Key Takeaways: The New York State Board of Pharmacy (NYBOP) issued guidance in December 2025 requiring licensure both for pharmacies and for each individual pharmacist participating in shared pharmacy services arrangements when servicing New York patients. Nonresident pharmacy registration alone is no longer sufficient to satisfy shared services compliance. While this requirement becomes effective May 22, 2026, organizations should not delay taking action now. A proactive assessment and timely remediation of any licensure gaps will be critical to ensuring compliance moving forward. What Organizations Should Be Doing Now Evaluate your shared services model to identify where operations may be impacted; Confirm that all pharmacists supporting or involved in New York operations, including remote personnel, hold appropriate licensure and identify any gaps; Implement proactive compliance measures for any

Polsinelli is pleased to share the Health Care Reimbursement Newsletter. This publication contains articles and insight into issues that affect Reimbursement. In this issue: Steps Congress May Take To Fix Reimbursement in 2025 Six Updates to Provider Enrollment in 2024 You Need to Know Utilization Management Changes to Medicare Advantage New Year, New 340B Program? Manufacturers Seek to Change the 340B Program Landscape Reimbursement Perspectives from the Host of The 10 Minute HealthBizCast The Latest in Government Audits: Three Lessons for Providers Medicaid in 2025: What Stays, What Changes and How to Prepare Continued Focus on the No Surprises Act and Hospital Price Transparency What You Need to Know About Home Health & Hospice Reimbursement in 2025 CMS Updates its Interpretation of the 60-Day Overpayment Rule IPPS Highlights Medicare Physician Fee Schedule Skilled Nursing Facility