On Feb. 3, 2025, H.R.7148 the Consolidated Appropriations Act, 2026[1] ( CAA) became law. Included in the Act, there were many new provisions surrounding the pharmacy industry emphasizing pharmacy contracting, pharmacy benefit managers (PBMs), Medicare Part D sponsors, and employer-sponsored Employer Retirement Income Security Act (ERISA) plans. This brief will focus on Section 6223 and 6224 of the Act, which centers on Medicare Part D. A second installment will discuss ERISA plans at a later date. This is a high-level summary, and we recommend referencing the actual Act for details to determine how this new law may impact your organization.
Executive Summary
The new law has introduced new requirements with a primary focus on increasing transparency among the relationships between PBMs, Prescription Drug Plan (PDP) sponsors,[2] and pharmacies. Section 6223 provides more definitive requirements for “any willing pharmacy” contracting terms and creates new designations for affiliate and non-affiliate pharmacies. It also engages federal oversight by allowing a pathway for pharmacies to report alleged violations of contract terms. Second, Section 6224 makes changes to Medicare Part D PBM compensation by only allowing payment for bona fide service fees (BFSFs) and requiring the pass through of rebates and discounts received from a drug manufacturer to the PDP sponsor. This section also requires detailed reporting from the PBM to the PDP sponsor and to the secretary. There are also new oversight provisions across the pharmacy supply chain that introduce more stringent audit rights for PDP sponsors of PBMs, enforcement mechanisms for federal entities, and pathways for parties to report alleged violations.
Section 6223 — Assuring Pharmacy Access and Choice for Medicare Beneficiaries
Any Willing Pharmacy[3]
The CAA expands on existing requirements surrounding “Any Willing Pharmacy,” introducing greater detail in the expectations between the PDP sponsor and the pharmacy. Specifically, contract terms and conditions that “shall be reasonable and relevant according to standards established by the Secretary.”[4] In order to establish these standards, the secretary will issue a request for information to gather information regarding pharmacy and PDP contracting attributes, such as PDP and network pharmacy contracting practices, reimbursements, quality measures, PDP restrictions or limitations on dispensing of Part D medications by network pharmacies, auditing practices, and other considerations in contract terms and conditions between PDPs and network pharmacies.
Notable Dates
The Request for Information will be issued no later than April 1, 2027. The standards for “reasonable and relevant contract terms and conditions” will be established no later than the first Monday in April of 2028. This will be applicable for plan year Jan. 1, 2029.
Essential Retail Pharmacies[5]
Before discussing the new provisions for “Essential Retail Pharmacies,” an introduction to new definitions from the Act will need to be considered:
“Affiliate – The term ‘affiliate’ means, with respect to any pharmacy benefit manager or PDP sponsor, any entity that, directly or indirectly-
(i) owns or is owned by, controls or is controlled by, or otherwise related in any ownership structure to such pharmacy benefit manager or PDP sponsor; or
(ii) acts as a contractor, principal, or agent to such pharmacy benefit manager or PDP sponsor, insofar as such contractor, principal, or agent performs any of the functions described (C) [pharmacy benefit manager].”[6]
“Essential Retail Pharmacy means, with respect to a plan year, a retail pharmacy that—
(A) is not a pharmacy that is an affiliate as defined in paragraph (4); and
(B) is located in—
(i) a rural area in which there is no other retail pharmacy within 10 miles, as determined by the Secretary;
(ii) a suburban area in which there is no other retail pharmacy within 2 miles, as determined by the Secretary; or
(iii) an urban area in which there is no other retail pharmacy within 1 mile, as determined by the Secretary.”[7]
“Pharmacy Benefit Manager — The term ‘pharmacy benefit manager’ means any person or entity that, either directly or through an intermediary, acts as a price negotiator or group purchaser on behalf of a PDP sponsor or prescription drug plan, or manages the prescription drug benefits provided by such sponsor or plan, including the processing and payment of claims for prescription drugs, the performance of drug utilization review, the processing of drug prior authorization requests, the adjudication of appeals or grievances related to the prescription drug benefit, contracting with network pharmacies, controlling the cost of covered part D drugs, or the provision of related services. Such term includes any person or entity that carries out one or more of the activities described in the preceding sentence, irrespective of whether such person or entity calls itself a ‘pharmacy benefit manager.”[8]
The essential retail pharmacy is differentiated by not being an affiliate and has different standards than the existing convenient access standards to network pharmacies as currently described in 42 Code of Federal Regulations (CFR) 423.120(a)(1).[9] Compared to the current service area standards, essential retail pharmacies have different geographic radius, rural is 15 miles vs. 10 miles, suburban is five miles vs. two miles, and urban is two miles vs. one mile for network pharmacies vs. essential retail pharmacies, respectively. The secretary will publish lists of pharmacies that shall be considered an essential retail pharmacy.
Reports will be published by the secretary comparing essential retail pharmacies to non-essential retail pharmacies beginning around Jan. 1, 2028 to discuss trends for PDPs and Medicare Advantage (MA) organizations, such as pharmacy financials (e.g., ingredient cost, dispense fees, other fees), amounts paid by essential retail pharmacies, network participation (e.g., preferred), number of essential retail pharmacies, cost-sharing comparisons, volume dispensed, and types of drugs dispensed (e.g., generics, specialty drugs).
PDP sponsors offering prescription drug plans and MA organizations offering Medicare Advantage Prescription Drug Plans (MA-PD) will be required to report “a list of retail pharmacies that are affiliates of the sponsor or organization, or are affiliates of a pharmacy benefit manager acting on behalf of such sponsor or organization.”[10] They will also need to report “incentive payments and other fees paid… to pharmacies.”[11]
Notable Dates
At the beginning of plan year 2027, PDP sponsors will need to submit information regarding incentive payment to pharmacies to the secretary, details are pending regarding format and timeframe. Beginning plan year 2028, PDP sponsors will need to begin submitting lists of essential retail pharmacies. Essential retail pharmacy trend reports are to be published by the secretary for plan years beginning on or after Jan. 1, 2028.
Enforcement[12]
This new section introduces the ability of pharmacies to raise “an allegation of a violation… of the standards for reasonable and relevant contract terms and conditions”[13] to the secretary. Enabling a pathway through a federal regulatory body to submit such concerns. The pharmacy is limited to one submission per contract per plan year with exceptions if a contract modification occurs.
If the secretary finds a PDP sponsor or MA organization[14] that has violated the “standards for reasonable and relevant contract terms and conditions,”[15] then “civil monetary penalties or other intermediate sanctions”[16] may be applied. It is an expectation that the PDP “sponsor has a written agreement with the PDP sponsor under which the pharmacy benefit manager agrees to reimburse the PDP sponsor for any amounts paid by the Sponsor… to the Secretary… if the violation was related to a responsibility delegated to the pharmacy benefit manager by such PDP sponsor.”[17]
Notable Dates
The process for pharmacies to submit allegations will be implemented by the secretary no later than Jan. 1, 2029.
Section 6224 — Modernizing and Ensuring PBM Accountability
The CAA adds a new subsection, focusing on the relationship between PDP sponsors and MA organizations with PBMs. It introduces many new detailed provisions surrounding the financial aspects of PDP and PBM relationships, reporting requirements, responsibilities across additional federal entities that will be involved with evaluating remuneration, greater transparency in pricing and relationships with drug manufacturers, and audit rights. Furthermore, it discusses engaging the Government Accountability Office (GAO) to conduct a study of prescription drug pricing in the retail prescription supply chain and the Medicare Payment Advisory Commission (MedPAC) to submit reports to Congress related to agreements with PBMs and MA-PDs.
The new section[18] begins by discussing the parameters of the written agreement between the PBM and affiliate(s) (if applicable)[19] with the PDP sponsor and corresponding prescription drug plans:
Agreements With Pharmacy Benefit Managers[20]
BFSFs[21]
A definition for BFSF was introduced:
“Bona Fide Service Fee —The term ‘bona fide service fee’ means a fee that is reflective of the fair market value (as specified by the Secretary, through notice and comment rulemaking) for a bona fide, itemized service actually performed on behalf of an entity, that the entity would otherwise perform (or contract for) in the absence of the service arrangement and that is not passed on in whole or in part to a client or customer, whether or not the entity takes title to the drug. Such fee must be a flat dollar amount and shall not be directly or indirectly based on, or contingent upon—
(i) drug price, such as wholesale acquisition cost or drug benchmark price (such as average wholesale price);
(ii) the amount of discounts, rebates, fees, or other direct or indirect remuneration with respect to covered part D drugs dispensed to enrollees in a prescription drug plan, except as permitted pursuant to paragraph (1)(A)(ii);
(iii) coverage or formulary placement decisions or the volume or value of any referrals or business generated between the parties to the arrangement; or
(iv) any other amounts or methodologies prohibited by the Secretary.”[22]
PBMs will only be allowed to receive BFSFs “in connection with the utilization of covered part D drugs”[23] as income from the PDP sponsor. The PBM may receive “incentive fees” — to be defined by the secretary — from the PDP sponsor even if they do not fit in the definition stated above, so long as, the incentive fee “is a flat dollar amount, is consistent with fair market value, is related to services actually performed by the pharmacy benefit manager or affiliate… connected to the utilization of covered part D drugs.”[24] The PBM may also receive rebates from drug manufacturers “if they are fully passed through to a PDP sponsor”[25] and follow direct and indirect remuneration reporting rules. There are many areas that will need further clarity, such as defining fair market value, the services associated with the utilization of covered part D drugs, and the types of services that are performed by a PBM in order for the industry to implement these new concepts.
There is also increased scrutiny of remuneration that is paid to or retained between PBMs and essentially any other entity that “is involved with dispensing or utilization of covered Part D drugs.”[26] This new section provides the secretary the authority to review and assess the appropriateness of the remuneration across these entities with assistance from the Office of Inspector General of the Department of Health and Human Services. If violations are identified, the remuneration will be disgorged from the PBM and paid to the PDP sponsor.
To ensure there is accountability between the PBM and any affiliates, this section requires that the PBM enter into written agreements with them. These agreements will require affiliates to “identify and disgorge” remuneration to the PBM if determined violations have been identified. The PBM must attest to the secretary that the written agreements have been established.
Transparency Regarding Guarantees and Cost Performance Evaluations[27]
To bring greater clarity to PDP sponsors surrounding contractual pricing guarantees and performance measures, the new provision requires the PBM provide definition of terms and methodology to calculate these parameters. For example, there are specific definitions for generic drug and brand name drug that are required to follow 42 CFR §423.4 and a need for the PBM to define terms, such as “specialty drug,”[28] “rebate,”[29] and “discount.”[30] The provisions also state that exclusions from the price guarantees or performance measure also need to be described in the agreement.
Wholesale Acquisition Cost is the recognized pricing benchmark in this subsection, however if an alternative is used the PBM must “calculate and provide a wholesale acquisition cost-based equivalent to the pricing guarantee or other cost performance measure.”[31] These provisions provide more definitive parameters for PDP sponsors to interpret how the PBM is calculating these measures.
Provision of Information[32]
This section creates new requirements for the PBMs to provide reporting to the PDP sponsor and to the Secretary. This will be an annual report based on previous plan year’s data for each of the PDP sponsor’s plans, which will be due July 1, 2028 (plan year 2027 data). There are several new reports that are summarized at a high level below:
Reporting Requirements Framework
1. Dispensing Report – This report will provide details surrounding each of the drugs that were dispensed. A summary of the information in this report includes:
- “Brand, generic, or non-proprietary name, and National Drug Code.”[33] Drug dispensing attributes, such as number of plan enrollees who were dispensed the drugs
- Type of pharmacy that dispensed the drug
- Average wholesale acquisition cost
- Average wholesale price
- Out-of-pocket spending
- Total rebates paid by the manufacturer
- Direct and indirect remuneration
- Average pharmacy reimbursement by dispensing channel
- Average National Average Drug Acquisition Cost (NADAC)
- Revenue from the manufacturer that was retained by the PBM or affiliate
2. Affiliate Reporting for Retail, Mail-Order, or Specialty (if applicable) – The PBM will be required to produce a report regarding the drugs that were dispensed. A summary of the information in this report includes:
- Percentage of total prescriptions that were dispensed by an affiliate by drug.
- Range of combined costs paid by plan and enrollee per 30-day and 90-day supplies that are not an affiliate pharmacy, subsequently the same parameters for a pharmacy that is an affiliate.
- Lowest combined cost for plan and enrollee per 30-day and 90-day from any pharmacy.
- Difference in average acquisition cost of the affiliate compared to average NADAC.
- Drugs dispensed under 340B where the PBM or affiliate has a contract with the covered entity in the service area of the plan.
3. Brand vs. Generics on Formulary – Regarding certain brand drugs on formulary the following information will be reported:
- Generic alternatives that are not covered, on the same tier, or a higher tier than the brand. Additionally, if there is utilization management the generic is subject to that the brand drug is not.
- The estimated average cost sharing for the brand drug for a 30-day supply and the corresponding cost sharing for the generic alternative if it had been on the same tier as the brand.
- Written justification for the favorable coverage of the brand compared to the generic.
- Number of generics on the market that are equivalent to the brand.
4. Biologics vs. Biosimilars on Formulary – Regarding certain biologic drugs on formulary the same information as provided for brand name drugs will be reported, however comparing the biologic to like biosimilars.
5. Total gross spending on covered part D drugs at the plan level before any rebates or discounts.
6. Total amount retained by the PBM or any affiliate(s) at the plan level, inclusive of BFSFs.
7. The total net spending on covered part D drugs.
8. An explanation of benefit designs that encourage enrollees to fill prescriptions at affiliate pharmacies (e.g., mail-order, specialty, auto-refill programs at mail or retail).
9. Broker and Consultant Compensation – The PBM will now be required to provide a list of entities (e.g., brokers, consultants) who receive compensation from the PBM for services offered to PDP sponsors for PBM services. The amount of compensation provided to each entity will be reported. Furthermore, the methodology which is used to calculate the compensation needs to be provided.
10. A list of all affiliates of the PBM.
11. A summary document of all the above information which will be determined by the Secretary.
Written Explanation of Contracts or Agreements with Manufacturers[34]
PBMs will now be required to provide a written explanation to the PDP sponsor of contracts and agreements that are made between the PBM or an affiliate with a manufacturer, including agents of the manufacturer. This explanation will describe any contingencies (e.g., formulary placement, utilization management) to receive financial incentives in the agreement with the manufacturer related to “all covered part D drugs or other prescription drugs.”[35][36] The explanation(s) must be certified by the CEO, chief financial officer (CFO), or general counsel — or designee of these officials — of the PBM and provided to the PDP sponsor within 30 days of finalization with the manufacturer.
Audit Rights[37]
Most current PBM contracts allow PDP sponsors to audit, however these new rights provide greater specificity in timelines, transparency, auditor choice, and include the PBM’s affiliate(s) if applicable. These audit rights enable the PBM to validate the information discussed above in the “Provision of Information”[38] section.
Timeline
- The PDP sponsor can audit the PBM “not less than once per year”[39] to ensure compliance with the terms and conditions of the written agreement.
- The PBM must provide requested information by the auditor within six months of the initiation of the audit and respond to additional requests for information within 30 days.
Auditor
- The PDP sponsor can choose the auditor and the PBM cannot influence the selection.
Provision of Information
- To validate the “provision of information,” the PBM will need to submit to the auditor “all records, data, contracts, and other information.”[40]
- This will be subject to reasonableness to protect proprietary information of the PBM from being disclosed.
Information from Affiliates
- The PBM must also provide the auditor with any information pertaining to affiliate(s) associated with the provision of information.
Enforcement[41]
This new section discusses the flow of penalties across the PBM and their affiliate(s) if applicable, the PDP sponsor, and the secretary. It also discusses how violations are to be reported and protections for those who identify violations.
As previously discussed in the BFSFs”section above, any violations identified by the secretary the remuneration will be disgorged from the PBM and paid to the PDP sponsor. However, these amounts will subsequently be disgorged from the PDP sponsor to the secretary.
The written agreements between PDP sponsors and PBMs and their affiliate(s) if applicable will require the PBM to reimburse the PDP sponsor for any civil monetary penalties that incur as a result of the PBM not fulfilling a requirement that was applicable under the agreement as described in the “Agreements with Pharmacy Benefit Mangers” section above. Additionally, the written agreement shall have “punitive remedies for breach of contract”[[42]] when a PBM does not meet the requirements.
To provide a pathway for reporting alleged violations, the secretary will develop a mechanism to enable individuals to report any alleged violations confidentially. They will be protected by anti-retaliation and anti-coercion laws.
Certification of Compliance[43]
Annually, each PDP sponsor will need to provide an annual certification of compliance to these provisions to the secretary. Details of the information that will be required and timeframe are to be determined.
Rules of Construction[44]
This subsection addresses that these new provisions are not to change existing payment models that occur in the pharmacy supply chain such as dispensing fees and reimbursements for ingredient costs for pharmacies, discounts between pharmacies and wholesalers, or to modify existing regulations “related to pharmacy payment, reimbursement, or dispensing fees.”[[45]]
Standard Formats[46]
By June 1, 2027, the standards and formats of the annual reports for PBMs will be defined.
Confidentiality[47]
The information provided by the PBM or their affiliate(s) if applicable, PDP sponsor, or a pharmacy that is not publicly available or available for purchase is confidential. The secretary or PDP sponsor shall not disclose this information except for select circumstances (e.g., review by other federal entities).
GAO Study and Report on Price-Related Compensation Across the Supply Chain[48]
The GAO has been tasked with providing a report to Congress by Feb. 2, 2028, which focuses on many financial and operational aspects of drug pricing, transactions, and business to business relationships related to the pharmacy supply chain for PDP sponsors. This report is to include not only PBMs and the PDP sponsors, but other intermediaries, such as drug wholesalers, pharmacies, manufacturers, pharmacy services administrative organizations, and other entities (e.g., brokers, consultants) involved with advising PDP sponsors. The results of the study shall provide recommendations to Congress for legislation or administrative action.
MedPAC Reports on Agreements with Pharmacy Benefit Managers with Respect to Prescription Drug Plans and MA-PD Plans[49]
MedPAC has been tasked with two reports (Initial and Final), that will discuss trends related to the information that has been submitted by the PBMs. The report will analyze the data to determine how PBM agreements may have financial implications such as enrollee out-of-pocket spending and pharmacy reimbursement. The Commission may make recommendations based on discoveries from this analysis.
This report will be provided no later than “the first March 15…2 years after the date…the Secretary makes the data available.”[50] The final report will be provided 2 years after the initial report which will describe any changes that have been observed since the initial report and any further recommendations.
Conclusion
The CAA of 2026 introduces significant regulatory changes to support transparency and accountability within the pharmacy and healthcare sectors. By addressing the relationships between PBMs, PDP Sponsors, pharmacies, and other participants across the pharmacy supply chain, the legislation seeks to create a more transparent system for all involved parties and introduces oversight by federal authorities. As the provisions of this law are implemented, stakeholders will need to ensure their organizations are compliant with these new requirements and implementations are thorough as violations can result in penalties.
References
[1] Consolidated Appropriations Act, 2026, H.R. 7148, 119th Cong. (2026), available at
https://www.congress.gov/bill/119th-congress/house-bill/7148/text
[2] The term “PDP sponsors” or “PDPs” is used throughout this summary and represents PDP sponsors offering prescription drug plans and MA organizations offering Medicare Advantage Prescription Drug Plans per 42 U.S.C. § 1395w‑27(f)(3) (2024).
[3] Consolidated Appropriations Act, 2026, Pub. L. No. 119‑75, § 1860D‑4(b)(1), 140 Stat. ___ (2026).
[4] Pub. L. No. 119‑75, § 6223(a), 140 Stat. ___ (2026).
[5] Pub. L. No. 119‑75, § 6223(b), 140 Stat. ___ (2026).
[6] Pub. L. No. 119‑75, § 1860D‑12(h)(7), 140 Stat. ___ (2026).
[7] Pub. L. No. 119‑75, § 1860D‑42(e)(2), 140 Stat. ___ (2026).
[8] Pub. L. No. 119‑75, § 1860D‑12(h)(7), 140 Stat. ___ (2026).
[9] 42 C.F.R. § 423.120(a)(1) (2026).
[10] Pub. L. No. 119‑75, § 1860D‑42(e)(3)(B), 140 Stat. ___ (2026).
[11] Pub. L. No. 119‑75, § 1860D‑42(e)(3)(C), 140 Stat. ___ (2026).
[12] Pub. L. No. 119‑75, § 6223(c), 140 Stat. ___ (2026).
[13] Pub. L. No. 119‑75, § 1860D‑4(b)(1)(F)(i)(I), 140 Stat. ___ (2026).
[14] Pub. L. No. 119‑75, § 1857(f)(3)(F), 140 Stat. ___ (2026).
[15] Pub. L. No. 119‑75, § 1860D‑4(b)(1)(F)(iii)(I), 140 Stat. ___ (2026).
[16] Ibid.
[17] Pub. L. No. 119‑75, § 1860D‑12(b)(9), 140 Stat. ___ (2026).
[18] Pub. L. No. 119‑75, § 6224(a), 140 Stat. ___ (2026).
[19] It should be assumed when “PBM” is mentioned in this summary that the requirement for the PBM will likely be applicable to any affiliate(s) of the PBM as well.
[20] Pub. L. No. 119‑75, § 1860D‑12(h)(1), 140 Stat. ___ (2026).
[21] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(A), 140 Stat. ___ (2026).
[22]Pub. L. No. 119‑75, § 1860D‑12(h)(7)(B), 140 Stat. ___ (2026).
[23] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(A)(i), 140 Stat. ___ (2026).
[24] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(A)(ii), 140 Stat. ___ (2026).
[25] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(A)(iii), 140 Stat. ___ (2026).
[26] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(A)(iv), 140 Stat. ___ (2026).
[27] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(B), 140 Stat. ___ (2026).
[28] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(B)(i)(III), 140 Stat. ___ (2026).
[29] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(B)(i)(IV), 140 Stat. ___ (2026).
[30] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(B)(i)(V), 140 Stat. ___ (2026).
[31] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(B)(iii), 140 Stat. ___ (2026).
[32] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(C), 140 Stat. ___ (2026).
[33] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(C)(i)(I)(aa), 140 Stat. ___ (2026).
[34] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(C)(ii), 140 Stat. ___ (2026).
[35] ‘[O]ther prescription drugs’ means prescription drugs covered as supplemental benefits under this part or prescription drugs paid outside of this part. Pub. L. No. 119‑75, § 1860D‑12(h)(1)(C)(ii)(III), 140 Stat. ___ (2026).
[36] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(C)(ii)(II)(aa), 140 Stat. ___ (2026).
[37] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(D), 140 Stat. ___ (2026).
[38] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(C), 140 Stat. ___ (2026).
[39] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(D)(i), 140 Stat. ___ (2026).
[40] Pub. L. No. 119‑75, § 1860D‑12(h)(1)(D)(iii), 140 Stat. ___ (2026).
[41] Pub. L. No. 119‑75, § 1860D‑12(h)(2), 140 Stat. ___ (2026).
[42] Pub. L. No. 119‑75, § 1860D‑12(h)(2)(iii), 140 Stat. ___ (2026).
[43] Pub. L. No. 119‑75, § 1860D‑12(h)(3), 140 Stat. ___ (2026).
[44] Pub. L. No. 119‑75, § 1860D‑12(h)(4), 140 Stat. ___ (2026).
[45] Pub. L. No. 119‑75, § 1860D‑12(h)(4)(B), 140 Stat. ___ (2026).
[46] Pub. L. No. 119‑75, § 1860D‑12(h)(5), 140 Stat. ___ (2026).
[47] Pub. L. No. 119‑75, § 1860D‑12(h)(6), 140 Stat. ___ (2026).
[48] Pub. L. No. 119‑75, § 6224(b), 140 Stat. ___ (2026).
[49] Pub. L. No. 119‑75, § 6224(c), 140 Stat. ___ (2026).
[50] Pub. L. No. 119‑75, § 6224(c)(1)(A), 140 Stat. ___ (2026).
© Copyright 2026. The views expressed herein are those of the author(s) and not necessarily the views of Ankura Consulting Group, LLC., its management, its subsidiaries, its affiliates, or its other professionals. Ankura is not a law firm and cannot provide legal advice.
