Fighting for a Better
Healthcare Future
Through Advocacy

Advocating for fairness, transparency, and integrity across the pharmaceutical supply chain.

Gatekeeper Compliance Program · Healthy People Healthy Planet

Healthcare deserves leaders who advocate, not just operate.
This standard is reflected in how we engage with partners, providers, and policymakers.

Publications & Resources

View our published insights, policy contributions, and formal filings.

May, 2025 232 BIS Comment Read more…

Submitted comment to the Department of Commerce for review during its Section 232 National Security Investigation into pharmaceutical and pharmaceutical ingredient imports.

232 BIS Comment
May, 2024 Hercules FTC / HHS Comment on Competition & Drug Shortages Read more…

Regarding the Federal Trade Commission (FTC) and U.S. Department of Health and Human Services (HHS) Solicitation of Public Comment to Understand Lack of Competition and Contracting Practices that May be Contributing to Drug Shortages.

Hercules FTC / HHS Comment on Competition & Drug Shortages
December, 2024 Podcast Excerpt: Organized Money — The Artificial American Drug Shortage Read more…

The great American drug shortage isn’t an accident — it’s artificial.

Podcast Excerpt: Organized Money — The Artificial American Drug Shortage
September, 2022 Comments on Proposed National Standards for the Licensure of Wholesale Drug Distributors & Third-Party Logistics Providers Read more…

Submitted comments on FDA’s proposed rule regarding National Standards for the Licensure of Wholesale Drug Distributors and Third-Party Logistics Providers.

Comments on Proposed National Standards for the Licensure of Wholesale Drug Distributors & Third-Party Logistics Providers
September, 2021 Comments on the US Food & Drug Administration’s Draft Guidance Documents Read more…

Submitted comments on two FDA draft guidance documents related to the Drug Supply Chain Security Act: (i) definitions of suspect and illegitimate products for verification obligations, and (ii) enhanced drug distribution security at the package level.

Comments on the US Food & Drug Administration’s Draft Guidance Documents
April 2021 Pharmaceutical Supply Chain Analysis Read more…

Analysis of the U.S. supply chain for critical drugs and medical devices, potential public health security or national security risks, existing supply chain information gaps and the potential economic impact of increased domestic manufacturing.

Pharmaceutical Supply Chain Analysis

Ethical leadership means showing up where it matters.