By Grant P. Bagley, M.D., J.D., a partner in Arnold & Porter LLP’s Washington, D.C., office, where his practice focuses on the representation of drug and device manufacturers for regulatory and reimbursement matters before public and private agencies; and Rosemary Maxwell, Counsel to the law firm Arnold & Porter LLP in its Washington, D.C. office. Ms. Maxwell focuses on healthcare compliance and public policy issues.