Insights: Policy

Drug Pricing/Most-Favored Nation Pricing (MFN)

HHS has submitted a Notice of Proposed Rulemaking (NPRM) entitled “Global Benchmark for Efficient Drug Pricing (GLOBE) Model” – presumably outlining a CMS Innovation Center (CMMI) model testing MFN pricing – to the White House’s Office of Information & Regulatory Affairs (OIRA) for review. This is the final step before a regulation is formally...

Drug Pricing/TrumpRx (Direct-to-Consumer)

The Trump administration is considering creating a government-run website which would facilitate the purchase of certain pharmaceuticals by consumers at discounted cash prices – a direct-to-consumer (DTC) construct that would presumably bypass pharmacy benefit managers (PBMs) and/or insurance companies. The plan has not yet been finalized and is...

Pharmaceutical Tariffs

President Trump yesterday posted... "Starting October 1st, 2025, we will be imposing a 100% Tariff on any branded or patented Pharmaceutical Product, unless a Company IS BUILDING their Pharmaceutical Manufacturing Plant in America. “IS BUILDING” will be defined as, “breaking ground” and/or “under construction.”

Tech / Media / Telecom

Antitrust (Google, Meta, Apple, Amazon)

The DOJ’s antitrust actions against Google have continued to advance this month. Earlier this month, the District Court for D.C. issued a series of remedies against Google following its finding last summer that the company illegally maintained a monopoly in the “general search services and general text advertising” markets. And this week, the...

Tech / Media / Telecom

Tech Workforce/H-1B Visas

Late last week, President Trump signed an Executive Order (EO) imposing a new, incremental $100,000 fee for H-1B petitions. Two days later, the Department of Homeland Security (DHS) – as directed by the EO – issued a proposed rulemaking to implement a weighted selection process that would generally favor the allocation of H-1B visas to higher...

Healthcare, Macro

Fiscal Year 2026 Funding/Government Shutdown, ACA

At the urging of Republican leaders, President Trump cancelled a meeting this week with Democratic leaders to address the need to pass appropriations legislation to fund government operations past the 10/1 beginning of FY26. If appropriations legislation is not passed by 9/30, government operations (e.g., discretionary programs such as...