Jeffrey I. Davis
Jeff Davis advises healthcare organizations on Medicare and Medicaid billing and reimbursement issues, with a special focus on the federal 340B drug pricing program. He also counsels clients on emerging healthcare regulatory issues, including COVID-19 relief funding, surprise medical billing, and hospital price transparency, and provides strategic insights to clients on public policy matters under consideration by the U.S. Congress and federal agencies, such as drug pricing policy and nonprofit hospital issues.
Jeff forged his deep knowledge of the 340B program and other Medicare and Medicaid reimbursement issues while working in the federal public policy arena. He spent more than seven years working as vice president and legislative and policy counsel for 340B Health, an association of more than 1,400 hospitals and health systems participating in the 340B program. In this role, he provided technical assistance to member hospitals, directed research and policy efforts, and helped lead government relations efforts to educate federal policy makers on 340B issues. He draws on this experience to advise hospitals, pharmacies, other provider organizations and vendors on 340B issues including enrollment, contracting, audits, compliance and self-disclosures.
Before his work at 340B Health, he was the healthcare legislative assistant to U.S. Representative Shelley Berkley (D-NV), where he worked with healthcare provider companies to promote increased Medicare funding for a range of organizations, including hospitals, physicians and post-acute providers.
Jeff is a frequent speaker on the 340B program for conferences and webinars organized by the American Health Law Association, the 340B Coalition, other national provider groups and state hospital associations.
Memberships
American Health Law Association (AHLA)
Media Mentions & Firm News
Additional News & Insights
Publications
- “Key Issues for Providers in Part 1 of Surprise Medical Billing Regulations,” Westlaw (July 2021)
- “Biden Administration Actions Promoting LGBTQ Equality,” Diversity Matters Newsletter (Second Quarter 2021)
- “HHS Sends Enforcement Letters to Drug Manufacturers Regarding 340B Contract Pharmacies While Litigation Against HHS Continues,” Westlaw (June 2021)
- “CMS Proposes Repeal of Median MA Rate Reporting, While Lawmakers Raise Concerns Over Hospital Price Transparency Compliance, Request Increased Enforcement,” Westlaw (May 2021)
- “Lawmakers Raise Compliance Concerns Over Hospital Price Transparency Rules, Request Increased Enforcement,” Westlaw (April 2021)
- “Repayment of Medicare Accelerated and Advance Payments Begins for Providers and Suppliers,” Westlaw (April 2021)
- “CARES Act Compliance for Physicians: The provider relief fund explained,” Medical Economics (March 2021)
- “Key Health Provisions in the American Rescue Plan Legislation,” Westlaw Today (April 5, 2021)
- “Courts Halt Most Favored Nation Model That Could Significantly Reduce Medicare Reimbursement to Providers and Require Direct Negotiation with Manufacturers,” AHLA (January 2021)
- “HHS/OIG Finalizes Rule Stripping PBM Rebates of Safe Harbor Protection,” Westlaw (December 2020)
- “Medicare Proposes Deeper Drug Payment Cuts to 340B Hospitals,” Westlaw (September 8, 2020)
- “Federal District Court Upholds CMS Hospital Price Transparency Rule, Reporting to Begin January 1, 2021,” Westlaw (August 5, 2020)
- “HRSA Eliminates Delay in Use of 340B Drugs in New Hospital Clinic Locations,” Westlaw (August 5, 2020)
- “A Flurry of Recent Activity Highlights Continued Interest in 340B Program Oversight,” Community Oncology Alliance and Westlaw Journal Pharmaceutical (January 2020)
- “Administrative and Congressional Activity Related to the 340B Drug Pricing Program Likely To Continue in 2019,” ABA Health eSource (February 2019)
- “Court Rules HHS 340B Payment Cuts Unlawful; HHS Seeks Stay in Proceedings,” Medical News (January 2019)
- “INSIGHT: Administrative Actions to Address Drug Prices Could Shrink the 340B Drug Pricing Program and Limit Hospital Savings,” Bloomberg Law (August 2018)
- “The 340B Drug Discount Program: A New Era of Enforcement and Oversight,” (co-author) Journal of Health & Life Sciences Law (June 2012)
Speaking Engagements
- “340B Program Latest Developments: 340B-Related Litigation, HHS Advisory Opinion, New Dispute Process Final Rule,” Strafford Webinar (June 2020)
- “Demystifying 340B for Correctional Institutions,” National Hepatitis Corrections Network (NHCN) and the National Viral Hepatitis Roundtable webinar (NVHR) (March 2021)
- “Contract Pharmacy Basics,” 340B Coalition Winter Conference (February 2021)
- “340B Contract Pharmacy Arrangements: What Does the Future Hold?,” Strafford webinar (January 2021)
- “CARES Act for Hospitals and Healthcare Providers: Implications of Key Provisions,” Strafford webinar (May 2020)
- “340B Demystified,” National Viral Hepatitis Roundtable webinar (January 2020)
- “Legislative and Regulatory Update,” Alabama Hospital Association (AlaHA) Education Series 340B Day, Montgomery, Alabama (January 2020)
- “Developments in Drug Pricing – The Changing Landscape for PBMs, Hospitals and Physicians,” Practicing Law Institute’s “Hot Topics in Health Care Law 2019,” (December 2019)
- “Value-Based Reimbursement and Alternative Payment Models,” Association of American Cancer Institute’s (AACI)/Cancer Center Administrators Forum (CCAF) Annual Meeting (October 2019)
- “340B Basics and Oversight Updates,” American Health Law Association (AHLA) Annual Meeting (June 2019)
- “AHLA 2019 Annual Meeting in Boston” (June 2019)
- “340B Legislative Update,” 340B Coalition Winter Conference (January 2019)
- “Exploring Changes to Medicare Part B Drug Reimbursement,” 340B Coalition Winter Conference (January 2019)
- “Community Benefit Reporting and Community Health Needs Assessment,” 340B Coalition Winter Conference (January 2019)
- “International Pricing Index Payment Model,” 340B Health Webinar (November 2018)
- “340B Drug Pricing Program: Past, Present and Future,” D.C. Bar panel (September 2018)
- “The Impact of 340B Reimbursement Cuts on Cancer Centers,” Association of American Cancer Institutes (AACI) webinar (September 2018)
- “Update and Submitting Comments on 2019 Proposed OPPS Rule,” 340B Health Webinar (August 2018)
- “340B Legislative Update,” 340B Coalition Annual Conference (July 2018)
- “Medicare Payment Cuts to 340B Hospitals — Financial and Operational Impact,” 340B Coalition Annual Conference (July 2018)
- “Understanding Medicare Provider Based Rules and Implications for 340B Child Site Registration,” 340B Coalition Annual Conference (July 2018)
- “PBM Panel Discussion,” American Pharmacy Purchasing Alliance Pharmacon Expo (June 2018)
- “340B Legislative Update,” 340B Coalition Winter Conference (February 2018)
- “Medicare Payment Cuts to 340B Hospitals: Operationalizing Modifiers and Evaluating Next Steps,” 340B Coalition Winter Conference (February 2018)
- “Navigate the Complexities of 340B and Its Impact on Pricing and Contracting,” Reimbursement and Contracting (September 2017)
- “340B Self-Disclosures,” Medicaid Drug Rebate Program Summit (September 2017)
- “Covered Entity Operational Insights and Case Study Examples,” 340B Manufacturer Summit (August 2017)
- “340B and Specialty Drugs,” 340B Coalition Annual Conference (July 2017)
- “Managing the Implementation and Operational Challenges Resulting from Significant Changes to the 340B Program,” 11th “Big Four” Pharmaceutical Pricing Boot Camp (May 2017)
- “Medicaid Billing and Reimbursement,” 340B Coalition Winter Conference (February 2017)
- “Orphan Drugs, Left Without a Home: The Impact of 340B Exclusions,” Iowa Hospital Association Annual Meeting (October 2016)
- “340B Essentials,” Florida Institute of Certified Public Accountants Health Care Industry Conference (April 2016)
Accolades
Best Lawyers: Ones To Watch — Administrative/Regulatory Law (2022)
Boston University Public Interest Law Journal — Managing Editor