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Madison M. Castle

Associate

[email protected]

+1.202.434.7309

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Madison focuses her practice on health care regulatory, transactional, privacy, and compliance matters. She represents clients across the health care sector, including providers, physician organizations, PBMs, pharmacies, and health care systems. 

While earning her JD, Madison served as an extern at the Center for Scientific Responsibility and Justice, which is part of the American Association for the Advancement of Science. In that role, she conducted legal research for amicus briefs concerning topics at the intersection of science and civil rights, including race, sex, and disability discrimination in STEM education and employment. She also interned with the National Health Law Program (NHeLP), where she researched state Medicaid program requirements, the Affordable Care Act and related case law. During her time at NHeLP she also prepared a legal memorandum analyzing nonprofit hospitals' charity care spending. In addition, while working as a law clerk for Health Law Advocates, Madison conducted research on and assisted with cases involving Medicaid coverage.

In law school, Madison earned a JD with a concentration in Health Law. She also served as a student attorney at GW Law’s Health Rights Law Clinic and an Administrative Law teaching assistant.

viewpoints

A year has passed since Congress enacted the Modernization of Cosmetics Regulation Act (MoCRA) and enhanced the Food and Drug Administration’s (FDA) authority to regulate the cosmetics industry. Although MoCRA implementation efforts steadily increased throughout the calendar year, as the December 29, 2023 compliance date for most MoCRA provisions approached, FDA’s release of information and deployment of new systems for the industry came to a climax. Several recent MoCRA-related developments will influence how cosmetic industry stakeholders, consumers, and even the FDA will approach and navigate the law’s requirements over the next year. In this blog post, we will discuss each of these developments and forecast the law’s future as we move into 2024.
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Since the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) was signed into law, cosmetics companies have spent the past year preparing to comply with its provisions. This includes the facility registration and cosmetic product listing requirements that have were mandated by Congress in the new law. Under MoCRA, the statutory deadline for meeting these foundational requirements is set at December 29, 2023 (one year after MoCRA’s enactment). However, on November 8, 2023, the Food and Drug Administration (FDA) issued Guidance for Industry: Compliance Policy for Cosmetic Product Facility Registration and Cosmetic Product Listing (Compliance Guidance) and announced that enforcement of facility registration and cosmetic product listing requirements will be delayed six months.
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On October 30, 2023, the Biden Administration released and signed an Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence (Executive Order) that articulates White House priorities and policies related to the use and development of artificial intelligence (AI) across different sectors, including health care.
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Publications

  • Co-author, “California Health Programs Must Take Steps to Implement Non-Binary Gender Markers,” National Health Law Program (July 2022)
  • Co-author: "HIPAA happenings: 2023 year in review." Compliance Today (March 2024)
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