Heath R. Ingram

• Serves as day-to-day fraud and abuse and drug pricing counsel to pharmaceutical and medical device manufacturers by providing analysis of discount and rebate arrangements with customers, sales and marketing practices, drug price reporting analysis, market access strategy, patient assistance programs, financial arrangements with healthcare professionals, preparing policies and procedures, and assisting with internal training and compliance matters
• Negotiated numerous managed care and rebate agreements with pharmacy benefit managers, payors, and group purchasing organizations, on behalf of both emerging and prominent manufacturers
• Conducted many comprehensive drug pricing audits and implemented government price reporting calculations and policies, procedures, systems and methodologies
• Oversaw many substantial bona fide service fee and fair market value analysis projects 
• Negotiated multiple prescription benefit services agreements on behalf of large self-insured employers
• Counsels drug manufacturers on strategic approaches to compliance with all state drug transparency laws and regularly presents and publishes on new developments in these state laws
• Regularly advises both prominent and emerging pharmaceutical, biotechnology, and medical device manufacturers on strategic approaches to Sunshine Act compliance
• Advised companies on strategic approaches to compliance with all aspects of the 340B Drug Pricing Program and integration of the 340B Drug Pricing Program into business models
• Regularly conducts regulatory due diligence reviews for numerous life sciences transactions, including mergers and acquisitions, and in connection with IPOs and SPACs, and advise clients on fraud and abuse, compliance, licensure, corporate practice of medicine, HIPAA, change of ownership, and other healthcare issues

• Represented multiple pharmaceutical manufacturers in Department of Health and Human Services (HHS) Office of Inspector General (OIG) investigations into allegations the manufacturers misreported drug prices to the Medicaid Drug Rebate Program and other federal healthcare programs and missed drug price reporting deadlines
• Represented a large drug manufacturer in a Department of Justice (DOJ) investigation into the company’s discount arrangements with a drug distributor
• Testified as an expert witness on all aspects of drug manufacturer patient assistance programs including fraud and abuse, government price reporting, and other legal and regulatory implications
• Represented a large private equity firm in a DOJ investigation into a portfolio medical device company’s promotion and sale of regenerative medicine products.
• Conducted multiple internal investigations on behalf of pharmaceutical drug and device manufacturers in response to allegations of violations of the Anti-Kickback Statute, the False Claims Act, and internal compliance violations
• Represented a practice management company in a DOJ investigation involving allegations of “upcoding” and other alleged fraudulent billing and coding practices

2026

• Advised Collegium Pharmaceuticals on its acquisition of AZSTARYS from Corium Therapeutics for $650 million with the potential for additional milestone payments up to $135 million

2025

• Advised Avadel Pharmaceuticals, a commercial stage pharma company, on its definitive agreement to be acquired by Alkermes for $2.37 billion
• Advised Arthrosi Therapeutics a late state biotech company focused on developing a treatment for progressive gout, in agreement to be acquired by Sobi for $950 million upfront and $550 million in milestones
• Advised Cycle Pharmaceuticals in acquisition of Applied Therapeutics, a biotech company developing treatments for rare diseases
• Advised Moderna, Inc., a leading biotechnology company pioneering mRNA-based medicines, on its $1.5 billion five‑year credit facility provided by Ares Management
• Advised Epoch Senior Living, a leading provider of senior‑care services, on the sale of its senior living management platform to Cogir Real Estate
• Advised Semler Scientific, Inc., a medical technology company focused on cardiovascular disease detection, on its definitive agreement to be acquired by Strive, Inc. in an all‑stock transaction
• Advised LumiThera, an ophthalmic medical device company, on its acquisition by Alcon, a global leader in eye care
• Advised SpringWorks Therapeutics on its $3.9 billion acquisition by Merck
• Advised Blueprint Medicines Corporation, a biopharma company developing targeted therapies for rare diseases and cancer, on its agreement to be acquired by Sanofi for $129 per share in cash, valuing the deal at $9.5 billion including contingent value rights
• Advised Akili, Inc., a pioneer in cognitive digital therapeutics, on its agreement to be acquired by Virtual Therapeutics for $0.4340 per share in cash

2024

• Advised Deciphera Pharmaceuticals, a biopharmaceutical company focused on cancer therapies, on its $2.4 billion sale to ONO Pharmaceutical Co., Ltd. for $25.60 per share in cash
• Advised Aerovate Therapeutics, a biotechnology company focused on rare cardiopulmonary disease, on its all‑stock merger with Jade Biosciences to advance Jade’s portfolio of novel biologics, including JADE‑001 for IgA nephropathy
• Advised Anika Therapeutics, a global joint preservation company focused on early‑intervention orthopedic care, on the divestiture of its Arthrosurface business, receiving $10 million in consideration, including a $7 million promissory note and up to $3 million in performance‑based payments
• Advised AVROBIO, Inc., a gene therapy company focused on freeing patients from lifelong genetic disease, on its all‑stock merger with Tectonic Therapeutic
• Advised AlloVir, an allogeneic T‑cell immunotherapy company focused on restoring natural immunity in immunocompromised patients, on its all‑stock merger with Kalaris Therapeutics, a clinical‑stage biopharmaceutical company

2023

• Advised GreenLight Biosciences Holdings, PBC, a public benefit corporation developing RNA‑based solutions for human health and agriculture, on its $45.5 million all‑cash acquisition by a buyer group led by Fall Line Capital
• Advised Alkermes plc, a global biopharmaceutical company focused on developing innovative neuroscience medicines, on the separation of its oncology business into Mural Oncology plc, a new independent publicly traded company
• Advised Q32 Bio, a clinical‑stage biotechnology company developing biologic therapeutics to rebalance immunity in autoimmune and inflammatory diseases, on its all‑stock merger agreement with Homology Medicines
• Advised Graphite Bio in its all‑stock merger with LENZ Therapeutics. Graphite Bio, historically a clinical‑stage next‑generation gene‑editing company, discontinued development of its lead sickle cell disease program in 2023 and began evaluating strategic alternatives to maximize stockholder value
• Advised KBP Biosciences, a global clinical‑stage biotechnology company developing small‑molecule therapeutics for serious cardiorenal and infectious diseases, on its sale to Novo Nordisk of Ocedurenone for up to $1.3 billion
• Advised SunMed, a leading medical device manufacturer of anesthesia and respiratory care consumables, in its acquisition of Vyaire Medical’s respiratory and anesthesia consumables business; terms were not disclosed
• Advised SunMed Group Holdings, a leading medical device manufacturer of anesthesia and respiratory care consumables, in its definitive agreement to acquire Avanos Medical’s Respiratory Health business
• Advised PointClickCare Corp., the leading healthcare technology platform enabling collaboration and real‑time clinical insights across the patient journey, on its acquisition of Patient Pattern
• Advised Surface Oncology, an immuno‑oncology company developing next‑generation antibody therapies targeting the tumor microenvironment, on its definitive stock‑for‑stock merger agreement with Coherus BioSciences, a transaction valued at up to $65 million plus contingent value rights
• Advised BridgeBio Pharma, Inc., a commercial‑stage biopharmaceutical company developing transformative medicines for genetic and genetically driven cancers, on its underwritten public offering expected to generate approximately $150 million in gross proceeds
• Advised FibroGen, Inc., a biopharmaceutical company developing first‑in‑class therapeutics, on its non‑dilutive term loan facility with Morgan Stanley Tactical Value providing up to $150 million in proceeds

2022

• Advised Nimbus Therapeutics, a clinical‑stage, structure‑based drug discovery company developing novel small‑molecule medicines for difficult‑to‑drug targets, on its sale to Takeda of Nimbus Lakshmi, Inc. and its Tyk2 inhibitor program for $4 billion upfront and up to $2 billion in commercial-related milestone payments
• Advised Biocon Biologics, a fully integrated global biosimilars company leveraging advanced science and technology to expand access to biologic therapies, on its agreement to acquire Viatris’ biosimilars assets for up to $3.335 billion
• Advised CathWorks, a leader in digital health innovations, in its acquisition option and co‑promotion agreements with Medtronic, which provide for a potential purchase price of up to $585 million plus post‑closing earn‑out payments
• Advised Forma Therapeutics, a clinical‑stage biopharmaceutical company developing treatments for sickle cell disease and other rare blood disorders, on its acquisition by Novo Nordisk

2021

• Advised Blueprint Medicines, a global precision therapy company developing treatments for cancer and hematologic disorders, in its agreement to acquire Lengo Therapeutics for $250 million upfront and up to an additional $215 million in milestone payments
• Advised AbCellera, a technology company with a centralized operating system for next‑generation antibody discovery, in its acquisition of TetraGenetics
• Advised Chiasma, a commercial‑stage biopharmaceutical company developing oral therapies for rare and serious chronic diseases, in its all‑stock acquisition by Amryt Pharma
• Advised Arvinas, a clinical‑stage biopharmaceutical company developing therapies that degrade disease‑causing proteins, in its collaboration with Pfizer involving $650 million upfront, a $350 million equity investment, a worldwide profit‑share arrangement, and up to $1.4 billion in milestone payments

2026

• Advised Candel Therapeutics, a clinical stage biopharma company developing off the shelf multimodal immunotherapies, on its $100 million underwritten public offering and $100 million royalty funding agreement with RTW

2025

• Advised Prime Medicine, a biotechnology company developing next‑generation gene‑editing therapies, on its $144.2 million underwritten public offering

2024

• Advised TELA Bio, Inc., a commercial‑stage medical technology company focused on preserving and restoring patients’ anatomy, on its $46 million underwritten public offering of common stock and pre‑funded warrants
• Advised Septerna, a clinical‑stage biotechnology company pioneering GPCR‑targeted oral small‑molecule drug discovery, on its $288 million upsized initial public offering
• Advised Upstream Bio, a clinical‑stage biotechnology company developing treatments for inflammatory diseases, on its $293 million upsized initial public offering
• Advised MBX Biosciences, a biopharmaceutical company developing precision peptide therapies for endocrine and metabolic disorders, on its $188 million upsized initial public offering
• Advised the underwriters for Taysha Gene Therapies, a clinical‑stage biotechnology company developing AAV‑based gene therapies for severe monogenic CNS diseases, on its $75 million underwritten public offering

2023

• Advised the initial purchasers and dealers on Amphastar, a biopharmaceutical company specializing in complex generic and proprietary injectable, inhalation, intranasal, and insulin API products, in its $345 million offering of 2.00% convertible senior notes
• Advised the initial purchasers and dealers on Enovis Corporation, an innovation‑driven medical technology company, in its $460 million offering of 3.875% convertible senior notes and related capped call transactions

2022

• Advised Amylyx Pharmaceuticals, a company developing therapies for neurodegenerative diseases, in its $190 million upsized initial public offering
• Advised Cerevel Therapeutics, a clinical‑stage biopharmaceutical company developing treatments for neuroscience diseases, in its $254 million public offering of common stock and concurrent $300 million private offering of convertible senior notes
• Advised PepGen, a clinical‑stage biotechnology company developing next‑generation oligonucleotide therapies for severe neuromuscular and neurological diseases, in its $108 million initial public offering
• Advised Acrivon Therapeutics, a clinical‑stage biopharmaceutical company developing precision oncology medicines using its AP3 platform, in its $99.4 million initial public offering and concurrent private placement

2021

• Advised Femasys, a biomedical company developing novel, next‑generation solutions to transform women’s healthcare, in its $34.45 million initial public offering
• Advised Centessa Pharmaceuticals, a clinical‑stage company employing an asset‑centric R&D model to develop impactful medicines, in its $379.5 million initial public offering
• Advised Privia Health Group, a technology‑driven national physician‑enablement company, in its $607.8 million initial public offering
• Advised Valneva, a specialty vaccine company developing prophylactic vaccines for infectious diseases with significant unmet medical need, in its approximately $107.6 million global offering, including its initial public offering
• Advised Graphite Bio, a clinical‑stage, next‑generation gene‑editing company developing targeted gene‑integration therapies for serious and life‑threatening diseases, in its $273.7 million upsized initial public offering
• Advised Absci, an AI‑powered synthetic biology company unlocking the potential of proteins as next‑generation therapeutics, in its $230 million initial public offering
• Advised Rapid Micro Biosystems, a life sciences technology company providing automation solutions for the efficient manufacturing and safe release of healthcare products, in its $158.4 million initial public offering
• Advised Cerevel Therapeutics, a clinical‑stage biopharmaceutical company developing targeted neuroscience therapies grounded in neurocircuitry and receptor‑selective science, in its $350 million public offering

• Advised pharmacy benefits managers (PBMs) on obtaining PBM and third-party administrator licenses in all 50 states
• Obtained Clinical Laboratory Improvement Amendments certificates for drug and laboratory companies 
• Advised pharmacies on pharmacy licensure requirements

• Co-founded OUTbio Greater New York, a non-profit organization dedicated to advancing LGBTQ equality, health, and wellness in the life sciences industry, where he advises on corporate matters and service agreements
• Serves as a lead outside counsel to The Trevor Project, the world’s largest suicide prevention and crisis intervention organization for LGBTQ young people, where he assists in negotiating service agreements, data privacy and security, healthcare regulatory issues, and employment law

2026

• Author, “CMS Finalizes Changes to Bona Fide Service Fee Requirements, Alongside Other Adjustments to Medicare Part B Drug Reimbursement Methodology,” 80, Employee Benefit Plan Review,” 2, January 2026

2023

• Co-Author, “4 Key Issues Driving Drug Discount Abuse Must Be Addressed,” Law 360, January 1, 2023

2022

• Author, “Heating Up: Federal Sunshine Act Enforcement on the Rise," 76, Employee Benefit Plan Review, 1, February 2022

2021

• Co-Author, “District Court Finds Favorably For Manufacturers in 340B Contract Pharmacy Dispute,” WLF Legal Pulse, Washington Legal Foundation, November 5, 2021
• Co-Author, “HRSA Takes Additional Measures to Enforce Unclear, Inconsistent 340B Contract Pharmacy Requirements,” WLF Legal Pulse, Washington Legal Foundation, September 30, 2021
• Co-Author, “Probing HHS for Consistency on the 340B Pricing Program Rules on Contract Pharmacies,” WLF Legal Pulse, Washington Legal Foundation, September 13, 2021
• Author, “State Drug Transparency Laws: Considerations for Pharmaceutical Manufacturers,” Health Law Watch, Ch. 8: 265-301, American Health Law Association, 2021
• Co-Author, “Compensated Gestational Surrogacy Is Now Legal in New York: A Practical Toolkit to Ensure Compliance with the New York Child Parent Security Act,” Health Law Weekly, American Health Law Association, June 4, 2021
• Author, “Got Bacon?: The Use of A Bioethics Advisory Board in Assessing The Future of Transgenic Animal Technology,” Northwestern Journal of Technology and Intellectual Property, 2017

2026

• “Ninth Circuit Enables 340B False Claims Act Enforcement,” Goodwin Client Alert, March 2026
• “Express Scripts Settles PBM FTC Action and Must Make Fundamental Changes to PBM Model,” Goodwin Client Alert, February 2026
• “Historic False Claims Act Enforcement Illustrates Trump Administration’s Focus on Healthcare Fraud,” Goodwin Client Alert, January 2026

2025

• “CMS Releases MFN Drug Pricing Models for Medicare Parts B and D and Medicaid Amid Trump Administration’s Push for Direct-to-Consumer Strategy,” Goodwin Client Alert, December 2025
• “CMS Finalizes Changes to Bona Fide Service Fee Requirements, Alongside Other Adjustments to Medicare Part B Drug Reimbursement Methodology,” Goodwin Client Alert, November 2025
• “340B Rebate Pilot Program Proposed by HRSA,” Goodwin Client Alert, August 2025
• “Move Fast: FDA is Accepting Submissions for the Pilot Program Class for FDA Commissioner’s National Priority Voucher Program,” Goodwin Client Alert, August 2025
• “Changes to Birthright Citizenship and the Impact on Fertility and Assisted Reproduction Clinics,” Goodwin Client Alert, July 3, 2025
• “Prescription Drug Affordability Review Boards – 2025 Update,” Goodwin Client Alert, June 2025
• “State Drug Transparency Laws – 2025 Update,” Goodwin Client Alert, June 2025
• “Most Favored Nations Drug Pricing Executive Order Resurrects Prior President Trump Policy,” Goodwin Client Alert, May 2025 

2023

• “A Practical Look at OIG’s New Compliance Guidance,” Goodwin Client Alert, November 2023
• “Significant 340B Drug Pricing Program Litigation May Impact 340B Scope,” Goodwin Client Alert, November 2023
• “2023 State Drug Transparency Law Development Update,” Goodwin Client Alert, November 2023
• “White House Unveils Landmark Executive Order on Safe, Secure, and Trustworthy Artificial Intelligence,” Goodwin Client Alert, October 2023
• “Federal Court Strikes Down Copay Accumulator Programs,” Goodwin Client Alert, October 2023
• “CMS Issues Guidance and Solicits Comment on the 2026 Inflation Reduction Act Part D Negotiation Process,” Goodwin Client Alert, April 2023
• “HHS to Create New Potential Medicare Pricing Models for Cell and Gene Therapy, Drugs Subject to Accelerated Approval, and ‘High Value’ Generics,” Goodwin Client Alert, March 2023
• “CMS Issues Proposed Guidance on Inflation Rebates Under Medicare Part B,” Goodwin Client Alert, February 2023
• “CMS Issues Proposed Guidance on Inflation Rebates Under Medicare Part D” Goodwin Client Alert, February 2023
• “Federal Court of Appeals Rejects HHS Stance on Section 340B Contract Pharmacies” Goodwin Client Alert, January 2023
• “CMS Issues First Request for Public Comments on Medicare Drug Price Negotiation Program ‘Small Biotech’ Exception – Due March 27, 2023” Goodwin Client Alert, January 2023

2022

• “Significant Drug Pricing Reform Measures in the Inflation Reduction Act of 2022” Goodwin Client Alert, August 2022
• “Pharma Manufacturer Federal Price Reporting: Recent Litigation and Settlements” Goodwin Client Alert, August 2022
• “DOJ False Claims Act Recoveries Exceed $5.6 billion in 2021” Goodwin Client Alert, March 2022
• “Medicare Agrees to Limited Payment for New Alzheimer’s Drug” Goodwin Client Alert, January 2022
• “Attention Pharmaceutical Manufacturers: New State Drug Transparency Laws and Enforcement Mechanisms Are Coming in 2022” Goodwin Client Alert, October 2021 

2021

• “CMS Proposes New Updates to the Sunshine Act’s Open Payments Program,” Goodwin Client Alert, July 2021

2020

• “President Trump Signs Four Executive Orders Designed to Reduce Drug Prices,” Goodwin Client Alert, August 2020