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Ashley Seibler is an associate in the Corporate Department and a member of the Health Care Group. Ashley handles a variety of corporate and transactional matters for clients in the health care and life sciences industries, including hospitals, physician groups, management/service organizations, life sciences companies, not-for-profit organizations, private equity firms and other financial institutions.

Ashley advises clients on mergers and acquisitions, joint ventures and strategic partnerships, vendor/service relationships, payor contracting, risk management, commercial dispute resolution, general corporate and business planning, and corporate governance matters. She previously worked as in-house counsel for a publicly traded medical device manufacturer.

On February 6, 2024, the New York State Department of Financial Services (“DFS”) released “pre-proposed” consolidated rulemaking related to the business practices of Pharmacy Benefit Managers (“PBMs”) licensed to operate in New York.

The draft regulations represent DFS’s latest attempt to promulgate PBM market conduct rules following state PBM licensing legislation that was enacted in 2021. In August 2023, DFS issued proposed regulations addressing consumer protection, conflicts of interest, and transparency issues related to PBM industry practices, including a dispensing fee of $10.18 per drug claim to be paid to pharmacies, but the proposed regulations were later withdrawn by the agency in October 2023 following the public comment period.

DFS’s announcement of the draft regulations and pre-proposal comment period stated that the draft regulations were informed by DFS’s “extensive outreach to industry, health plans, pharmacy groups, state and federal regulators, and the general public.”