Insights: Clients

Healthcare, Macro

Fiscal Year 2026 Funding/Government Shutdown, ACA

Yesterday’s meeting between President Trump and Congressional leaders yielded no progress towards resolution of FY26 government funding. In fact, both sides emerged from the meeting echoing their partisan messages with no indication they intend to soften their current positions (i.e., Democrats demanding that an extension of enhanced ACA...

Fed Personnel/Litigation

The various lawsuits challenging President Trump’s ability to fire members of independent boards are moving to a more advanced stage. Most notably, last week the Supreme Court (SCOTUS) agreed to take up the case of Rebecca Slaughter, a member of the Federal Trade Commission (FTC), whom Trump attempted to fire in March. Separately, Trump has filed...

Mergers & Acquisitions

The EC will soon decide whether to issue a formal statement of objections (SO) against the deal. An SO typically issues on or around the 40th business day of the EC’s review, which would be October 10th in this case. The M&A publication Dealreporter reported today that the case team reviewing the transaction has found no basis for an SO and has...

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.”