Toby C Frost

Dr. Toby C Frost

Frost Pharmacy and Regulatory Advising, LLC
716 Barnsley Rd
Farragut, TN 37934
Mobile: 865-951-3925
Office: 865-951-3925
Introduction

Dr. T.C. Frost is a pharmacy law expert and Doctor of Pharmacy with twenty-plus years of pharmacy operations, executive compliance leadership, and direct PBM contracting experience. PharmD, JD in Health Law, and Certified Pharmacy Benefits Specialist. Passed the Uniform Bar Examination, February 2026. Founded and scaled a multi-location independent pharmacy to approximately twelve million dollars in annual revenue. Adjunct Professor of Clinical Pharmacy at the University of Tennessee Health Science Center. Author of forthcoming law review scholarship on ERISA preemption and PBM market foreclosure. Available as a consulting or testifying expert nationwide.


Areas of Expertise
  • Drug Abuse
  • Health Care Economics
  • Health Care Litigation
  • HIPAA
  • Managed Care & HMOs
  • Medical Billing
  • Medical Credentialing
  • Medical Fraud
  • Medical Toxicology
  • Pharmacology

Expert Background
Q: Please list your professional accreditations, degrees, licenses, and certificates granted:
A: Doctor of Pharmacy (PharmD), University of Tennessee Health Science Center, 2002.
Juris Doctor (JD), Health Law Concentration, University of Tennessee College of Law, 2021.
Tennessee Pharmacist License No. 12080; active and in good standing.
Certified Pharmacy Benefits Specialist (CPBS), Pharmacy Benefits Institute of America, TransparentRx, and University of Kentucky College of Pharmacy.
APhA Diabetes Educator Certification.
APhA Immunization Certification.
APhA Asthma Certification.
LexisNexis Certification.
USP 795, 797, and 800 compliance training.
ACHC accreditation training.
Uniform Bar Examination passed, February 2026.
Q: Please list your affiliations or memberships in any professional and/or industry organizations:
A: American Bar Association.
Tennessee Bar Association.
Federal Bar Association.
American Health Law Association.
American Society for Pharmacy Law.
Tennessee Pharmacists Association.
Phi Alpha Delta Law Fraternity.
Kappa Psi Pharmacy Fraternity.
Q: Please list any teaching or speaking experience you have had, including subject matter:
A: Adjunct Professor of Clinical Pharmacy, University of Tennessee Health Science Center, 2014 to present. Teaches Advanced Community Pharmacy and Compounding and Regulatory Compliance to PharmD candidates. Subject matter includes USP 795, 797, and 800 compounding standards; regulatory frameworks governing community and compounding pharmacy practice; pharmacist standard of care; and pharmacy law fundamentals.

Continuing education programming available for state pharmacy associations, bar association sections, and industry conferences on ERISA preemption, PBM regulation, and pharmacy law, calibrated to pharmacist or attorney audiences.

Has provided PBM regulatory input to Tennessee policymakers on PBM-related questions.
Q: Have any of your accreditations ever been investigated, suspended or removed? (if yes, explain)
A: No. Tennessee Pharmacist License No. 12080 has been continuously active and in good standing with no disciplinary history. No professional accreditation, license, or certification has been investigated, suspended, or removed.
Q: On how many occasions have you been retained as an expert?
A: No prior retained expert engagements. Available as a first-time expert witness with twenty-plus years of pharmacy operations leadership, executive compliance experience, and direct PBM contracting experience supporting substantive expert testimony in pharmacy and PBM matters.
Q: For what area(s) of expertise have you been retained as an expert?
A: No prior expert retention to date. Available for retention in the following areas: PBM contracting, network admission, credentialing, and recredentialing; ERISA Section 514 preemption analysis; pharmacy reimbursement methodology, MAC pricing, and spread-pricing analysis; pharmacy compounding compliance under USP 795, 797, and 800; pharmacy standard of care; PSAO selection and pharmacy-payer contract negotiation; DEA and FDA audit defense; State Board of Pharmacy disciplinary proceedings; healthcare antitrust as applied to PBM vertical integration; and False Claims Act and qui tam matters in pharmacy benefits.
Q: In what percentage of your cases were you retained by the plaintiff?
A: Not applicable. No prior retentions. Available for plaintiff engagements.
Q: In what percentage of your cases were you retained by the defendant?
A: Not applicable. No prior retentions. Available for defense engagements.
Q: On how many occasions have you had your deposition taken?
A: Not applicable. No prior depositions.
Q: When was the last time you had your deposition taken?
A: Not applicable. No prior depositions.
Q: On how many occasions have you been qualified by a court to give expert testimony?
A: None to date.
Q: On how many occasions have you testified as an expert in court or before an arbitrator?
A: None to date.
Q: For how many years have you worked with the legal industry as an expert?
A: First year of retained expert availability. Twenty-plus years of pharmacy operations, executive compliance leadership, and direct PBM contracting experience directly supporting expert testimony in pharmacy and PBM matters. Approximately three years of law clerk experience (Moore & Brooks, 2020 to 2023; Baker Donelson via TruGreen engagement, 2021), Juris Doctor in Health Law (2021), and consultative input to Tennessee policymakers on PBM regulatory questions.
Q: What services do you offer? (E.g.: consulting, testing, reports, site inspections etc.)
A: Case analysis. Expert reports. Consulting expert services. Testifying expert services. Deposition testimony. Trial testimony. Regulatory affidavits. Administrative proceedings testimony. Arbitration testimony. PBM contract pricing forensics. Pharmacy compliance assessment. PSAO and pharmacy-payer contract review. Pharmacy standard of care assessment. ERISA preemption analysis. Healthcare antitrust analysis as applied to PBM conduct. Pharmacy and PBM litigation strategy support under counsel direction.
Q: What is your hourly rate to consult with an attorney?
A: $300/hour
Q: What is your hourly rate to review documents?
A: $275/hour
Q: What is your hourly rate to provide deposition testimony?
A: $400/hour
Q: What is your hourly rate to provide testimony at trial?
A: $475/hour
Q: Please list any fees other than those stated above (E.g.: travel expenses, copy fees, etc.)
A: Travel time billed at the applicable consulting rate. Travel expenses (airfare, lodging, ground transportation) billed at actual cost. Document reproduction, exhibits preparation, and printing costs are billed at actual cost. Rush or expedited engagements (defined as those requiring completion within 72 hours of engagement acceptance) are billed at 1.25 times the applicable rate. Retainer required for all substantive engagements. Retainer balance refundable for unused fees at engagement close.


References

Available Upon Request