OIG Approves Vaccine Manufacturer Discounts

The U.S. Department of Health & Human Services, Office of Inspector General issued a favorable advisory opinion (25-11) regarding an arrangement under which a vaccine manufacturer proposed to offer four types of discounts and rebates on three selected vaccines to its retail and non-retail customers.

Change Healthcare Class Action Advances

On December 19, 2025, the U.S. District Court for the District of Minnesota issued a significant decision in the Change Healthcare cybersecurity multidistrict class action, largely denying defendants’ motion to dismiss claims brought by health care providers nationwide. The Court permitted core negligence and breach-of-contract claims to proceed against Change Healthcare, UnitedHealth Group, and affiliated Optum entities, dismissing only narrower negligence-per-se theories premised on HIPAA and the Federal Trade Commission Act.

DEA Extends Telehealth Controlled Substances Prescribing Until December 31, 2026

The Drug Enforcement Administration (DEA) and the Department of Health and Human Services (HHS) have jointly issued a fourth temporary extension (the “Extension”) permitting health care practitioners to prescribe Schedule II–V controlled substances via audio-video telemedicine encounters without first conducting an in-person evaluation. The Extension, effective through December 31, 2026, continues to afford the DEA time to finalize permanent regulations governing controlled substance prescribing through telemedicine.