Richard B. Davis, Associate

Richard Davis is an attorney in the firm's Health Law Practice Group. He has extensive experience with the 340B Program and has worked with both contract pharmacies and covered entities to develop and optimize their 340B Program participation. Richard’s practice also focuses on a wide range of pharmacy regulatory issues, including controlled substances and state licensure compliance. He also assists health care entities, including hospitals, nursing homes, and physician practices, with a diverse range of regulatory issues, transactional matters, and reimbursement appeals.

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
• Drafts memoranda interpreting and analyzing HRSA OPA 340B program guidance based on relevant Medicare and Medicaid statutory and regulatory language
• Researches and assembles complex 50-state surveys on a variety of intricate issues related to pharmacy operations for national retail pharmacy chains
• Assists in negotiating GPO participation and drug purchasing agreements on behalf of various hospitals and health systems
• Represents health systems before the Departmental Appeals Board and the Provider Reimbursement Review Board to dispute millions of dollars in improper recoupment and payment adjustments by CMS and Medicare Administrative contractors
• Oversees physician practice acquisitions and other significant transactions involving drafting asset purchase agreements and member substitution agreements, reviewing physician employment agreements, conducting due diligence, and assisting in closing