D.C. Circuit holds agency letters reviewable despite agency statement that they do not constitute "a final agency action or even an initial determination"

Under the Medicaid program, companies give rebates to states based upon the application of a formula to the average wholesale price (AWP) of a drug as of a certain date. The Director's letter "expressly stated that it was not 'a final agency action or even an initial determination on...

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Bibliographic Details
Published in:Administrative & Regulatory Law News 2020-01, Vol.45 (2), p.19-19
Main Author: Jordan, Bill
Format: Article
Language:English
Subjects:
False information
Fines & penalties
Judicial reviews
Medicaid
Online Access:Get full text
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