New Kickback Safe Harbor for Federally Qualified Health Centers
Client Alert | less than 1 min read | 07.01.05
The HHS Office of Inspector General has issued a proposed new anti-kickback law safe harbor protecting transfers of goods, items, services, donations and loans to federally qualified health centers if specific conditions are met. The proposed regulation implements a provision of the Medicare Modernization Act calling for the new safe harbor where an arrangement contributes meaningfully to the health center's provision of services to a medically underserved population. The comment period on the proposed regulation runs until August 1, 2005. Click here to view the proposed rules published in the Federal Register.
Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 10.30.26
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
