FTC Reaches Second Insulin Pricing Settlement: Comparing the Caremark and ESI Orders

Short summary

The FTC announced its second insulin pricing settlement on July 14, 2026, this time with Caremark Rx, closely tracking the earlier Express Scripts order. The Caremark Order requires ending rebate-driven formulary preferences, delinking PBM compensation from drug list prices, expanding insulin affordability protections, and increasing transparency for plan sponsors. Plan sponsors may still opt for non-standard arrangements subject to disclosure and anti-steering obligations.

• •FTC settled with Caremark over anticompetitive insulin rebate schemes, second settlement after ESI
• •Order requires delinking PBM compensation from list prices, capping patient out-of-pocket insulin costs
• •Plan sponsors can still choose non-standard arrangements if Caremark complies with disclosure and anti-steering rules

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