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DOJ Is Not Taking Its Foot Off the Gas in Health Care Fraud Enforcement: What DOJ’s New White-Collar Enforcement Plan Means for Health Care and Life Sciences Companies

On May 12, 2025, the US Department of Justice’s Criminal Division Chief, Matthew R. Galeotti (“Chief Galeotti”), announced DOJ’s first ever White-Collar Enforcement Plan (the “Plan”), which directs prosecutors to: (1) focus on certain priority areas, including several areas directly impacting the health care and life sciences industries, as noted below; (2) conduct white-collar investigations in fairness by incentivizing good corporate conduct and voluntary self-disclosure; and (3) boost efficiency by reducing the duration of corporate investigations and charging decisions. The Plan also introduces revisions to existing DOJ white-collar and corporate enforcement policies.
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Tri-Agencies Stay Enforcement of the 2024 MHPAEA Final Rules

On May 15, 2025, the Departments of Labor, Health and Human Services and the Treasury issued a nonenforcement policy of the final rules under the Mental Health Parity and Addiction Equity Act of 2008 that the Departments promulgated last fall.
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Executive Order Calls for Most-Favored-Nation Pharmaceutical Pricing for American Patients

On May 12, 2025, President Trump issued an executive order directing executive agencies and, imminently, pharmaceutical manufacturers to take steps to deliver most-favored-nation prescription drug pricing to patients in the United States.
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