Richard Davis

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Richie has extensive experience with the 340B Program and has worked with both contract pharmacies and covered entities to develop and optimize their program participation. His practice also focuses on a wide variety of pharmacy regulatory issues, including controlled substances and state licensure compliance.

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Interesting 340B Takeaways from 2020 OPPS Proposed Rule

By Brenda Maloney Shafer and Richard Davis on Posted in Covered Entities, Legislation
The Centers for Medicare & Medicaid Services (CMS) “respectfully disagreed” with a recent federal district court’s “understanding of the scope of CMS’ adjustment authority” in making cuts to Medicare Part B reimbursement for drugs purchased through the 340B program, saying it plans to continue its 28.5 percent reduction in reimbursement while it pursues an appeal … Continue Reading

340B Litigation Updates and Other Program Developments

By Brenda Maloney Shafer and Richard Davis on Posted in Covered Entities, Legislation
340B Medicare Part B Adjustment Litigation Update In the latest development of the ongoing 340B Medicare Part B payment reduction controversy, US District Judge Rudolph Contreras again concluded that the Department of Health and Human Services (HHS) exceeded its statutory authority in implementing a reduced Medicare reimbursement rate for 340B Program drugs for 2019. In … Continue Reading

The President’s 2020 Budget Keeps 340B Program in the Spotlight

By Brenda Maloney Shafer and Richard Davis on Posted in Covered Entities, Legislation
On March 11, 2019, the President delivered his proposed 2020 budget to Congress. While a President’s budget proposal is the beginning of a lengthy budget process, this proposed budget nonetheless keeps the 340B Program in the national focus and delineates the President’s position on desired 340B Program changes.… Continue Reading

CVS Caremark Reverses Planned Payment Cuts to 340B Providers

By Brenda Maloney Shafer and Richard Davis on Posted in Covered Entities
CVS Caremark has decided not to implement reimbursement reductions which may have had adverse effects on Covered Entities and their retail pharmacies (including contract pharmacies). This decision, coupled with the recent court decision invalidating certain aspects of the proposed Medicare Part B payment reductions for 340B drugs,[1] provides some positive news for these Covered Entities … Continue Reading

We’re 340Back! Review of Major Developments to the 340B Program

By Brenda Maloney Shafer and Richard Davis on Posted in Audits, Covered Entities, Legislation
It’s been a roller coaster two years for the 340B Program, and we are now back to review some of the major developments and program changes during this time. On the highest level, despite a flurry of proposed legislative action, the 340B Program remains largely unchanged from where it stood prior to 2017. As covered … Continue Reading
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