Lexology December 14, 2021
Introduction
The past two years have featured a flurry of legislative action, agency rulemaking and executive orders targeting the pricing of pharmaceutical and biologic products and related price reporting obligations. The legislative and executive branches of government were especially active over the summer and the start of fall, as discussed in an August 2021 Alert. As we approach the end of 2021, this Alert takes stock of what’s happened, what’s been delayed, and what’s likely to happen in 2022 in the key areas that have been in play. Specifically, what we’re seeing is:
- Multiple best price value-based price reporting must wait. A delay in the implementation of the value-based arrangement exception to the “best price” rule, including related reporting...
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