Michael Gaba provides strategic FDA regulatory, Medicare policy, and federal relations counsel to an array of companies developing a variety of products in the life sciences space, whether traditional medical devices, digital health-based products, biotechnologies, biologic-device combinations, or pharmaceuticals. His primary goal is to bring companies to market and then help them remain there in the most efficient and effective manner possible.

Working as an extension of each company’s legal and business teams, Michael draws on nearly 30 years of experience to navigate the FDA pre-market regulatory pathways, counsel companies on FDA post-market compliance matters, and resolve Medicare coverage, coding, and reimbursement disputes with the Centers for Medicare and Medicaid Services. By using his FDA and CMS experience during the product development phase, Michael is able to help maximize companies’ opportunities to be appropriately compensated in the proper treatment venues, whether a physician's office, hospital outpatient or inpatient departments, ambulatory surgical centers or home care.

During the COVID-19 pandemic, Michael provided strategic FDA counsel to many medical device and diagnostic companies, including several first-time entrants to the medical device space, helping them obtain emergency use authorizations from the FDA, and advising them on how to comply with FDA’s pandemic-focused enforcement discretion policies. Michael continues to advise these companies on transitioning to full FDA compliance in the post-pandemic environment.

There are times when federally-regulated life science companies and the patients they serve would benefit from changes to public policy, Michael works with members of Congress and Executive Branch officials to develop, enact and implement these policy changes.

Education

  • The George Washington University Law School (J.D., 1986)
    • Franklin & Marshall College (B.A., 1983)
      • Government

    Bar Admission

    • Maryland, 1987
    • District of Columbia, 1988

    Court Admissions

    • U.S. District Court for the District of Columbia, 1988
    • State of Maryland, 1987

    Professional Affiliations

    • American Health Law Association
    • Maryland Bar Association
    • District of Columbia Bar Association
    • Food and Drug Law Institute

    Recognition

    • Ranked in Chambers USA: America's Leading Lawyers for Business, Healthcare Pharmaceutical/Medical Products Regulatory, District of Columbia, 2007­-2014, 2021-2025
    • Selected for inclusion in Best Lawyers in America® for Health Care Law, 2014­-2026
    • FDAnews Medical Device Conferences Advisory Board Member, 2017-present
    • AdvaMed, Medical Technology Learning Institute Advisory Council, 2015-­present
    • Food & Drug Law Institute, Food & Drug Law Journal Editorial Advisory Board, 2009-­2013
    • Bloomberg BNA Medical Devices Law & Industry Report ­ Advisory Board, 2007­-2018
    • Food & Drug Law Institute, H. Thomas Austern Writing Awards Committee, 2006-­2010
    Publications
    Beyond the Pump: The Iran War’s Adverse Impact on U.S. Health Care
    Key Takeaways The closure of the Strait of Hormuz following the U.S.-Iran conflict is disrupting global health care supply chains and increasing costs for critical medical products. Shortages and delays are already affecting pharmaceuticals, MRI-related helium supplies and cold-chain products. The disruptions create operational and financial pressure for health care providers that depend on imported drugs, medical equipment and time-sensitive supplies. Rising freight, fuel and insurance costs are contributing to higher prices and longer lead times across multiple product categories. Health care organizations should closely monitor supply availability, transportation delays and pricing volatility tied to the ongoing conflict and shipping restrictions. Providers may need to evaluate inventory levels, supplier diversification and contingency planning for critical medical inputs. Since the beginning of the United States’
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    FDA Signals it Has No Appetite to Add Popular GLP-1 Drug Substances to the 503B Bulks List
    Key Takeaways FDA has proposed excluding semaglutide, tirzepatide and liraglutide from the 503B bulks list. The proposal would materially limit 503B bulk compounding of these GLP-1 products. Comments on the proposal are due June 29, 2026. Bulk compounders should consider submitting comments that directly address FDA’s clinical-need framework, including patient safety considerations and any specific medical necessity for compounding these products from bulk drug substances. On April 30, 2026, FDA proposed to exclude semaglutide, tirzepatide and liraglutide from the 503B bulks list via a Federal Register notice published on May 1, a move that, if finalized, would limit mass compounding of these substances by outsourcing facilities. FDA explained that, after reviewing nominations for semaglutide, tirzepatide and liraglutide, it found no demonstrated clinical need for outsourcing
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