Insights & Analysis
Practical guidance on PBM audits, federal investigations, compounding defense, DEA enforcement, telehealth compliance, and the regulatory pressures facing pharmacies and providers nationwide.
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Florida Attorney General Launches Investigation Into CVS Caremark: What It Means for Independent Pharmacies
Florida’s Attorney General issued a Civil Investigative Demand to CVS Health and Caremark, underscoring intensifying scrutiny of P…
Health Law Alliance Successfully Reverses PBM Network Termination for a California Independent Pharmacy
Health Law Alliance obtained a complete reversal of a PBM network termination for a California independent pharmacy, preserving it…
PBM Audit Defense Lawyer Insights: Avoiding the Top PBM Audit Traps That Lead to Network Termination
Six common PBM audit-response mistakes that can escalate into recoupment, network termination, or a broader government investigati…
State Professional Licensing Boards Take Aim at Peptides
State medical, nursing and pharmacy boards are taking an aggressive stance against clinical use of peptides despite FDA’s recent…
Skin Substitute Distributor Arrangements and Enforcement
A $309 million DOJ settlement shows how distributor commissions and pricing spreads on skin substitutes become Anti-Kickback Statu…
Selective Versus Excisional Debridement Documentation
Selective and excisional debridement pay differently and require different proof. What the operative note must show, and why wound…
Medically Unnecessary Services as an FCA Theory
Medical necessity splits the federal circuits on what counts as false under the FCA, turning a documented clinical judgment into t…
Materiality as a Defense: Government Knowledge
Escobar made FCA materiality a demanding standard. Continued government payment despite knowledge of a violation is very strong ev…
Laboratory Kickback Enforcement: Process and Handling Fees
Specimen processing fees look like overhead reimbursement, but the OIG's 2014 alert and $48.5M in DOJ settlements show how they be…