Articles and Blogs

Last week, the D.C. Circuit Court of Appeals (the “Court”) reinstated a rule cutting reimbursement rates for drugs purchased at a substantial discount under Section 340B of the Public Health Service Act (the “340B Program”) that had previously been ruled unenforceable by the District Court. In American Hospital Association v. Azar,[1] the Court held... READ MORE

On September 30, 2019, the Centers for Medicare & Medicaid Services (“CMS”) published notice of a proposed survey (“Survey”) of drug acquisition costs for all hospitals participating in the 340B drug discount program (“340B Program”). The Survey would require reporting of acquisition cost data on 340B discounted drugs, referred to as specified covered outpatient... READ MORE