On October 31, 2019, the Office of General Counsel for the U.S. Department of Health and Human Services (HHS) issued an important memo from Kelly M. Cleary, CMS Chief Legal Officer, and Brenna E. Jenny, Deputy General Counsel, discussing the impact of the recent U.S. Supreme Court ruling Azar v. Allina Health Services, 139 S. Ct. 1804 (2019) on enforcement actions brought by the government (“Cleary Memo”).
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