People

Diane M. Signoracci

Diane Signoracci has practiced in the areas of hospital and health care provider reimbursement, regulation and compliance for over 35 years. Diane's clients include hospitals, hospital systems and hospital-affiliated physician practices, home health agencies, medical equipment suppliers, independent diagnostic testing facilities and hospices. Her practice encompasses Medicare and Medicaid billing compliance, government and commercial payer-billing investigations and audits, provider reimbursement appeals, EMTALA compliance and defense, managed care contracting, hospital-physician contracting, response to OIG and DOJ subpoenas and Civil Investigative Demands, litigation involving health care fraud and qui tam defense, hospital-vendor contracting and hospital-payer contracting, and dispute resolution of hospital-vendor and hospital-payer disputes.

Diane is a frequent speaker on health related topics, including current Individual Accountability for Corporate Wrongdoing, hospital charges and discounts, health care provider's obligation to report and refund overpayments, self-disclosure options for health care providers, and Medicare and Medicaid managed care contracting.

Additionally, Diane served as law clerk to the Hon. John D. Holschuh of the U.S. District Court, Southern District of Ohio from 1981–1982.

"Diane Signoracci has a wealth of experience in health care regulation, reimbursement and compliance matters."

As quoted in Chambers USA, 2019

"Diane is extremely detail-oriented and has an incredible understanding of the regulatory environment."

Bricker client as quoted in Chambers USA, 2018

"Diane Signoracci is 'our go-to person for things related to in-depth compliance and governmental, Medicaid issues.'"

Bricker client as quoted in Chambers USA, 2017

Experience

  • Appeals of RAC denials

    Guided multiple hospitals and health systems through the Medicare appeals process for Recovery Audit Contractor (RAC) claim denials and overpayment determinations. This matter involved preparing hospitals for RAC audits and managed appeals involving a wide array of billing issues through the Administrative Law Judge hearing process and Medicare Appeals Council (MAC), when necessary.

  • Health care information database

    Assisted in the development of a state-wide database for health care information reports, including the creation of policies and agreements and compliance with regulatory requirements (including HIPAA). Also worked to revise protocols for state-to-state relationships, the sharing of data and related data sharing agreements.

  • Amicus in support of HHS interpretive rule

    Prepared an amicus brief on behalf of the American Hospital Association in support of the U.S. Department of Health and Human Services (HHS) interpretive rule providing guidance on the scope of the exclusion of orphan drugs from 340B discounts. 

  • False Claims Act defense

    Successfully defended, through appeal to the United States Court of Appeals for the Sixth Circuit, a qui tam action brought under the False Claims Act on behalf of a hospital system who was alleged to have violated the Health Information Technology for Economic and Clinical Health (HITECH) Act by improperly certifying its compliance with the HITECH Act in exchange for receiving meaningful use payments.

  • System-wide electronic medical record system

    Assisted a large health system with the system-wide implementation of an electronic health records (EHR) system, ensuring legal and regulatory compliance, HIPAA security and continuity of patient care. 

  • Management services organization development

    Served as lead counsel to an Ohio-based health network in developing a unique physician-led management services organization (MSO) providing day-to-day operation and management of multiple breast health centers. This unique MSO also developed a clinically integrated incentive strategy within the network of primary care and OB-GYN physicians to implement a physician-designed evidence-based patient protocol to enhance breast health, early detection and prevention in the health network's market area. 

Professional & Community Activities

  • Member, Healthcare Financial Management Association
  • Member, Society of Ohio Hospital Attorneys
  • Member, American Health Lawyers Association

Presentations & Published Works

  • Speaker, "Preserving Attorney-Client Privilege in Internal and External Investigations," Ohio Hospital Association Annual Meeting, June 2018
  • Speaker, "Provider Self-Disclosure Options: Reducing the Risk of Overpayments," Ohio Hospital Association Annual Meeting, June 2017
  • Speaker, "The Yates Memo: Individual Accountability Under the False Claims Act," University Hospitals Health System, May 2017
  • Speaker, "The Obligation to Report and Refund Overpayments," Ohio Hospital Association Annual Meeting, June 2016
  • Speaker, "Hospital Pricing – Emerging Compliance Issues," Ohio Hospital Association Annual Meeting, June 2015
  • Speaker, "Avoiding the Latent Hazards of Poorly Negotiated Hospital Contracts: What Every Hospital Should Know Before Signing on the Dotted Line," Ohio Hospital Association Annual Meeting, June 2015
  • Speaker, "Inpatient or Observation? Practical Advice for Hospitals on Compliance with CMS’ 'Two Midnight' Benchmark," AHLA Annual Meeting, June 30, 2014
  • Speaker, "Medicare Inpatient Admission Standards: Two Midnight and Physician Certification Rules," HFMA Southwest Chapter, May 15, 2014
  • Speaker, "The Obligation to Report and Refund Over Payments," OHA Annual Meeting, June 11, 2013

Bar Admissions & Activities

  • Admitted, State of Ohio, 1981
  • Admitted, U.S. Supreme Court, 1994
  • Admitted, U.S. Court of Appeals for the Sixth Circuit
  • Admitted, U.S. District Court, Southern District of Ohio, Eastern Division, 1992
  • Admitted, U.S. Court of Appeals, District of Columbia, 1994
  • Admitted, U.S. District Court, District of Columbia, 1993
  • Admitted, District of Columbia Court of Appeals, 1991
  • Member, Ohio State Bar Association
  • Member, District of Columbia Bar Association

Awards & Recognition

  • Recognized, ChambersUSA, Health Care with a Band 3 ranking, 2013–2020
  • Listed, Best Lawyers in America (Health Care Law), 1999–2020
  • Listed, Ohio Super Lawyers (Health Care), 2004–2016
  • Listed, Top 25 Women Columbus, Ohio Super Lawyers, 2010, 2013–2014
  • Columbus Lawyer of the Year, Best Lawyers in America (Health Care Law), 2013

Education

  • The Ohio State University Moritz College of Law (J.D.) 1981; Member, Order of the Coif; Member, editorial staff, The Ohio State Law Journal
  • Franklin University (B.S.) 1978
Active Lay Minister
Active Lay Minister

Diane is active in lay ministry for St. Michael's Catholic Church, where she serves as a parish finance committee member, choir member, lector/cantor, Eucharistic minister for the homebound and treasurer of the altar society.