Medical Charity Brings First Amendment Challenge Against HHS
The charity alleges HHS issued an advisory opinion that prohibits it from communicating with companies about treatment options for patients.
January 11, 2018 at 09:10 PM
4 minute read
A charity that provides financial and other assistance to patients with chronic and life-threatening diseases sued the U.S. Department of Health and Human Services this week, claiming the department is violating its First Amendment rights.
In its lawsuit filed in the Eastern District of Virginia, Patient Services Inc. claimed a March 2017 HHS advisory opinion blocks the nonprofit from communicating with donors and potential donors about its patient programs, a move that altered guidance it's followed for years and severely limits its ability to operate. PSI general counsel Neil Millhiser said the change has contributed to a $17 million drop in the organization's budget.
“In the end, this is really hurting the patients,” Millhiser said.
An HHS spokeswoman said the agency does not comment on pending litigation. PSI is represented by a team from Sidley Austin that includes Carter Phillips, William Sarraille, Robert Keeling, Jack Pirozzolo and Paul Zidlicky.
The lawsuit comes as the Justice Department has been investigating improper payments by pharmaceutical companies to charities like PSI. The Justice Department secured a guilty plea and millions of dollars from Aegerion Pharmaceuticals in September to resolve criminal charges, including that the company used PSI to illegally pay for patients' co-pays. PSI faced no allegations of wrongdoing in the investigation.
To help businesses and nonprofits ensure they are not running afoul of fraud provisions including the Anti-Kickback Statute, the Office of the Inspector General at HHS issues advisory opinions. According to its lawsuit, PSI has operated for more than 15 years under an advisory opinion under which the organization promised to provide help to patients without regard to their choice of medication or healthcare provider.
However, in a new modified advisory opinion, PSI alleges HHS barred the organization from communicating with donors, which include pharmaceutical manufacturers, about diseases and treatments for those diseases.
The organization claims in the lawsuit it has no choice but to agree to the advisory opinion because donors often will not participate in the programs without the assurance of such an opinion, and because the organization fears prosecution if it operates outside an advisory opinion.
PSI argues it must engage in communication with certain donors because they have information needed to ensure PSI programs fully cover not only the treatment for a disease, but supplemental needs like transportation or underlying treatments.
The organization says the new opinion bars it from asking donors or their “affiliates” about items including available treatment for diseases, costs of new or evolving treatments and how treatments are administered. PSI also says the opinion is unclear about the definition of “affiliates.”
“It's a classic chicken and egg scenario, because how can we set these programs up without getting the information?” Millhiser said.
Millhiser said the opinion prevents PSI “from doing our due diligence” and violates the First Amendment because it's a restriction on speech that is “truthful” and “non-misleading.”
PSI claims the government has failed to narrow the restrictions to meet its interest in prohibiting certain violations of the law.
“[HHS] can't just introduce draconian limits on speech because of something that might happen. They have that burden of justifying these proposed restrictions,” Millhiser said. “That's what really goes to the core of this. They are violating our First Amendment rights.”
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View All'Absurd Costs'?: Visa Faces Antitrust Class-Action Surge Following DOJ Complaint
3 minute read'Systemic and Pervasive'?: DiCello Levitt Alleges WWE Child Sexual Abuse Scandal
3 minute readThe 2024 NLJ Awards: Professional Excellence—Appellate Hot List
4th Circuit Revives Workplace Retaliation Lawsuit Against Biden's HHS Secretary
3 minute readTrending Stories
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250