challenge its exclusion under federal antitrust law, arguing that Caremark and CVS conspired to drive

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