51 JFK Parkway, Short Hills, NJ 07078
25+ Years Defending Pharmacies Nationwide

PBM Audit Defense Attorneys

OptumRx, Caremark, Express Scripts, Humana, Prime — and every major PBM.

PBM audits can lead to devastating recoupments, network termination, and criminal prosecution. Our attorneys - former federal prosecutors and senior PBM executives - know exactly how to protect your business and your livelihood.

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(800) 345 - 4125
Available 24/7 - speak with an attorney, not a call center
2,500+ Clients
1,500+
Audits Overseen
5,000+
Matters Handled
24/7
Availability

Free Confidential Case Review

Speak directly with a former prosecutor

What Happens Next
1
A senior attorney reviews your situation within hours
2
We schedule a confidential strategy call at your convenience
3
You receive a clear action plan to protect your pharmacy
100% Confidential · No obligation · Attorney-client privilege applies
Our Attorneys' Prior Experience Includes
U.S. Department of Justice Dept. of Justice
Federal Bureau of Investigation FBI
HHS Office of Inspector General HHS-OIG
IRS / U.S. Treasury IRS
NAMFCU NAMFCU
Drug Enforcement Administration DEA
McKesson McKesson
OptumRx OptumRx
Your Defense Team
Meet the Attorneys Who Will
Fight for Your Pharmacy
Anthony Mahajan - Healthcare Defense Attorney

Anthony Mahajan

Founding Partner

Former federal prosecutor and senior executive at United Health/OptumRx. Anthony has personally overseen more than 1,500 pharmacy audits and brings rare cross-training in both government enforcement and PBM operations.

  • Former Assistant U.S. Attorney
  • Former Sr. Executive, United Health/OptumRx
  • 1,500+ pharmacy audits overseen
  • DOJ Director's Award recipient
Diana Yastrovskaya - Healthcare Defense Attorney

Diana Yastrovskaya

Partner

A seasoned healthcare defense attorney with deep expertise in PBM audit defense, regulatory compliance, and government investigations. Diana represents pharmacies nationwide in complex audit disputes and enforcement matters.

  • Concentrated practice in healthcare regulatory defense
  • PBM audit & compliance counsel
  • Federal & state investigation defense
  • Focused on network termination appeals
The Stakes Are High
What's at Risk When a PBM Audit Hits

Without experienced counsel, pharmacies face consequences that can threaten their entire livelihood. A strategic response from day one is critical.

01

Massive Financial Recoupments

PBMs can demand repayment of hundreds of thousands, even millions, in reimbursements, often based on flawed audit methodologies and extrapolated findings that inflate alleged overpayments. Demand letters routinely cite disputed MAC pricing benchmarks, contested signature logs, and aggressive readings of the provider manual.

02

Network Termination

Losing your PBM network participation means losing the ability to serve the majority of your patients. For most pharmacies, a network termination is effectively a death sentence for the business.

03

Criminal Prosecution

PBM audits can trigger referrals to federal and state prosecutors, FBI, HHS-OIG, and DEA. What begins as a billing review can escalate into a criminal healthcare fraud investigation.

Every day without legal counsel is a day the PBM builds its case.

Protect Your Pharmacy Now →
How We Defend You
Comprehensive PBM Audit Defense

From the moment you receive an audit notice through appeals and final resolution, our team provides strategic legal counsel at every stage.

01

Immediate Audit Response

Free initial strategy session to assess risk exposure and develop an action plan to protect your pharmacy from the moment you receive notice.

02

Detailed Audit Analysis

We construct a comprehensive factual narrative, challenge every questionable finding, and identify weaknesses in the PBM's audit methodology.

03

Legal Strategy & Response

Tailored legal responses rooted in federal and state pharmacy law, contractual provisions, and regulatory frameworks that challenge unfair findings.

04

Appeals & Settlement

Deep knowledge of PBM internal processes allows us to drive the full audit appeal sequence, negotiate reduced recoupments, reverse network terminations, and fight for the best outcome.

05

Compliance & Prevention

We design internal audit protocols, improve documentation practices, and provide ongoing compliance guidance to reduce future audit risk.

06

Criminal Defense

If your audit escalates to a government investigation, our former federal prosecutors provide experienced criminal defense representation.

Why Health Law Alliance
We Used to Work for Them
Now We Fight for You

Our attorneys include former federal prosecutors, government regulators, and senior PBM executives who understand the system from the inside out.

From the Other Side of the Table

A former prosecutor, a former DEA Diversion Program Manager, and senior healthcare-industry executives who know exactly how enforcement agencies build their cases - and how to dismantle them.

PBM Executive Experience

Our founding partner served as a senior executive at United Health/OptumRx. We understand PBM audit tactics, internal processes, and settlement leverage firsthand.

Documented Outcomes

Over 1,500 pharmacy audits overseen, 2,500+ clients represented, and documented wins including dismissed federal charges and reversed network terminations.

Recent Wins
Proven Results for Pharmacies Under Fire
Federal - Charges Declined

United States v
Pharmacy & Owner

Allegation: $6.5M inventory shortfall in compound cream APIs

Agencies: U.S. Attorney's Office, FBI, HHS-OIG

Outcome

Federal prosecutors declined criminal charges. Settlement at $2.5M - just 40% of claimed loss.

State - All Charges Dropped

Commonwealth of Massachusetts v. Pharmacy & Owner

Allegation: 25,000 unit Zegerid discrepancy

At stake: Criminal prosecution, network exclusion

Outcome

State dropped all charges before trial. No admission, no exclusion, no sanctions.

State - Owner Protected

Commonwealth of Pennsylvania v. Pharmacy & Owner

Allegation: $600,000 inventory shortfall

At stake: Criminal charges against owner personally

Outcome

State declined criminal charges against the owner. Personal liability eliminated entirely.

Specialized Defense
Defense for Every Major PBM
Client Reviews
What Clients Say
  1. Anthony's background as a former federal prosecutor and executive for major healthcare companies provided a level of expertise and insight that made all the difference. His deep understanding of healthcare law, particularly in litigation and compliance matters, helped navigate complex legal issues with ease.
Common Questions
Frequently Asked Questions
What should I do immediately after receiving a PBM audit notice?+
Contact an experienced PBM defense attorney before responding to the audit. Anything you say or submit can be used against you. Our team will review the notice, assess your risk exposure, develop an immediate action plan, and guide every step of the response to protect your pharmacy's interests.
What do PBMs typically examine during an audit?+
PBMs examine prescription records at the NDC level, prior authorization compliance, formulary tier adherence, step therapy override approvals, billing accuracy, copay collection practices, and clinical documentation. Common triggers include high-reimbursement medications, brand/generic substitution patterns, and inventory discrepancies. Findings are interpreted against the PBM's provider manual rather than any neutral standard.
Can a PBM audit lead to criminal charges?+
Yes. PBM audits can result in referrals to federal and state prosecutors, FBI, HHS-OIG, and DEA. What begins as a routine billing review can escalate into a criminal healthcare fraud investigation with potential imprisonment. Early legal counsel from attorneys experienced in both civil and criminal defense is critical.
Can I appeal PBM audit findings?+
Absolutely. Most PBM contracts include an audit appeal process with strict deadlines. Our team has extensive experience challenging audit findings, reducing recoupment amounts, and reversing network terminations through both formal and informal appeal stages.
How do PBM pricing mechanics drive recoupment risk?+
PBM economics shape what an audit can claim. Reimbursement caps from MAC pricing set the ceiling on what a pharmacy is paid per claim, spread pricing sits between what the plan pays the PBM and what the PBM pays the pharmacy, and DIR fees in Medicare Part D can reclaim margin months after dispense. Contracts with an effective rate guarantee or a pass-through pricing model produce a different audit posture than traditional spread contracts. AWP benchmarks anchor most of these calculations, and 340B covered entity status adds a separate audit track. Defending an audit requires arguing every one of these layers, not just the dispensing record.
What does a PBM defense attorney cost?+
We offer flexible fee structures tailored to your situation. The initial consultation is always free and confidential. Given that PBM recoupments often reach six or seven figures, experienced legal representation is a critical investment in protecting your pharmacy's financial future.
I received a network termination notice. Is it too late?+
No, but time is critical. Network termination notices typically come with tight appeal deadlines. We have successfully reversed network terminations for pharmacies across the country. Contact us immediately so we can assess your options.

Don't Face a PBM Audit Without Experienced Counsel

Every day without legal representation is a day the PBM builds its case against you.

"You will want them in your corner. Their cross-trained view of PBM processes and government enforcement is hard to find anywhere else." - Seth M., Independent Pharmacist
1,500+
Audits Overseen
25+
Years Experience
24/7
Availability

Get Your Defense Strategy

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100% Confidential · No obligation · Attorney-client privilege applies