The 340B Drug Pricing Program (the Program) has long been a cornerstone for healthcare providers seeking to deliver affordable care to underserved communities. However, as the regulatory and compliance landscape evolves, stakeholders—including covered entities, pharmaceutical manufacturers, and pharmacies—must navigate an increasingly complex array of legal requirements and enforcement trends.
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Navigating FDA’s Evolving Approach to Guidance Publication for Medical Products
Guidance development and publication from the Food and Drug Administration (FDA) has long been considered an essential element of medical product development, approval, and regulation. While temporary pauses in guidance publication are a frequent side effect of changes in administration, after the January 2025 executive order (EO) announcing a “10-to-1” deregulatory policy, many have wondered…
FDA Extends Scrutiny Over Color Additives Beyond Food to Drug Products
FDA’s recent focus on potentially harmful color additives in food products has expanded to the pharmaceutical sector. In May 2025, FDA issued a draft guidance titled Replacing Color Additives in Approved or Marketed Drug Products. This guidance signals FDA’s increasing attention to the use of colors in all consumable products, including both prescription and over-the-counter…
FDA’s AI-Assisted Review: The Next Stage of Regulated Product Evaluation
On June 2, 2025, FDA announced the launch of Elsa, a generative AI tool designed to “help employees—from scientific reviewers to investigators—work more efficiently.” Per FDA, the tool “modernizes agency functions and leverages AI capabilities to better serve the American people.” While Elsa may add efficiencies to FDA’s review processes, it also raises a number…
New Measures to Encourage Clinical Trials in the United Kingdom
While the US Food and Drug Administration has been experiencing recent reorganization and cuts in personnel, the United Kingdom has its own upcoming policy changes making it easier and faster to initiate and maintain UK clinical trials, which will create attractive new options and strategy decisions for pharma research and development companies.
Bipartisan Drug Pricing Reform: The FPDP Act and Revival of Most-Favored-Nation Pricing
As part of a broader resurgence in pharmaceutical pricing reform and manufacturing policies in 2025, President Donald Trump and bipartisan congressional leaders have introduced contemporaneous proposals to lower prescription drug prices under “most-favored-nation” (MFN) drug pricing models.
Distribution Chain Compliance for Medical Devices
Distributors, dispensers, and retailers of medical device products face a patchwork of federal and state requirements governing distribution chain compliance. Given the evolving and expanding requirements for device distribution activities, companies must take proactive measures to assess and mitigate risk. Below are key considerations that companies operating in this space should consider to safeguard their…
Conditional Approval Proposals for FDA: Current Context and Potential Ramifications
Drug approval is unequivocally the linchpin to any drug development effort and, given the role of the US market in the global marketplace, the drug approval standard employed by FDA remains a perennial focus of stakeholders across the industry. In light of recent remarks from the FDA commissioner on the development of a new conditional…
FDA's Recent Release of a Roadmap to Reduce Animal Testing
The US Food and Drug Administration (FDA) recently announced a strategic roadmap to phase out animal testing requirements for certain drug products, starting with monoclonal antibodies. This shift marks a significant change in regulatory policy, reflecting advancements in science and technology that offer alternative testing methods.
Drug Pricing & Access in 2025: Issues to Watch and Developing Strategies
The pharmaceutical industry is a critical component of the global economy, impacting public health, national security, and economic stability. Recent developments—including investigations into the national security implications of pharmaceutical imports, executive actions aimed at reducing prescription drug prices, and the evolving role of pharmacy benefit managers (PBMs)—highlight the complex interplay of policy, economics, and healthcare.