Jonathan M. Phillips

Partner, Washington, D.C.

+1 202.887.3546

Jonathan Phillips is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher, where he is a member of the firm’s litigation department and Co-Chair of the FDA and Health Care Practice Group and False Claims Act/Qui Tam Defense Practice Group. A former DOJ Trial Attorney, his practice focuses on FDA and health care enforcement, compliance, and litigation, as well as other white collar enforcement matters and related litigation. Mr. Phillips is ranked nationally as a leading False Claims Act practitioner by Chambers USA.

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2026 Life Sciences Industry Outlook: Regulatory Environment

January 16, 2026 | Posted by Katlin McKelvie; John D.W. Partridge; Lindsay M. Paulin; Michael J. Perry; Jonathan M. Phillips; Adam M. Smith; Carlo Felizardo; Samantha Sewall; Hui Fang; Jenna Raspanti; Lindsay Bernsen Wardlaw; Topic(s): Antitrust; False Claims Act; FDA; FDA Guidance; Government Regulation; International Trade; Trends and Insights

Welcome to Part 5 of our 2026 Life Sciences Industry Outlook series. Today, we are wrapping up the week with a review of the regulatory environment for life sciences companies in 2025 and our expectations for what 2026 could bring.

In 2025, life sciences companies faced a fast-moving regulatory environment shaped by the Trump administration’s priorities, including deregulation, the use of policy levers to encourage domestic manufacturing and development, and efforts to reduce healthcare costs for American consumers. We expect this unpredictable atmosphere to continue into 2026. In particular, we anticipate regulatory and enforcement developments in FDA regulation, drug pricing and reimbursement, government contracts, tariffs, and antitrust oversight, although specific outcomes and impacts remain difficult to predict.

Trump Administration Revives Possibility of MFN Drug Pricing: Key Implications for the Life Sciences Industry

May 15, 2025 | Posted by Rachel E. Baron; Wynne Leahy; Carlo Felizardo; Jonathan M. Phillips; John D.W. Partridge; Katlin McKelvie; Topic(s): FDA; Government Regulation; Trends and Insights

On May 12, 2025, President Trump signed an Executive Order (“EO” or “Order”) “Delivering Most-Favored-Nation Prescription Drug Pricing to American Patients” aimed at significantly reducing U.S. prescription drug prices by aligning them with the lowest prices paid by other developed nations. According to the EO, drug manufacturers “deeply discount their products to access foreign markets and subsidize that decrease through enormously high prices in the United States.” Seeking to rectify this “egregious imbalance,” the EO announced the following policy: “Americans must therefore have access to the most-favored-nation price for these products… [and] should drug manufacturers fail to offer American consumers the most-favored-nation lowest price, [the] Administration will take additional aggressive action.”