June 16, 2022
Publications and Blog Posts by Michael B. Glomb
February 23, 2021
CLIENT ALERT: The SBA’s Loan Necessity Questionnaire Raises Concerns for Borrowers
In late October and early November 2020, the SBA began distributing to lenders SBA Form 3509[1] and 3510[2] (the “Loan Necessity Questionnaire”) to collect supplemental information for its review of loan forgiveness applications, in particular the certification that the borrower made as part of its loan application that economic uncertainty…
December 10, 2020
Supreme Court Rules States Can Regulate Pharmacy Reimbursement Rates without Triggering ERISA Preemption in Important Case for 340B Reimbursement Protection
On December 10, 2020, the Supreme Court ruled in a unanimous decision (8-0) in Rutledge v. Pharmaceutical Care Management Association (PCMA)[1] that an Arkansas law that requires Pharmacy Benefit Managers (PBMs) to reimburse pharmacies for the cost of prescription drugs at no less than the pharmacies’ acquisition costs is not…