Skip to main content

Ariane Horn focuses her practice on fraud and abuse compliance and pharmaceutical market access. Ariane advises pharmaceutical, biotechnology, and medical products companies on a wide variety of complex arrangements with pharmacy benefit managers, group purchasing organizations, specialty pharmacies, integrated delivery networks, healthcare professionals, and vendors that administer manufacturer patient support programs. Her counseling in this area includes questions related to compliance with the federal Anti-Kickback Statute, the False Claims Act, the Civil Monetary Penalties & Exclusion laws, and their state law analogs. Ariane has extensive experience with securing favorable advisory opinions from the Office of Inspector General of the U.S. Department of Health & Human Services, particularly with respect to manufacturer patient support programs. In addition, Ariane regularly counsels clients on the roles of field-based personnel (e.g., commercial, medical, and patient support roles), communications with payers and other population health decision-makers, and use of telemedicine. Prior to joining the firm, Ariane worked for many years as in-house counsel for a major pharmaceutical company.

Experience

  • Lead counsel in connection with requests for advisory opinions from the Office of Inspector General of the US Department of Health and Human Services.
  • Conducted various comprehensive internal business reviews assessing compliance with federal laws relating to healthcare fraud and abuse, including the Anti-Kickback Act.
  • Negotiation and development of numerous complex commercial contracts with pharmacy benefit managers, insurance companies, wholesalers, pharmacies, hospitals, and many other commercial customers.
  • Counseling a variety of clients on structuring and implementing a variety of patient support programs, including co-pay assistance programs, free product programs for financially needy patients, coverage/reimbursement support, and patient educational programs.
  • Served on company promotional and non-promotional material review committees for multiple pharmaceutical manufacturers, including in support of new product launches.

  • Developed and helped implement compliance policies and procedures.
  • Conducted numerous in-house trainings for small and large groups (legal and non-legal personnel) concerning fraud and abuse compliance, FDA regulation of promotion, and enforcement trends.

Recognition

LMG Life Sciences Guide
"Life Sciences Star" FDA: Pharmaceutical (2024)
BTI Consulting Group
BTI Client Service All-Star (2023)
"Ariane is business first and she always provides a definitive response — I trust her implicitly."
The Legal 500 US
Healthcare: Life Sciences (2021-2022)
"Next Generation Lawyer" – Healthcare: Life Sciences (2017-2019)

Credentials

Education

  • J.D., Cornell Law School, 1996, cum laude
  • B.A., Cornell University, 1991, cum laude

Admissions

  • District of Columbia
  • New York
  • U.S. District Court, Eastern District of New York
  • U.S. District Court, Southern District of New York

Clerkships

  • U.S. District Court, Western District of New York, The Honorable John T. Curtin
Overview