HHS Limits Use of Guidance Documents in Civil Enforcement Actions and Issues First Good Guidance Practices Petition Response

On January 14, 2021, the Department of Health and Human Services (“HHS”) published the Transparency and Fairness in Civil Administrative Enforcement Actions final rule (“Rule”). The Rule amends and supplements the HHS Good Guidance Practices Rule (“GGPR”) published on December 7, 2020, and provides additional protections against the use of improper guidance and the application of unpublished standards or practices in enforcement actions brought by HHS....
By: Epstein Becker & Green

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