Articles and Blogs

Discount Safe Harbor

Discount Disruption: PBM Rebate Protection May Be Removed, New Safe Harbors Combat Increasing Drug Costs

[02/01/19]

Posted on February 1, 2019 in Health Law News

Published by: Hall Render

On January 31, 2019, the Department of Health and Human Services Office of Inspector General (“OIG”) issued a proposed rule that, if finalized, would eliminate Anti-Kickback Statute (“AKS”) safe harbor protection for prescription drug rebates paid by manufacturers to pharmacy benefit managers (“PBMs”), Medicare Part D plans and Medicaid managed care organizations (“Proposed Rule”).... READ MORE

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OIG Approves Risk-Sharing Arrangement Furthering Shift Toward Value-Based Purchasing

[09/19/18]

Posted on September 19, 2018 in Health Law News

Published by: Hall Render

In the era of value-based care, health care providers and manufacturers are increasingly examining risk sharing opportunities in the treatment of patients. On September 17, the Department of Health and Human Services Office of Inspector General (“OIG”) published Advisory Opinion 18-10 whereby it approved a proposed risk sharing initiative with defined guardrails. Advisory Opinion... READ MORE

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Three Supply Chain Strategies to Impact the Bottom Line

[01/13/17]

Posted on January 13, 2017 in Health Law News

Published by: Hall Render

The supply chain continues to be the second largest and fastest growing expense for health care systems, second only to labor costs, making this an area of untapped cost savings opportunity and an area ripe for leveraging supply chain as a strategic driver of savings. Because the procurement of goods and services impacts nearly... READ MORE

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