Ex-HHS General Counsel Robert Charrow during a webinar yesterday defended his since-withdrawn 340B contract pharmacy advisory opinion.

In His First Public Comments, Ex-HHS Top Lawyer Stands by 340B Contract Pharmacy Advisory Opinion

Former U.S. Health and Human Services Department General Counsel Robert Charrow yesterday defended his strongly worded and colorful December 2020 advisory opinion, since vacated by a court and withdrawn by HHS, that the 340B statute unambiguously requires drug manufacturers to offer 340B pricing on their products when covered entities use contract pharmacies or other distribution methods.

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