Hospital Employment of Physicians: Stark Law and Anti-Kickback Statute Compliance, Physician-Hospital Alignment

Ms. Gross practices in the firm’s regulatory and business departments, where she assists health care providers, including hospitals, physicians, and health services companies with a broad range of corporate, transactional, compliance, and reimbursement issues. Prior to attending law school, Ms. Gross served as a program analyst with the Center for Consumer Information and Insurance Oversight within the Centers for Medicare & Medicaid Services. In that role, Ms. Gross was responsible for drafting portions of the first regulations establishing the Affordable Care Act’s health insurance exchanges and played a lead role in operationalizing the health plan certification process.

Mr. Oppenheim’s practice includes all aspects of transactional, operational and regulatory healthcare law, including mergers & acquisitions, affiliations, joint ventures and the formation of integrated delivery systems. Among his clients are many of the largest healthcare companies and hospital systems in the U.S. A nationally-recognized expert on anti-kickback and Stark Law issues, Mr. Oppenheim wrote the 2014 American Health Lawyers Association Monograph on Stark. He has served as an expert on anti-kickback and Stark Law issues in arbitration and litigation, in both civil and criminal proceedings. In addition, he creates and implements compliance programs, investigates compliance issues, responds to government enforcement actions, and negotiates settlements for many types of healthcare providers.

Mr. Ulrich is focused on providing valuation and consulting services for contractual service arrangements within the healthcare services industry. He has particular expertise in valuations relating to provider employment, on-call coverage, physician administrative and executive services, telemedicine, hospital-based coverage, management / billing, and quality initiatives. Prior to joining the Compensation Division, Mr. Ulrich worked in VMG Health’s Business Valuation division where he provided valuation services related to hospitals, specialty/surgical hospitals, ambulatory surgical centers, diagnostic imaging centers, and single and multi-specialty physician practices. He is currently designated as a Certified Valuation Analyst (CVA) and is a member of the National Association of Certified Valuation Analysts.