Articles by Michael B. Glomb

During the COVID-19 public health emergency, many health centers, community-based organizations, and small to mid-sized for-profit businesses will find themselves with decreased revenue due to reduced operations or closures.  In direct response to this challenge, the federal government has recently implemented two new loan programs that appear well-situated to offer…

HRSA’s Office of Pharmacy Affairs (OPA) has posted guidance for 340B covered entities during the COVID-19 pandemic.  The guidance can be accessed on the HRSA OPA website at https://www.hrsa.gov/opa/COVID-19-resources. Some of the questions addressed in the guidance include: Patient eligibility – Although HRSA has not waived the patient eligibility standards,…

FTLF Partners Michael Glomb and Jason Reddish will participate in the 2020 340B Coalition Winter Conference next week in San Diego, CA. During the three-day conference, FTLF will present at the following sessions: Tuesday, February 11, 2020 Aligning Your Health Center’s Pharmacy Program for Operational Excellence and Optimal 340B Compliance – Michael…

On January 8, 2020, CMS’ Center for Medicaid and CHIP Services (CMCS) issued an Informational Bulletin (“Bulletin”) sharing best practices with state Medicaid agencies for the prevention of 340B program Medicaid duplicate discounts.  The Bulletin addresses both fee-for-service (FFS) Medicaid and Medicaid managed care organizations (MCOs), and describes covered entity…

FTLF Partner Michael B. Glomb, a senior member of FTLF’s Health Law Practice Group, will make a presentation on Using 340B Drugs Across the Continuum of Care: How to Provide Quality Service and Stay Compliant, on April 10th at the Health Care Compliance Association’s 23rd Annual Compliance Institute in Boston,…