Prepared several options for a health system and physician-owned surgical hospital to affiliate in a secondary market. Provided regulatory advice, including an analysis of potential Stark Law and Anti-Kickback Statute compliance issues, as well as antitrust and federal tax law advice.

Represented a home health agency in its appeal of post-Medicare Change of Ownership Request for Anticipated Payment suspension imposed by the Centers for Medicare and Medicaid Services. Successfully appealed the payment suspension, which was worth $15 million.

Represented a health system in its sale of a skilled nursing facility to the management firm of the nursing facility. Formulated potential structures, drafted and negotiated various agreements, and implemented each agreement’s operation. The sale involved a bed purchase agreement, Medicare change of ownership, certificate of need and comprehensive facility and operating lease, as well as several regulatory filings.

Reviewed the HIPAA policies of two regional health plans to ensure continued compliance with relative state laws. These regional health plans were part of a national health plan’s portfolio and also required compliance with the national plan’s policies on HIPAA privacy, security and breaches.