On January 4, 2013, the D.C. Circuit upheld a Department of Defense rule that probably has drug manufacturers feeling like they’re going to pay for drinks they didn’t order—but not literally, of course. In reality, the decision puts them on the hook for the partial refund of thousands of prescription drugs dating back to 2008. … Continue Reading
On October 15, 2010, the Department of Defense (“DoD”) issued a final rule implementing Section 703 of the National Defense Authorization Act (“NDAA”). In this rule DoD takes the position that the NDAA requires pharmaceutical manufacturers to provide discounted drug prices based on the Veterans Health Care Act’s (“VHCA’s”) Federal Ceiling Price (“FCP”), for covered drugs … Continue Reading