Innovative health care counsel with extensive experience

Richard Davis helps clients with a wide range of pharmacy regulatory issues such as controlled substances and state licensure compliance. He has extensive experience with the 340B drug pricing program and has worked with both contract pharmacies and covered entities to develop and optimize their participation. Richard regularly assists pharmacy benefit managers (PBM), utilization review agents (URA) and third-party administrators (TPA) in navigating the complex and evolving regulatory landscape facing these entities. He also focuses on the convergence of traditional health care and technology and has assisted in developing innovative and legally compliant automated dispensing models for pharmacy clients in a variety of health settings.

Bar Admissions

• Pennsylvania
• Wisconsin

Education

• George Washington University (B.A.)
  • Major: International Affairs

• University of Wisconsin Law School (J.D., with honors, 2015)

• "340B Drug Pricing Program"
• "340B Program Upheaval: Compliantly Navigating Program Uncertainties While Maximizing Available Benefits"
• "340B Update 2021: Another Tumultuous Year for the 340B Program"
• "340B Year in Review"
• "A Program in Upheaval: What to Expect in the 340B Space Moving Forward"
• "Changes to the 340B Program: What Covered Entitles Must Know"
• "CVS Caremark Reverses Planned Payment Cuts to 340B Providers"
• "Drug Manufacturers Cut Off 340B Pricing for Contract Pharmacies"
• "Multistate Pharmacy Jurisprudence Review"
• "The 340B Drug Pricing Program Year in Review: What's Smoke and What's Fire in a Changing Landscape"
• "To Be or Not to 340B: HHS Issues Advisory Opinion and New GAO Report Sheds Light on HRSA’s Enforcement Pullback"
• "We're 340Back! Review of Major Developments to the 340B Program"
• 340B Developments in 2024 – Litigation and Legislation
• 340B Litigation Updates and Other Program Developments
• 340B Program Changes on the Horizon? Start Planning Now for Potentially Seismic Impact of Upcoming Genesis Decision
• 340B Program Compliance in a Shifting Landscape: What Challenges Do Stakeholders Face?
• 503B Loses Federal Preemption Argument, Appeals to Ninth Circuit
• Amidst Ongoing Manufacturer Restrictions, 340B Covered Entities and Contract Pharmacies Get Creative
• Applications Now Available for Alaska's New Licensing Categories and Prescription Standards
• AstraZeneca to Cut Off 340B Pricing for Contract Pharmacies on October 1
• Board’s Economic Impact Analysis Disputes Industry Submissions, Board Advances Proposed Rule Without Changes
• Brenda Shafer, Michael French and Richard Davis Author Law360 Article on Questions Related to Section 340B Drug Pricing
• CMS Proposal to Make One-Time $9 Billion Lump Sum Payment to 340B-Covered Entity Hospitals
• CMS Publishes 340B Drug Acquisition Cost Survey: Respond by May 15, 2020
• Continuing Changes in the 340B Space: New Restrictions and Shifting Alliances
• District Court Allows for Expanded Interpretation of Eligible Patient in Impactful 340B Program Ruling
• Fifth Circuit Issues Mifepristone Decision: Case Likely to Move to Supreme Court
• GAO Report Suggests Increased Oversight of 340B Program
• HRSA Notice Provides Clarity on 340B Child Site Registration Requirements
• HRSA Unveils New 340B Flexibilities During COVID-19 Crisis
• Interesting 340B Takeaways from 2020 OPPS Proposed Rule
• Navigating Abortion Restrictions Post Dobbs: Considerations for Pharmacy Providers
• New Alabama Law Imposes Designated Representative Registration Requirements for Wholesalers and Manufacturers
• New PBM State Laws Indicate a Shifting Battlefront over 340B Program Drug Pricing
• New Wisconsin Law Regulates PBM and Other Stakeholders Involved in Drug Pricing
• New Wisconsin Patient Consultation Rule Affecting Resident and Non-Resident Pharmacies to Take Effect on January 1, 2021
• Notice to Covered Entities: Manufacturer Seeking 340B Claims Data
• Results of Economic Impact Discussion: The Latest on Proposed Changes to Wisconsin Patient Counseling Rule That Will Impact Mail Order Pharmacies
• Supreme Court Decision Maintains Status Quo for Disproportionate Share Percentage Calculation: What Does It Mean for the 340B Program?
• The Current State of 340B and What to Expect in 2023
• The End of a Wild Year for 340B: HHS Issues Advisory Opinion and New GAO Report Sheds Light on HRSA’s Enforcement Pullback
• The Latest on Proposed Changes to Wisconsin Patient Counseling Rule That Will Impact Mail Order Pharmacies
• The Latest on Proposed Changes to Wisconsin Patient Counseling Rule That Will Impact Mail Order Pharmacies: Board Submits Final Rule Draft
• The Latest on Proposed Changes to Wisconsin Patient Counseling Rule That Will Impact Mail Order Pharmacies: Potential Relief for Mail Order Pharmacies?
• The Mifepristone Battle Enters a New Phase 
• The President’s 2020 Budget Keeps 340B Program in the Spotlight
• Update on Status of Proposed Wisconsin Patient Counseling Rule that Will Impact Mail Order Pharmacies
• UPDATE: U.S. Supreme Court Sides with 340B Hospitals in Significant $1.6 Billion Part B Drug Payment Ruling
• UPDATE: U.S. Supreme Court Sides with 340B Hospitals in Significant $1.6 Billion Part B Drug Payment Ruling
• “Pharmacy 101 and the 340B Program"

Seminar

• 2019 Pharmacy Law Symposium
• 2021 Pharmacy Law Symposium
• 2022 Pharmacy Law Symposium
• 2023 Pharmacy Law Symposium
• 2024 Pharmacy Law Symposium
• 340B Outlook from Capitol Hill, Federal Courts, and the States
• 340B Program: What Covered Entities Must Know
• Abortion Medication Access Post-Dobbs: What Healthcare Providers Need To Know
• Health Law Update
• Navigating the Post-PHE Landscape: Law and Policy Changes for the Healthcare Industry
• Privacy Protections Post-Dobbs: Preparing for a Multi-State Approach or a Federal Overhaul