Although Medicaid is only ~10% of Acthar sales, the CMS announcement appears to be having a "chilling effect" on fill rates as the injunctive relief process under the Administrative Procedure Act
evolves, Petrone tells investors in a research note.
The brief challenges the rule, asking the court to block implementation as illegal under the Administrative Procedure Act
. It also points out that if physicians withhold health information from patients, they could be liable for practicing substandard care.
District Court for the Southern District of Texas ruled that the Water of the United States (WOTUS) rule, released during the former President Barack Obama administration, violated the Administrative Procedure Act
He previously has served as chairman of the Camden Yards Sports and Entertainment Commission and of the Commission to Revise Maryland's Administrative Procedure Act
In a dispute where a charitable foundation that operates patient assistance programs challenges an advisory opinion from the Department of Health and Human Services, the court said that although the Administrative Procedure Act
limits a court's discretion to grant discovery to supplement an administrative record, here, the government was entitled to limited discovery, including on the issue of standing.
Finally, even the requirement that agencies solicit public comment before finalizing a regulation, which dates back to the 1946 Administrative Procedure Act
, has been criticized as disproportionately helping business interests and not living up to its promise of encouraging broader participation in regulatory decisions.
US District Judge Brian Morris found that the US government's use of a 2014 environmental review to justify issuing a presidential permit for construction of the cross-border pipeline violated the National Environmental Policy Act, the Endangered Species Act and the Administrative Procedure Act
, according to the court order issued Thursday.
Appendixes offer the Constitution, the Administrative Procedure Act
, the Freedom of Information Act, and other documents.
Corporation Counsel Ed Siskel argued that the Trump administration's efforts to "discourage enrollment, raise prices, sow uncertainty in insurance markets and eliminate choices" violates the Administrative Procedure Act
and the Take Care Clause of the U.S.
The Board had exempted itself from the Administrative Procedure Act
, so its procedures were by its own regulations--everything from the Board of Equalizations and its regulations in terms of the process.
These agencies act in accordance with the Florida Administrative Procedure Act