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In what is becoming an annual tradition, the Medicare Fraud Strike Force, comprised of members from the U.S. Department of Justice and the Department of Health and Human Services (more about which can be read here), announced the latest . . .
In a step viewed optimistically by healthcare businesses, the United States Department of Labor ("DOL") has withdrawn two Obama-era guidance letters used to interpret the overtime wage provisions of the Fair Labor Standards Act.
The first guidance letter concerned independent contractors, and set forth the DOL's now-former position . . .
In News and Updates
Final Guidance for Part D DIR Reporting Requirements:
It appears that the Centers for Medicare & Medicaid Services ("CMS"), in its newly-released Final Guidance on Medicare Part D DIR Reporting Requirements for 2016, has begun addressing the lack of transparency surrounding Part D plan sponsors' collection of Direct and Indirect Remuneration ("DIR") fees from independent pharmacies.
The Office of Civil Rights of the U.S. Department of Health and Human Services ("OCR") has released a checklist of actions to be taken by covered entities in the event of a ransomware attack or other cyber-related security incident. OCR noted that in investigating breaches of protected health information ("PHI"), it will consider all . . .
Recently, Express Scripts started requiring that pharmacies seeking new enrollment provide a $500,000 surety bond as a condition of entering into the provider agreement. The cost of such a surety bond depends on the pharmacy and its owners' creditworthiness, but is still very high, and can easily exceed $15,000.
We urge new and prospective pharmacy owners to contact us at 212-668-0200 or . . .
On March 28, 2017, Roche Diagnostics Corp. and Roche Diabetes Care, Inc. filed a lawsuit in the U.S. District Court for the Southern District of Indiana, entitled Roche Diagnostics Corp. et al. v. Binson's Hospital Supplies, Inc., et al., Docket No. 17-cv-0949 (LJM)(DML). The Indianapolis-based subsidiaries of the Swiss . . .
Newly proposed Federal legislation would increase PBM transparency regarding aggregate rebates and "spread pricing".An oft-controversial issue, independent pharmacy associations have long lobbied for greater disclosure of the rebates that PBMs receive from drug companies, which . . .