News & Analysis as of

Laboratory Developed Tests

McDonald Hopkins

Managing genetic testing risk and lessons from recent DOJ enforcement

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Over the last several years, federal concern about genetic testing has been steadily growing. Regulators have watched Medicare Part B spending on molecular and genetic tests spike while a relatively small number of...more

Baker Donelson

CMS Signals Expanded Anti-Fraud Enforcement Through CRUSH Initiative

Baker Donelson on

The Centers for Medicare and Medicaid Services (CMS) issued a Request for Information (RFI) on February 27, 2026, that signals a potential expansion of federal health care fraud, waste, and abuse enforcement. While the RFI...more

Katten Muchin Rosenman LLP

Genetic Testing Enforcement Poised to Rise: What to Expect in the Coming Year

On January 28, 2026, the U.S. Department of Health and Human Services Office of Inspector General (“HHS OIG”) released a report, “Total Medicare Part B Spending on Lab Tests Rose in 2024, Driven by Increased Spending on...more

Robinson+Cole Health Law Diagnosis

Medicare Part B Lab Spending Increased in 2024: Here’s what the Latest OIG Report Reveals

Introduction On January 28, 2026, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released a new report analyzing Medicare Part B (Part B) spending on laboratory tests in 2024....more

Robinson+Cole Health Law Diagnosis

DOJ Enforcement of Clinical Laboratories: Trends from Q4 2025

The final quarter of 2025 saw continued enforcement actions against clinical labs and other related healthcare entities. The Office of Inspector General (OIG) and Department of Justice (DOJ) heavily focused on False Claims...more

Akin Gump Strauss Hauer & Feld LLP

Self‑Collection Kits in the Crosshairs

The Food and Drug Administration (FDA) has begun 2026 with a clear signal to the direct‑to‑consumer testing industry: self‑collection devices remain firmly within the agency’s regulatory reach, notwithstanding the 2025 court...more

Bass, Berry & Sims PLC

Absent Congressional Action, Most Laboratories Required to Submit Outdated Data to CMS Beginning February 1, 2026

Bass, Berry & Sims PLC on

After years of delays, the Centers for Medicare & Medicaid Services (CMS) is preparing to update the Clinical Laboratory Fee Schedule’s (CLFS) reimbursement rates for clinical diagnostic laboratory tests (CDLTs) that aren’t...more

Troutman Pepper Locke

“All Foam and No Beer:” First Circuit Shields Lab From Relator’s Ginned-Up FCA Case

Troutman Pepper Locke on

The U.S. Court of Appeals for the First Circuit has weighed in on Omni Healthcare, Inc.’s (Omni) False Claims Act (FCA) allegations against MD Labs, issuing a decisive win for the defendant. On December 1, 2025, a unanimous...more

Rivkin Radler LLP

Diagnostic Lab to Pay $9.6 Million to Settle FCA/AKS Allegations

Rivkin Radler LLP on

The U.S. Department of Justice recently announced a settlement with Patients Choice Laboratories (“PCL”), a diagnostic laboratory headquartered in Indianapolis, Indiana, under which PCL will pay over $9.6 million to resolve...more

Robinson+Cole Health Law Diagnosis

OIG Greenlights Sponsored Diagnostic Testing in Advisory Opinion 25-07

On July 2, 2025, the Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 25-07, which concluded that a pharmaceutical manufacturer’s proposed arrangement to sponsor a free,...more

ArentFox Schiff

Top Four FDA Compliance Issues for Hospitals and Health Systems: What They Are, Why They Matter, and What To Watch

ArentFox Schiff on

An artificial intelligence (AI) triage model piloted in the emergency department can become a deterioration predictor on med-surg floors and then prioritized on a radiology worklist. A lab‑developed sepsis panel built in the...more

Snell & Wilmer

FDA Reverses Final Rule on LDTs: A Win for Labs, a Shift in Regulatory Strategy

Snell & Wilmer on

In a major regulatory reversal, the U.S. Food and Drug Administration (FDA) has officially rescinded its 2024 final rule that sought to regulate Laboratory Developed Tests (LDTs) as medical devices. The decision, announced on...more

Womble Bond Dickinson

FDA’s Authority Over Lab-Developed Tests Overturned: What the Court’s Decision Means for Lab Testing

Womble Bond Dickinson on

Previously, this blog covered the FDA’s decision to regulate lab-developed tests (LDTs) as medical devices. However, a ruling from a federal district court in Texas earlier this year has changed that. Multiple lawsuits were...more

Knobbe Martens

The FDA Drops New Laboratory Test Regulations

Knobbe Martens on

Laboratory-developed tests (“LDTs”) are in vitro diagnostic (“IVDs”) products designed and used within a single clinical laboratory to perform high complexity testing. ...more

Haynes Boone

FDA Reverses Final Rule Regulating Laboratory Developed Tests

Haynes Boone on

The United States Food and Drug Administration (FDA) has officially rescinded its final rule proposing to regulate Laboratory Developed Tests (LDTs) as medical devices. On Sept. 19, 2025, FDA issued a new final rule reverting...more

Goodwin

Life Sciences and Medtech Policy Update: Key Things to Know - Q4 2025

Goodwin on

Expected New Drug Pricing Model: We anticipate the Centers for Medicare & Medicaid Services (CMS) to release a significant proposed new drug pricing model through its Innovation Center called the Global Benchmark for...more

Venable LLP

FDA Announces Autism-Related Initiatives, Malaria Guidance, CBER Leadership, Pediatric Voucher Bill, and LDT Rule Rescinded

Venable LLP on

Through our Venable FDA Pulse series, we report on critical developments within the Food and Drug Administration (FDA or Agency) that may affect the Agency's structure and stakeholder interactions. ...more

Akin Gump Strauss Hauer & Feld LLP

FDA’s Latest on Emergency Diagnostics and a No-Frills Rescission of the LDT Rule

On Tuesday, September 23, 2025, FDA published guidance titled “Consideration of Enforcement Policies for In Vitro Diagnostic Tests During a Section 564 Declared Emergency.” The guidance, a draft of which was published on May...more

Venable LLP

The End of FDA’s LDT Rule, Trump Administration’s Regulatory Agenda Released, an Analysis of HHS Workforce Reductions Raises...

Venable LLP on

Earlier this month, the Office of Information and Regulatory Affairs (OIRA) updated its list of rules pending review under Executive Order 12866 to include FDA's request to rescind its controversial Laboratory Develop Test...more

Hogan Lovells

FDA to rescind laboratory developed test rule

Hogan Lovells on

FDA decided to rescind the LDT rule after declining to appeal a district court decision vacating it. The rule reflected FDA’s latest attempt to regulate LDTs under the same framework as IVDs, which FDA considers medical...more

Gardner Law

LDT Rule Vacated: FDA Backs Down, but Uncertainty Remains

Gardner Law on

In December 2024, we published an alert highlighting the FDA’s final rule on Laboratory Developed Tests (LDTs) and the compliance countdown to May 2025. The rule, issued in May 2024, sought to phase out the agency’s...more

Epstein Becker & Green

A Final Rule Bites the Dust, Part II: FDA Gives up on Regulating LDTs as Medical Devices

As the song goes, the Food and Drug Administration’s (“FDA’s”) 2024 Final Rule regulating laboratory-developed tests (“LDTs”) as medical devices (“Final Rule”), is not merely dead—it’s really most sincerely dead....more

Ropes & Gray LLP

Regulation of Laboratory Developed Tests in APAC

Ropes & Gray LLP on

Laboratory Developed Tests (LDTs) are critical for diagnosing rare diseases and addressing unmet clinical needs. They are developed, manufactured, and used within a single licensed clinical laboratory for purposes of clinical...more

McGuireWoods LLP

Court Strikes Down FDA Rule Regulating Laboratory-Developed Tests

McGuireWoods LLP on

On March 31, 2025, the U.S. District Court for the Eastern District of Texas, in American Clinical Laboratory Association v. U.S. Food and Drug Administration, vacated the U.S. Food and Drug Administration’s (FDA’s) May 6,...more

Epstein Becker & Green

Federal Court Strikes Down FDA Rule on LDTs - Thought Leaders in Health Law®

On March 31, 2025, the U.S. District Court for the Eastern District of Texas ruled that the Food and Drug Administration (FDA) lacks the statutory authority to regulate laboratory-developed tests (LDTs). The court’s judgment...more

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