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Docusign Envelope ID: 921 F7A24-D5CE-4BCC-9F3C-5E7844661266 current drug utilization mix to a new mix of utilized products that are therapeutically equivalent and are better aligned with the RIGHTWAY Formulary. (viii) Appeals. RIGHTWAY will provide Client Plan's with an appeals program as follows (the "Appeals Program"): (1) First Level Appeals: RIGHTWAY shall be responsible for conducting appeals relating to prescription drug benefit determinations (as related to Claim adjudication). Such reviews will be based on the Plan Documents with respect to coverage of prescription drug benefits only and shall not include a review of medical necessity as may be defined under the terms of the Plan; (2) Medical Necessity Reviews: RIGHTWAY may contract with an independent vendor or vendors for the processing of appeals resulting from a denial of authorization of pharmacy benefits where the Eligible Person is entitled to obtain a review of the denial by an independent physician specialist. Such appeals process shall in compliance with the procedures and timeframes specified under the Appeals Program. The decision of the independent vendor shall be final, subject to external review below, or available judicial review only for abuse of discretion; and (3) External Reviews: RIGHTWAY shall contract with independent review organizations to provide external review of benefit determinations that are subject to external review under ACA. The decision of the independent review organization shall be final and binding on the Plan and Eligible Person, subject only to any judicial review. (ix) Treatment Decisions. Client Plan's acknowledges that the decisions, in all circumstances, to prescribe and dispense any prescription drug shall be made solely by the prescribing physician or health care provider and the dispensing pharmacist, respectively. (x) Drug Interchange Programs. RIGHTWAY may implement drug interchange program(s) for selected prescriptions, under which Practitioners may be contacted to obtain approval for the drug interchange. (b) Care Complete Specialty Programs. Upon Client's election, RIGHTWAY will provide Eligible Persons access to a RIGHTWAY pharmacist who will provide coverage, financial assistance and clinical support specific to Specialty Drugs as well as coordination of fulfillment of such Specialty Drugs with the Specialty Pharmacy. The program includes two levels of support as follows: (i) Care Complete Specialty - Basic. Upon Client's election of the Care Complete Specialty — Basic program, RIGHTWAY will assist Eligible Persons in accessing publicly available Specialty Drug copay assistance, when available, for their Cost -Sharing amount. RIGHTWAY will also manage the claim adjudication process. (ii) Care Complete Specialty - Enhanced. Upon Client's election of the Care Complete Specialty — Enhanced program which includes enrollment in the Care Compete Specialty - Basic program, RIGHTWAY will assist Client by identifying additional Specialty Drug alternative funding programs and provide Client with the coverage support needed to enable those Eligible Persons that may meet the financial requirements access to such programs as well as assist Eligible Persons who may be eligible in the enrollment process. (c) Care Complete Diabetes Program. Upon Client's election and Eligible Person's enrollment in the Care Complete Diabetes program, a licensed pharmacist will assess enrolled 33 This document is CONFIDENTIAL AND PROPRIETARY to RIGHTWAY Healthcare, Inc. and may not be reproduced, transmitted, published, or disclosed to others without the prior written authorization of RIGHTWAY Healthcare, Inc.