A recent U.S. Department of Health and Human Services advisory opinion, which decided not to impose administrative sanctions regarding a biopharmaceutical company's free genetic testing services, illustrates some unsteady reasoning that could yield different results in other cases, say Dominick DiSabatino and Cynthia Suarez at Sheppard Mullin.
Cynthia Suarez is a corporate lawyer at Sheppard Mullin law firm focused on advising healthcare industry clients in connection with mergers and acquisitions, joint ventures, and other corporate transactions, as well as a range of legal and regulatory compliance issues such as Stark Law and Anti-Kickback Statute compliance