United States: Eleventh Hour Rulemaking: HHS Eliminates Safe Harbor Protections For PBM Drug Rebates; And Creates Two New Safe Harbors For Point-of-Service Discounts And PBM Fixed-Fee Arrangements - Sheppard Mullin Richter & Hampton

United States: Eleventh Hour Rulemaking: HHS Eliminates Safe Harbor Protections For PBM Drug Rebates; And Creates Two New Safe Harbors For Point-of-Service Discounts And PBM Fixed-Fee Arrangements - Sheppard Mullin Richter & Hampton

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On November 30, 2020, the United States Department of Health and Human Services ("HHS") Office of Inspector General ("OIG") issued a final rule ("Final Rule")

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