Martha M. Rumore, PharmD, JD, MS, LLM, FAPhA is Of Counsel at Health Law Alliance and a registered U.S. Patent Attorney

Frequently Asked Questions

In an era where pharmacy benefit managers (“PBMs”) are aggressively targeting pharmacies for audits, failing to address inventory discrepancy allegations can have dire consequences. Luckily, our team at Health Law Alliance knows how to beat PBMs at their own game. Last month, Health Law Alliance scored a major victory for one of our clients, slashing their inventory discrepancy findings by an astonishing 80%.

The Danger of Inventory Discrepancies

Inventory discrepancies are one of the first things PBMs look for during an audit. Even minor clerical errors like entering the incorrect NDC or failing to return a medication to stock can snowball, creating major financial risks that could place your pharmacy in jeopardy.  

And PBMs don’t always ensure a level playing field. In their appeal procedures, PBMs often place arbitrary limitations on the invoices they will accept, refusing to consider purchases for medications that have long been part of the pharmacy’s inventory. Without a tailored appeal strategy, pharmacy owners may find it nearly impossible to ensure their documentation is being reviewed and considered during the appeal process.

In 2026, independent pharmacy owners are increasingly at risk of facing severe penalties, including thousands of dollars in recoupments and even termination from PBM networks. As PBMs ramp up enforcement and scrutiny, many pharmacies find themselves caught in a web of audits that can quickly spiral out of control, leading to devastating financial losses and damaged reputations.

Our Winning Strategy

When our client faced a daunting audit alleging thousands of dollars in discrepancies, they turned to us for help. Our team developed a strategic defense to challenge the audit findings, highlighting that Caremark had failed to consider several of the pharmacy’s purchases despite having received invoices from the relevant wholesalers. Thanks to HLA’s advocacy, Caremark drastically reduced the pharmacy’s total recoupment, saving the pharmacy from paying thousands in unjustified penalties for medications that were properly ordered and dispensed.  

Act Before It’s Too Late

This recent win highlights the importance of proactive legal support. Ignoring the risks associated with inventory discrepancy findings can quickly place your pharmacy in hot water with PBMs—and even state and federal regulators. No matter how daunting the findings, Health Law Alliance is here to help you navigate the PBM audit appeal process with ease.  

Need to prepare an appeal of a PBM’s audit findings, but not sure where to start? Contact Health Law Alliance today to ensure your pharmacy has the tools it needs to fight back.

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