Health Law Advisor

On September 24, 2026, the Centers for Medicare & Medicaid Services (CMS) issued a request for information (RFI) seeking input from stakeholders for purposes of establishing “reasonable and relevant” pharmacy contract terms and conditions between pharmacies and Part D plan sponsors under the Medicare prescription drug benefit, effective for plan years starting after January 1, 2029. This RFI was mandated by Congress in Section 6223(a) of the Consolidated Appropriations Act of 2026 (the “CAA”).

At first blush, the passage of House Bill 5483, entitled the “Special Registration for Telemedicine Clarification Act of 2018” (the “Bill”), appears to address the issue concerning the lack of regulatory guidance regarding the “Special Registration” exception to the Ryan Haight Act of 2008; however, a deeper and more careful analysis reveals that the Bill may not be as effective as most health care practitioners may hope. The Bill, sponsored by Rep. Carter (R-Georgia), a pharmacist, Rep. Bustos (D-Illinois), and nine others, cleared the House on June 12, 2018 without ...

There is a proposal moving through Congress that has some interesting implications for telemedicine.  Sen. Diane Feinstein (D-CA) and Rep. Bill Cassidy (R-LA) have proposed an amendment to the Online Pharmacy Safety Act that would impose additional restrictions on when and under what circumstances practitioners can prescribe medication under the Federal Food, Drug, and Cosmetic Act.  Although the Online Pharmacy Act is primarily intended to put an end to illegitimate pharmacies and the fraudulent sale of drugs online, as the American Telemedicine Association, HealthLeaders