Topic
340B
257 published works
To Be or Not to 340B Blog
CVS Caremark Reverses Planned Payment Cuts to 340B Providers
By Brenda Maloney Shafer, Richard Davis
CVS Caremark has decided not to implement reimbursement reductions which may have had adverse effects on Covered Entities and their retail pharmacies (including contract pharmacies). This decision, coupled with the…
To Be or Not to 340B Blog
We’re 340Back! Review of Major Developments to the 340B Program
By Brenda Maloney Shafer, Richard Davis
It's been a roller coaster two years for the 340B Program, and we are now back to review some of the major developments and program changes during this time. On…
Triage Health Law
Federal Court Held HHS Lacks the Authority to Impose Dramatic 340B Reimbursement Rate Reduction
On December 27, 2018, the provider community scored a major victory when the U.S. District Court for the District of Columbia held that the Medicare statute did not authorize the…
Health Industry Washington Watch
It’s Official: January 1, 2019 is Effective Date for HRSA 340B Ceiling Price/CMP Rule
The Health Resources and Services Administration (HRSA) has announced that it will implement its January 5, 2017 340B drug pricing program rule on January 1, 2019. The oft-delayed final rule…
Health Care and Life Sciences
HRSA Establishes January 1, 2019 Effective Date for 340B Ceiling Price and Civil Monetary Penalty Rule
By Alan J. Arville, Constance A. Wilkinson, James S. Tam, Lauren A. Farruggia
On November 30, 2018, the Department for Health and Human Services (“HHS”) Health Resources and Services Administration (“HRSA”) will publish its final rule to change the effective date for its…
Healthcare Law Insights
HHS proposes moving up the enforcement of 340B penalties to January 1, 2019
By Wakaba Tessier, Renee Zerbonia
On Wednesday, the Department of Health and Human Services (“HHS”) reversed course in its delay of implementing fines against drug manufacturers that intentionally overcharge 340B providers. In a notice of…
Health Industry Washington Watch
HRSA Changes Course on 340B Ceiling Price/CMP Rule Implementation, Proposes Accelerating Effective Date to January 1, 2019
After multiple implementation delays, the Health Resources and Services Administration (HRSA) now seeks to move up the effective date of its January 5, 2017 rule on 340B drug pricing program ceiling price…
Healthcare Law Blog
More Than 700 CEOs of Hospitals and Health Systems Write to Congress to Stop Cuts to the 340B Drug Pricing Program
By Jordan Grushkin, Melissa Gertler, Matthew Goldman
On October 2, 2018, the CEOs of more than 700 hospitals and health systems representing healthcare providers in all fifty states sent a letter to Congress (the “Letter”) in a…
Healthcare Law Blog
340B Drug Pricing Program Litigation Update: American Hospital Association, Et Al. v. Azar
On July 17, 2018, the Court of Appeals for the D.C. Circuit upheld the D.C. District Court’s decision to dismiss the lawsuit led by the American Hospital Association, the Association of…
Health Industry Washington Watch
Roundup of Recent Congressional Hearings, Markups on Health Policy Issues
Congressional committees have held numerous hearings and markups in recent weeks on health policy topics, including several hearings focused on health care costs. Highlights include the following: The Senate Health,…