HHS Clarifies NPDB Reporting Obligations
Client Alert | 1 min read | 09.24.03
Some health care entities have expressed concern that the National Practitioner Data Bank regulations require health care entities to report adverse actions taken against practitioners to both the NPDB and the applicable State Board of Medical Examiners, while the NPDB Guidebook directs health care entities to report directly to the NPDB first, and then subsequently to send to the State Board the Report Verification Document that the NPDB sends to the plan confirming receipt of the adverse action report in satisfaction of the plan's Board reporting obligation. We requested confirmation of health care entity obligations from the NPDB, and received the attached letter from HRSA Deputy Administrator Cynthia Grubbs in response. The letter confirms the process set forth in the Guidebook, and should provide additional comfort to health care entities who may have been unsure of their obligations.
Insights
Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
