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ARTICLE · 22 JULY 2026

Caremark Settles PBM FTC Action Regarding Reimbursement Practices, Second Major PBM To Settle

Goodwin Procter LLP
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CVS Health subsidiary Caremark has reached a landmark settlement with the Federal Trade Commission, requiring sweeping changes to its pharmacy benefit management practices including rebate transparency, formulary prioritization of lower-cost drugs, and point-of-sale rebate programs. The agreement follows a similar Express Scripts settlement and could fundamentally reshape how the nation's largest PBMs operate, potentially delivering billions in consumer savings while accelerating an industry-wide shift from

United StatesConsumer Protection
Katherine Cheng
Katherine Cheng
Heath Ingram
Heath Ingram
Alexandra Russell
Alexandra Russell
Samantha Jandl
Samantha Jandl
Avi Strauss
Avi Strauss

On July 14, 2026, CVS Health subsidiaries Caremark Rx LLC and Zinc Health Services LLC (collectively, “Caremark”) agreed to a settlement with the Federal Trade Commission (FTC), resolving the administrative claims against Caremark in the agency’s ongoing case targeting the nation’s three largest pharmacy benefit managers (PBMs). The Caremark settlement follows the FTC’s February 2026 settlement with Express Scripts in the same case. For more information on the Express Scripts settlement, read Goodwin's prior alert, “Express Scripts Settles PBM FTC Action and Must Make Fundamental Changes to PBM Model.”

Under the terms of the settlement, Caremark must make significant changes to its business practices, including changes to its pharmaceutical product formulary practices, rebate transparency, and pharmacy network contracting. The FTC estimates the settlement will deliver $8.5 billion in consumer savings over the next 10 years and unlock up to $4.5 billion in additional savings through

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