AbbVie Inc. v. Bailey

CourtDistrict Court, E.D. Missouri
DecidedJuly 11, 2025
Docket4:24-cv-00996
StatusUnknown

This text of AbbVie Inc. v. Bailey (AbbVie Inc. v. Bailey) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AbbVie Inc. v. Bailey, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

ABBVIE INC. et al., ) ) Plaintiffs, ) ) v. ) Case No. 4:24-cv-00996-SRC ) ANDREW BAILEY, in his official ) capacity as Attorney General of the State ) of Missouri et al., ) ) Defendants. )

Memorandum and Order The federal government allows AbbVie Inc., a pharmaceutical manufacturer, to participate in Medicaid. In exchange, federal law requires AbbVie to offer its drugs at discounted prices to healthcare providers serving underserved communities. Not all those providers have their own pharmacies, so some of them ask AbbVie to deliver the discounted drugs to for-profit, commercial pharmacies with which the providers have contracts. AbbVie doesn’t like that because, it claims, those third-party pharmacies use special accounting and inventory methods to buy drugs at a discount and resell them at a higher price, in violation of federal law. Last year, Missouri enacted a law that prevents companies like AbbVie from refusing to deliver the discounted drugs to these pharmacies. AbbVie sued various state officials to enjoin enforcement of the law. Missouri moves to dismiss for failure to state a claim and failure to join necessary parties, and two organizations of healthcare providers move to intervene. But because AbbVie only alleges injuries stemming not from the Missouri law at issue but from violations of federal law—which violations AbbVie does not ask the Court to address—the complaint fails to adequately allege standing. Thus, the Court does not reach the merits of either motion. I. Background A. Section 340B

Section 340B of the Public Health Service Act (codified at 42 U.S.C. § 256b) “imposes ceilings on prices drug manufacturers may charge for medications sold to specified health-care facilities.” Astra USA, Inc. v. Santa Clara Cnty., 563 U.S. 110, 113 (2011). Section 340B requires the Secretary of the United States Department of Health and Human Services to “enter into an agreement with each manufacturer of covered outpatient drugs.” 42 U.S.C. § 256b(a)(1). Manufacturers include entities engaged in the production of prescription drugs. 42 U.S.C. § 1396r-8(k)(5)(A). Whether a drug qualifies as a “covered outpatient drug” depends on whether the drug satisfies a complex, and, for purposes of the pending motions, irrelevant, statutory definition. See 42 U.S.C. § 1396r-8(k)(2). As part of the deal with HHS (which has delegated its authority to the Health Resources and Services Administration (HRSA)), see Astra, 563 U.S.

at 113–14, manufacturers must “offer each covered entity covered outpatient drugs for purchase at or below” a price ceiling, 42 U.S.C. § 256b(a)(1). Long story short, section 340B requires pharmaceutical manufacturers that participate in Medicaid to offer drugs at discounted prices to certain entities called “covered entities.” Section 340B defines “covered entity” to include fifteen subsets of healthcare providers. See 42 U.S.C. § 256b(a)(4). Federally qualified health centers, Native Hawaiian health centers, black-lung clinics, some children’s hospitals, and a host of other providers qualify as covered entities. See id. Through two provisions, section 340B restricts covered entities from abusing their access to discounted drugs. First, a covered entity—which is the only type of entity qualified to receive 340B discounts, see 42 U.S.C. § 256b(a)(1)—may not “resell or otherwise transfer” a drug for which it obtained a discount to anyone “who is not a patient of the [covered] entity,” 42 U.S.C.

§ 256b(a)(5)(B). This operates as a no-resale provision. Second, if the covered entity obtains a drug through section 340B, the covered entity may not request payment for medical assistance with respect to that drug if the same drug is subject to the payment of a Medicaid rebate. 42 U.S.C. § 256b(a)(5)(A)(i). “Medical assistance” includes Medicaid payments for “part or all of the cost” of prescription drugs, i.e. a subsidy. 42 U.S.C. §§ 1396d(a), 1396d(a)(12). To have its drugs covered by Medicaid, a manufacturer must agree to pay a rebate to the state Medicaid plan determined by the number of drug units that the plan covers. See 42 U.S.C. §§ 1396r–8(a)(1), 1396r–8(b)(1)(A), 1396r–8(c)(1)(A). To tie it all together, if a manufacturer pays a Medicaid rebate for a drug, then a covered entity cannot obtain from the manufacturer a 340B discount for the same drug. See Sanofi Aventis U.S. LLC v.

United States Dep’t of Health & Hum. Servs., 58 F.4th 696, 700 (3d Cir. 2023) (noting that “covered entities cannot get the 340B discount on drugs already subject to a Medicaid rebate” (citing 42 U.S.C. § 256b(a)(5)(A)(i)). This operates as a no-double-discount provision. Section 340B provides a number of avenues to ensure compliance and resolve disputes among HRSA, manufacturers, and covered entities. For one, a covered entity must permit HRSA and manufacturers to audit the “records of the entity that directly pertain to the entity’s compliance with the requirements” of section 340B. 42 U.S.C. § 256b(a)(5)(C). And section 340B provides for an administrative-dispute-resolution process to resolve claims of manufacturers’ overcharging and of covered entities’ violations of the no-resale and no-double- discount provisions. See 42 U.S.C. § 256b(d)(3). To opt into the 340B program, manufacturers must enter into a “form contract” with HHS called the Pharmaceutical Pricing Agreement (PPA). Astra, 563 U.S. at 115; see also 58 Fed.

Reg. 27,289, 27,289 (May 7, 1993). Neither section 340B nor the PPAs require manufacturers to transfer 340B drugs to anyone besides covered entities. See generally 42 U.S.C. § 256b; see also Astra, 563 U.S. at 113 (describing PPAs as “uniform agreements that recite the responsibilities [section] 340B imposes, respectively, on drug manufacturers and the Secretary of HHS”). B. Contract pharmacies 1. Legal framework As described above, only covered entities may obtain discounted drugs under section 340B. But what happens when, as is often the case, a covered entity doesn’t have a pharmacy of its own? In 1996, HRSA issued a notice stating its position that a covered entity that lacks an on-site pharmacy may, without violating section 340B, have an outside pharmacy receive and

dispense 340B drugs on the covered entity’s behalf: [Section 340B] is silent as to permissible drug distribution systems. There is no requirement for a covered entity to purchase drugs directly from the manufacturer or to dispense drugs itself.

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AbbVie Inc. v. Bailey, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abbvie-inc-v-bailey-moed-2025.