HHS’ Withdrawal of the Richardson Waiver and New Statement of Organization: What Does It Mean for the Health Care Industry?

In March, the Department of Health and Human Services (HHS) withdrew the Richardson Waiver, a policy under which HHS voluntarily undertook notice-and-comment rulemaking in circumstances where it wouldn’t otherwise need to. HHS also issued a new Statement of Organization for the Office of the General Counsel (HHS-OGC), which, among other things, may signal an effort to consolidate and expand HHS-OGC’s authority. Jaime Jones, Partner, Sidley Austin LLP, and Brenna Jenny, Partner, Sidley Austin ...