Richard B. Davis, Associate

Richard Davis 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. In addition to helping clients with a wide range of pharmacy regulatory issues such as controlled substances and state licensure compliance, Richard regularly assists pharmacy benefit managers (PBMs), utilization review agents (URAs) and third-party administrators (TPAs) in navigating the complex and evolving regulatory landscape facing these entities. Richard 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.

Representative Experience

• Assists in implementing and enhancing 340B drug pricing programs across a wide variety of health systems, enabling the systems to obtain millions of dollars in savings.
• Provides ongoing compliance and operational support to 340B participating entities, including successfully disputing and mitigating HRSA OPA audit findings, enabling these entities to retain their 340B savings in addition to contracting with various national retail pharmacy chains and 340B program software vendors.
• Assists large health systems in addressing all manner of pharmacy regulatory issues ranging from "own use" questions to advising on complex internal pharmacy re-organizations.
• Assists national URAs, TPAs, and PBMs in obtaining and maintaining the appropriate licensure across all 50 states following the recent Rutledge decision.
• Assists in negotiating GPO participation and drug purchasing agreements on behalf of various hospitals and health systems.
• Drafts detailed and legally compliant "own use" policies for large nonprofit health systems to maximize their drug purchasing leverage.