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HHS Announces 340B Rebate Model Pilot Program

On July 31, the US Department of Health and Human Services’ (HHS) Health Resources and Services Administration (HRSA) announced the availability of a new pilot program altering how pharmaceutical manufacturers can honor the...more

Medicare 2026 Proposed Rules, Major Drug Pricing Updates, and What Stakeholders Need to Know

Every July, the Centers for Medicare & Medicaid Services (CMS) publishes two proposed rules that set Medicare reimbursement and shape the administration of the Medicare Part B program for the upcoming calendar year. These...more

The 2025 Final Hospital Outpatient Prospective Payment System and Physician Fee Schedule Rules: What Pharma Stakeholders Need to...

This past July, we reported on the Centers for Medicare & Medicaid Services (CMS) release of the 2025 proposed Hospital Outpatient Prospective Payment System (HOPPS) and Physician Fee Schedule (PFS) rules. CMS has now...more

Fast 5: Five Quick Regulatory Takeaways for Pharmaceutical Companies

Here we are in fourth quarter of 2023 already! As companies start wrapping up 2023 and preparing and modeling for 2024, we thought it was a good time to highlight five regulatory developments, changes, or challenges on the...more

There’s One for You, Nineteen for Me: IRS Issues Guidance on 1900% Pharmaceutical Excise Tax

The Internal Revenue Service (IRS) has issued guidance on the pharmaceutical excise tax that may apply to certain drug manufacturers, producers, and importers that fail to negotiate a drug-pricing agreement with the US...more

CMS and OIG Issue Guidance on Implementation of the Inflation Reduction Act

The Centers for Medicare & Medicaid Services (CMS) and the US Department of Health and Human Services Office of Inspector General (OIG) continue to issue guidance regarding the implementation of the drug pricing provisions of...more

CMS Issues First Guidance Regarding the Inflation Reduction Act

The Centers for Medicare & Medicaid Services (CMS) has released the first in what undoubtedly will be a series of guidance documents regarding the recently enacted Inflation Reduction Act (IRA). ArentFox Schiff outlined...more

Drug Pricing Reform Finally Becomes Law: What the Inflation Reduction Act Means for Pharma

After many years of policy debate and attempts at proposed legislation, some of the most meaningful changes to the ways in which Medicare pays for prescription drugs – and the obligations of manufacturers selling drugs to...more

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