Professor of Practice, Nationally Recognized Health Care and Life Sciences Expert, Regulatory Consultant, Patient Access Advocate, Independent Director, and Retired Sidley Austin Partner; ALL VIEWS EXPRESSED ARE PERSONAL
#Chevron’s Demise and the #340B Program: What’s the Impact? This 340B Report article explores the question, with different sources providing very different takes. I’m quoted. My take? I think #Loper puts #HRSA in an even worse position—as difficult as that is to imagine. Both #drug #manufacturers and #coveredentities will be further encouraged to develop “self-help” solutions, more confident that, even if the Health Resources and Services Administration (HRSAgov), HHS tries to intervene, its enforcement efforts can be beaten back. Though it didn’t make the cut for this article, I also think a DIFFERENT #SupremeCourt case, #Jarkesy, spells the demise of HRSA’s ability to impose #civilmonetarypenalties (#CMPs). You can see my separate post exploring that issue. If I’m right, that, too, will encourage manufacturers to pursue more self-help solutions. Buckle up, people. #lifesciences #drugpricing #Protect340B #adlaw #administrativelaw #HHS
Jenn Kerfoot
8mo
Buckle up and put on a hockey mask… The last few weeks have been like riding in a rollercoaster without being strapped in!
Health Policy | Market Access | Medical Affairs
8moWilliam Sarraille do you foresee Braidwood, coupled with Chevron, puts screening services (eg lung and breast cancer) in jeopardy? Or at least patients having to incur additional out of pocket expenses ?