Life Science Compliance Update Sailing with a New Safe Harbor in Sight: The EU-U.S. Privacy Shield Thomas Sullivan Jan 16, 2017 0 Beginning August 1, 2016, the United States Department of Commerce began accepting self-certifications to the EU-U.S. Privacy…
Congress FDA Issues Guidance on REMS Thomas Sullivan Jan 13, 2017 0 With the passage of the long-awaited 21st Century Cures legislation, we saw Senator Mike Lee (R-UT) vote “no” because the bill did…
Life Science Compliance Update Managing Medical Inquiries in an Era of Data Analytics Thomas Sullivan Jan 13, 2017 0 Although compliance professionals tend to view Corporate Integrity Agreements (“CIAs”) as setting the basic compliance standards,…
Drug Prices President-Elect Donald Trump on the Pharmaceutical Industry Thomas Sullivan Jan 12, 2017 0 On Wednesday, January 11, 2017, President-Elect Donald Trump held a news conference in New York; a conference that was held out…
Congress HHS Releases Regulations on Alternative Pay Models in Last Weeks of Current… Thomas Sullivan Jan 11, 2017 0 Despite Republicans’ call for a suspension on new rules, the Department of Health and Human Services (HHS) pushed regulations…
Life Science Compliance Update Maintaining Independence & Objectivity – OIG Releases New IRO… Thomas Sullivan Jan 11, 2017 0 The Health and Human Services Office of Inspector General has released new guidance on an important topic, Independent Review…
FDA FDA Seeking Comments on Direct to Consumer Advertising Proposed Research Thomas Sullivan Jan 10, 2017 0 On January 4, 2017, the United States Food and Drug Administration (FDA) published a Notice in the Federal Register, requesting…
Drug Prices OIG Report Addresses High Federal Spending on Catastrophic Part D Coverage Thomas Sullivan Jan 9, 2017 0 The Department of Health and Human Services (HHS) Office of Inspector General (OIG) today released a report examining federal…
Life Science Compliance Update Feeling Needy: The Why, What and How of Needs Assessments Thomas Sullivan Jan 9, 2017 0 Given trade association guidance and recent government involvement in life sciences transactions, this article emphasizes the…
CMS A Review of CMS’ Hospital Compare Website Thomas Sullivan Jan 6, 2017 0 As we reported, in July CMS released its first-ever hospital quality star ratings on its Hospital Compare website. The overall…