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CMS Releases Final Medicare Advantage and Prescription Drug Plan Marketing Guidelines

Client Alert | less than 1 min read | 07.27.06

The Centers for Medicare & Medicaid Services released revised Medicare Advantage, MA-PD, Prescription Drug Plan and Medicare cost plan marketing guidelines on July 25, 2006.
We are reviewing the new guidelines for substantive changes from the previously released version.

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Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....