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In June 2016, AmSurg Corp. and Envision Healthcare Holdings, Inc. (Envision) announced they have signed a definitive merger agreement pursuant to which the companies will combine in an all-stock transaction. Upon completion of the merger, which is expected to be tax-free to the shareholders of both organizations, the combined company will be named Envision Healthcare Corporation and co-headquartered in Nashville, Tennessee and Greenwood Village, Colorado. The company's common stock is expected to trade on the New York Stock Exchange under the ticker symbol: EVHC. Bass, Berry & Sims served as lead counsel on the transaction, led by Jim Jenkins. Read more.

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Inside the FCA blogInside the FCA blog features ongoing updates related to the False Claims Act (FCA), including insight on the latest legal decisions, regulatory developments and FCA settlements. The blog provides timely updates for corporate boards, directors, compliance managers, general counsel and other parties interested in the organizational impact and legal developments stemming from issues potentially giving rise to FCA liability.

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Pennsylvania Will Enforce Non-Resident Pharmacy Licensure Requirement Beginning December 7, 2015

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November 23, 2015

The Pennsylvania Board of Pharmacy has indicated its intent to begin enforcement of Pennsylvania's new non-resident pharmacy licensure requirement on December 7, 2015. Non-resident pharmacies with Pennsylvania operations should apply for a non-resident pharmacy license as soon as possible. The application is available through the Board's website and requirements include, among other things:

  • the submission of a $125 fee;

  • a copy of the pharmacy's resident state license;

  • the provision of a letter of good standing or license verification from the resident state Board of Pharmacy directly to the Pennsylvania Board; and

  • a copy of a sample prescription label including the pharmacy's toll-free phone number.

On October 7, 2015, Pennsylvania enacted legislation requiring non-resident pharmacies to register with the Pennsylvania Board of Pharmacy before delivering prescriptions to Pennsylvania patients or advertising in Pennsylvania.

To ensure compliance and prevent any disruption to operations, out-of-state pharmacies currently shipping product to Pennsylvania patients should apply for Pennsylvania licensure as soon as possible. Regulators have advised pharmacies to allow at least two weeks for the processing of applications, meaning pharmacies should attempt to submit their applications by November 23, 2015.

Pennsylvania does not require that the non-resident pharmacy's designated pharmacist-in-charge hold a Pennsylvania pharmacist license.

As noted in our previous alert, the licensure requirement will create new compliance obligations for non-resident pharmacies with operations in Pennsylvania.

If you have questions about Pennsylvania's new non-resident licensure requirement, please contact the authors of this alert or any member of our Specialty Pharmacy team.


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