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HHS Drops Appeal in Drug Coupon Case

On January 16, 2023, the Department of Health and Human Services (“HHS”) dropped its appeal of the U.S. District Court for the District of Columbia’s September 29, 2023 decision that vacated a portion of the 2021 Notice of...more

2025 Medicare Advantage and Part D Proposed Rule: What’s New for 2025?

In early November, the Centers for Medicare and Medicaid Services (“CMS”) published the contract year 2025 proposed rulemaking (“Proposed Rule”) for Medicare Advantage (“MA”) and Part D sponsors. The Proposed Rule previews...more

Court Ruling Calls Into Question Whether Plans and Issuers Can Exclude Drug Coupons Towards the MOOP

On September 29, 2023, the U.S. District Court for the District of Columbia vacated the 2021 Notice of Benefit and Payment Parameters (“2021 NBPP”) amendments to Affordable Care Act regulations. The amendments permitted (but...more

The Supreme Court Narrows ERISA Preemption in Rutledge v. PCMA

In the recently-decided Rutledge v. Pharmaceutical Care Management Association (“PCMA”), the Supreme Court found 8–0 (Justice Barrett did not take part) that ERISA did not preempt an Arkansas state law that established...more

Post-Election 2020: Healthcare Priorities Under a Biden Administration

The dust has settled and the 2020 election has concluded with former Vice President Biden poised to become president. At the same time, Democratic control of the House of Representatives has narrowed to the smallest margin...more

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