CVS Caremark Settles FTC Insulin Pricing Lawsuit: Key Developments And Industry Impact

CVS Caremark has reached a proposed settlement agreement with the Federal Trade Commission (FTC). The proposed agreement follows a high-profile FTC lawsuit filed in September 2024, which accused leading PBMs, including CVS Caremark, Cigna’s Express Scripts and UnitedHealth’s OptumRx, of engaging in anticompetitive and unfair rebating practices that drove up insulin prices for millions of Americans.

On March 23, 2026, the FTC and CVS Caremark jointly moved to withdraw from the adjudicative proceeding to allow the Commission to consider the proposed settlement agreement. The proposed consent agreement, which conforms to the requirements of Commission Rule of Practice 2.32, 16 C.F.R. § 2.32, has been fully executed by Complaint Counsel and the Caremark Respondents, and approved by the Bureaus of Competition and Consumer Protection.

This agreement closely follows the precedent set by Express Scripts’ February 2025 settlement with the FTC, which required a comprehensive overhaul of rebate pricing practices. That settlement is projected to reduce out-of-pocket drug costs by up to $7 billion over the next decade and specifically targeted the practice where drugmakers provide PBMs with post-dispensing discounts. Regulators have criticized this model for incentivizing higher list prices and steering patients toward more expensive drugs to generate larger rebates.

Industry sources indicate that CVS Caremark’s settlement closely mirrors the Express Scripts settlement framework, with final terms expected to be confirmed in the coming weeks. That deal was finalized two weeks after being proposed, and CVS Caremark’s could be signed into effect sooner.

CVS expects the settlement process ⁠to conclude in the coming weeks, but said final terms were still pending and would be confirmed once the settlement was officially finalized. While the proposed settlement between CVS Caremark and the FTC marks a significant development in the regulation of PBM practices, it remains essential to review the final settlement conditions before assessing the overall impact. The specific terms and implementation details will determine whether this agreement delivers meaningful benefits to consumers and the industry or if further action will be necessary. As the details emerge, stakeholders should closely monitor the situation to evaluate how these changes may affect compliance obligations, drug pricing strategies, and consumer access to essential medications.

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