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Event

FTC insulin case against the three largest PBMs

In September 2024 the FTC sued Express Scripts, Caremark and Optum Rx over insulin rebates; all three denied the allegations. Express Scripts settled in February 2026; a Caremark order was published for comment on 5 August 2026; in June 2026 the FTC paused its case against Optum Rx to consider a proposed settlement. We read no final order for Caremark or Optum Rx.

4 links, 3 backed by primary records

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Dates
Sep 2024 –

A consent order is a settlement. The FTC’s own analysis describes the complaint’s allegations; it is not a finding of fact.

Connections 4

involved

  • U.S. Federal Trade Commission plaintiff; alleges the rebating practices inflated insulin list prices; the three companies denied the allegations Primary record 1
  • The Cigna Group Express Scripts: agreed in February 2026 to a ten-year consent order Primary record 1
  • CVS Health Caremark: proposed consent order published 5 August 2026 Primary record 2
  • UnitedHealth Group Optum Rx: the FTC paused the case in June 2026 to consider a proposed consent agreement; terms not read Scholarship & press 3
Timeline 1 date
  1. Sep 2024 – FTC insulin case against the three largest PBMs
Proof 3 sources
  1. Express Scripts, Inc., et al.; Analysis of Agreement Containing Consent Order To Aid Public Comment, Federal Register 91 FR (12 February 2026), U.S. Federal Trade Commission, 12 Feb 2026. Primary record
    In September 2024, the FTC sued the three largest PBMs—Express Scripts, Caremark, and Optum—and their affiliated GPOs.
    The Proposed Order, which lasts ten years from the Implementation Date, contains the following provisions
  2. Caremark and Zinc Health Services; Analysis of Proposed Agreement Containing Consent Order To Aid Public Comment, Federal Register 91 FR (5 August 2026), U.S. Federal Trade Commission, 5 Aug 2026. Primary record
    The Complaint alleges that Caremark Respondents have engaged in anticompetitive and unfair rebating practices that artificially inflated the list price of insulin drugs
  3. UnitedHealth, FTC reach proposed settlement in insulin case, Healthcare Dive, 12 Jun 2026. Scholarship & press
    The FTC is pausing the case against UnitedHealth’s PBM Optum Rx and its group purchasing organization Emisar.
    CVS’ Caremark, Express Scripts and Optum Rx have denied the agency’s allegations.
Page history 3 changes
  1. Second revision of Too Big to Fail: the FTC's 1917 finding, the 1952 report's seven firms, the 1984 hearing record, and corrected cards for Spirit, beef, tickets, Google and the final verdictAlibek05663c47
  2. Revise Too Big to Fail after the skeptic's review: read to 2 November 2026, a verdict card that separates findings from shares, the 1929 fight with its scandal and the board's stand, and sources for every cardAlibekc819f2cb
  3. Add the story Too Big to Fail: Standard Oil's stockholders, the phrase's origin in 1984, and market-by-market cases to November 2026Alibekaa9c434d

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