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Ninth Circuit Applies EKRA to Marketing Intermediaries in Lab Operator’s Allergy Testing Scheme

The U.S. Court of Appeals for the Ninth Circuit has held that a laboratory owner’s payments to marketing intermediaries violated the Eliminating Kickbacks in Recovery Act (EKRA)—in its first interpretation of the statute...more

After Decades of Broad Enforcement Discretion, FDA Signals New Approach to Homeopathic Drugs

Two announcements made by FDA in late October signal a marked change to FDA’s regulatory approach to “homeopathic” drugs. On October 25, 2019, FDA withdrew the 1988 Compliance Policy Guide (“CPG”) 400.400 Conditions Under...more

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