Topic
340B
257 published works
Turtle Talk
Tribal Consultation Today: What Would 340B Rebates Mean for Tribal Clinics?
HRSA is testing a change that could require Tribal health clinics to pay more upfront for certain prescription drugs, then claim their 340B discount afterward. This is the agency’s second…
Agricultural Law & Rural Practice | Solo Small Firm & General Practice Section
HRSA’s New FQHC Scope of Project Manual Affects Provider-Patient Relationships, Arrangements with Other Providers and 340B Operations
On August 11, 2026, the Health Resources and Services Administration (“HRSA”) released its Health Center Program Scope of Project Policy Manual (“Scope Manual”), providing comprehensive guidance on what constitutes a…
GoodLifeSci
CMS’ CY 2027 OPPS and PFS Proposed Rules Include Major Changes to Reimbursement for 340B Hospitals, Data Reporting, and Digital Health
By Meenakshi Datta, Trevor L. Wear, Catherine Y. Starks, Elizabeth Hardcastle, Rina Mady, Kim Schroer, Taylor Andelman, George Maliha, Allie K. Gilchrist
In July 2026, the Centers for Medicare & Medicaid Services (CMS or Agency) published two of their annual proposed rules: the CY 2027 Hospital Outpatient Prospective Payment System and Ambulatory…
Government Enforcement, Compliance & Investigations Report
How 340B Overcharges Result in False Claims Act Problems
We just released Episode 46 of the False Claims Act Insights podcast where Robert Hess and I talk about a Ninth Circuit case that opens to door to False Claims…
Drug & Device Law
We Were Wrong On 340B, Sort Of
We reported a couple of months ago on important decisions in the Fourth Circuit that invalidated state laws in West Virginia and Maryland purporting to compel pharmaceutical manufacturers to deliver…
Pennsylvania Divorce and Domestic Relations Blog
Raising Your Four-Year-Old on a $1,000 a day.
By Mark Ashton
Child support is a challenge these days. When support guidelines were first introduced in the 1980s, the vast majority of Americans worked W-2 jobs where they made a salary or…
Drug & Device Law
Next Stop SCOTUS? Fourth Circuit Creates Split On 340B Contract Pharmacies
Can states compel prescription drug manufacturers to deliver steeply discounted medicines to unlimited numbers of pharmacies? That is the issue that has been kicking around federal courts for a few…
Kang Haggerty Firm News
Legal Intelligencer: No Private Right? No Problem: Ninth Circuit Lets 340B Pricing Claims Proceed Under the False Claims Act
The U.S. Court of Appeals for the Ninth Circuit just disrupted that assumption. In Adventist Health System of West v. AbbVie, the court revived a qui tam action alleging systemic…
The FCA Insider
Ninth Circuit Ruling in FCA Case Predicated on 340B Pricing Violations Has Significant Implications for Pharma Manufacturers
By Craig B. Bleifer, Michael J. Podberesky, Jessica L. Vaughn, Ph.D.
On March 17, 2026, the United States Court of Appeals for the Ninth Circuit issued a significant opinion in United States ex rel. Adventist Health System of West v. AbbVie…
Consumer Financial Services Law Monitor
Fourth Circuit Blocks West Virginia’s 340B Contract Pharmacy Law as Likely Preempted
By Virginia Bell Flynn, Chad R. Fuller, Jessamyn Vedro
The Fourth Circuit has affirmed a preliminary injunction barring enforcement of West Virginia’s S.B. 325, which sought to restrict how drug manufacturers implement contract pharmacy policies under the federal 340B…