AHLA June 2015 Volume 19 Issue 6

For the and life sciences law community

Top Honors 2015 (page 10)

Fiduciary Duties of Officers and Directors (page 20)

Is Your Physician Compensation Governance Process Ready? (page 28)

OFFICIAL MAGAZINE OF AMERICAN HEALTH LAWYERS ASSOCIATION SAI GLOBAL GIFT TRACKER Makes it Simple To Adhere to Federal Stark Laws & The Physicians Payments Sunshine Act

SAI Global Compliance’s Physician Non-Monetary Our Physician’s Non-Monetary Compensation Tracker: Compensation Tracker will help your organization establish a compliance “system of record” and improve compliance • Enables users to request approval to accept or give a gift or hospitality within a certain limit processes as information is centrally maintained and secured in one place; giving you simple recordkeeping and • Supports automated or manual approval based on your reporting. standardized processes

• Provides easy, secure search and find capabilities for The automated workflow process improves communication quick retrieval of information as disclosures are routed to the proper individual who can approve, deny or request more information in a timely way. • Includes configurable workflow with automated alerts and reminders for key dates and assigned activities Our Non-Monetary Gift Tracker Manager allows you to know what disclosures have been reported and what actions have • Actionable online dashboards and reports for monitoring been taken to resolve issues and mitigate risks. activity and trends

Call us @ +1-877-470-SAIG www.saiglobal.com/compliance First Reflections

Lessons Learned

“Leadership and learning are Tell our members they Be patient. Remember that it indispensable to each other.” 2 don’t need a title to be 4 takes at least 10,000 hours –Undelivered remarks of John F. Kennedy, an AHLA leader. to become an expert. Dallas Trade Mart, November 22, 1963 Most of what AHLA accomplishes The mastery of any skill or subject every day is performed by members matter takes time. Human beings are As I approach the end of my and staff who may never be the head a naturally impatient, but through self- term, I thought I’d share what I practice group, council, or committee. discipline, perpetual learning and the have learned as AHLA President The primary mission of our organiza- steady support of others, most people with anyone who aspires to hold tion is to provide a “collegial forum” for can rise above mediocrity and make this office in the future. educating one another and the public a difference. What a joy it has been to about issues. That work can witness the success of so many AHLA Derive your leadership and should be done through the regular members during my nine-year tenure on 1 from your passion, exchange of knowledge using the many the Board of Directors. not from your position. communication channels sponsored by Serving as the president of a prestigious AHLA. In that sense, we all are leaders. Give others credit organization like the American Health 5 whenever it is due. Lawyers Association is a tremendous Expect your dreams to be It is often said that the road to success honor, certainly one of the high points 3 challenged before their is paved with failure. But as much as we of a professional career. I have learned, merit is appreciated. can learn from our mistakes, we can however, that a leader’s greatest impact As the president of a 13,000+ member learn even more by recognizing and does not come from the ability to make voluntary organization, one gets to hear appreciating the accomplishments of decisions or control events. Rather, many interesting but sometimes imprac- others. In a multi-dimensional organiza- leaders are given a special opportunity tical ideas. AHLA members are nothing tion like the AHLA, there are so many to use their passion to inspire others. if not creative. However, out of these unheralded success stories. Unfortu- Without question, the pursuit of profes- flights of fancy often comes the next nately, some of us find it hard to compli- sional excellence requires a great deal “killer app.” As proof, just consider the ment other members who do a good job. of hard work, but unless people are myriad of new programs, services and By failing to do that, we miss an oppor- instilled with a sense of curiosity and communities offered by AHLA today tunity to strengthen the culture of our purpose, their efforts often lack real that didn’t exist five years ago. We need organization and make it more resistant meaning. AHLA provides its members to nurture our dreamers and make sure to inevitable threats and pressures. with a fertile environment for all forms they help us remain relevant in a rapidly of thought leadership to blossom and changing world. Make decisions by grow. Be sure to fan that flame. 6 building consensus as much as possible. Most people prefer to make decisions on their own. Even when they are part of a group that needs to reach a common conclusion (e.g., a new hire, a different approach to solving a problem), indi- viduals don’t like being told by someone in authority to do something they have not already decided to do. This is espe- cially true in a professional association. Although there comes a time when every leader is required to make the final call on a particular issue, guiding others to a consensus may be the most important thing that a leader does on a regular basis.

(continued on page 48)

healthlawyers.org 1 In this issue

COLUMNS 1 First Reflections In his last column as AHLA President, Peter Pavarini shares ten “lessons learned” from his year as AHLA President.

10 AHLA Top Honors DEPARTMENTS AHLA Top Honors, now in its twelfth year, gives the Association the opportunity to 6 Connections to Learning honor the organizations behind our members—those law firms, organizations, plans and companies that consistently and enthusiastically encourage and sustain their 18 Mentoring members’ and employees’ affiliation with AHLA. 26 Public Interest 20 Fiduciary Duties of Officers and Directors of 34 Women’s Network 36 Focus On: Consultants & Financially Distressed Nonprofit Hospitals Expert Witnesses The first Feature, by Jay R. Bender, and John B. “Jay” Hardcastle, both from Bradley Arant Boult Cummings LLP, examines the fiduciary duties of officers and directors 38 Member News of financially distressed nonprofit hospitals. 42 Classified Advertising 28 Compensation-Focused Compliance: Is Your Physician Compensation Governance Process Ready for Shifts in Stark Law Enforcement? This month’s second Feature, by Joseph N. Wolfe, Hall Render Killian Heath & Lyman, and Alex T. Krouse, Krieg DeVault LLP, seeks to provide guidance for medical groups, hospitals, and health systems as they assess their compensation governance structures to ensure existing processes and internal controls support compensation-focused compliance in today’s shifting enforcement climate.

Postmaster: Send address changes to AHLA Connections, AMERICAN HEALTH LAWYERS ASSOCIATION, 1620 Eye Street, NW, 6th Floor, Washington, DC 20006-4010.

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2 AHLA Connections June 2015 INNOVATIVE HEALTH CARE COUNSEL

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We provide leading-edge advice to a wide range of health care clients on transactional, regulatory, operational, contractual, and litigation matters.

K&L Gates LLP. Global legal counsel across five continents. Learn more at klgates.com. AHLA

For the health and life sciences law community

David S. Cade Executive Vice President/ CEO (202) 833-0777 [email protected]

EDITORIAL

Editor in Chief Allison E. Beard Senior Manager, Communications, Social Media & Community Engagement (202) 833-0779 [email protected] Bianca L. Bishop Senior Managing Editor, Member Publications (202) 833-0757 [email protected]

Cynthia Conner Vice President, Professional Resources AHLA now offering free student membership! (202) 833-0755 [email protected] Put away your debit card, Google Wallet, Paypal, or bitcoin—Student member- Kerry B. Hoggard, CAE ship in AHLA is now FREE! AHLA knows that making the right connections Vice President, Membership & Public Interest and having the most timely analyses are crucial to advancing your career in (202) 833-0760 health law, and we are committed to helping students make these connections as [email protected] early as possible. Andrea Santos Editorial Assistant Share this amazing news with all of the students in your network. Marketing & Community Engagement Coordinator [email protected] Visit www.healthlawyers.org/join to become a member today. GRAPHICS AND ADVERTISING

Mary Boutsikaris Creative Director (202) 833-0764 [email protected]

Ana Tobin Graphic Designer (202) 833-0781 [email protected]

Advertising Information Karyn Kessler Network Media Partners Viewpoint/Writers’ Guidelines AHLA Connections must retain full copyright or unlimited (410) 584-1982 license before publishing. Factual accuracy and opinion contained in articles published in [email protected] AHLA Connections are the responsibility of the authors alone and should not be interpreted as representing the views or opinions of the Association. AHLA is a non-partisan educational organization that does not take positions on public policy issues and instead provides a forum for an informed exchange of views. Guidelines are available at www.healthlawyers.org/ AHLA Connections (ISSN 1949-9035) © 2015 is published each month, 12 times a year by AMERICAN connections or by calling (202) 833-0779. We welcome Letters to the Editor, no longer than HEALTH LAWYERS ASSOCIATION. Editorial, 250 words in length. Longer responses may be submitted to [email protected] and subscription and circulation offices at 1620 Eye Street, NW, 6th Floor, Washington, DC 20006-4010. Tel. (202) will be considered for publication on a space available basis, after review by our Editorial staff. 833-1100. All rights reserved. The price of an annual subscription for AHLA members ($45) is included The Mission of the American Health Lawyers Association is to provide a collegial forum for inseparably in their dues. An annual subscription for interaction and information exchange to enable its members to serve their clients more effec- non-members is $105. Periodicals postage paid at tively; to produce the highest quality non-partisan educational programs, products, Washington, DC, and at additional mailing offices. and services concerning health law issues; and to serve as a public resource on selected Copyright/Reprint Permission: For academic health care legal issues. purposes, contact Copyright Clearance Center at (978) 750-8400 or www.copyright.com. Further reprint Diversity Statement In principle and in practice, AHLA values and seeks diverse and request should be directed to Cynthia Conner, AHLA, 1620 Eye Street, NW, 6th Floor, Washington, DC inclusive participation within the Association regardless of gender, race, ethnicity, creed, 20006-4010. (202) 833-0755. age, sexual orientation, gender identity and expression, national origin, or disability. The Association welcomes all members as it leads health law to excellence through education, information, and dialogue.

4 AHLA Connections June 2015 CONGRATULATIONS TO OUR AHLA LEADERS AND CONTRIBUTORS

We are pleased to honor our colleagues’ active involvement as authors, speakers and committee members in the American Health Lawyers Association, an organization that has greatly enhanced our ability to serve healthcare clients in the US and around the world for decades.

Peter C. Alfano III Jessica M. Hoke Lawrence J. Rosenfeld

Peter A. Pavarini Susan M. DiMickele Mark J. Botti Kelly A. Leahy Heather L. Stutz 2014-15 AHLA President Vice Chair & Member: Author and Speaker Labor and Employment Practice Group

D. Lewis Clark, Jr. Stanford L. Moore Anthony W. Swisher

Robyn Helmlinger Vice Chair Strategy & Member: Tax & Finance Practice Group 2014-15 Speaker

Adam D. Colvin Robert D. Nauman Thomas E. Zeno

Kimberly J. Donovan Daniel B. Pasternak

Local Connections. Global Influence.

44 Offices in 21 Countries squirepattonboggs.com Annual Meeting— Featured Webinar Series June 29Celebrating Diversity+ Inclusion Reception Sponsored by Deloitte Telemedicine: 23Exploring Different Delivery Models and Their Regulatory Annual Meeting— Consequences, Part IV: How to 30 Practice Group Luncheons Protect Against Fraud and Abuse While Promoting Telemedicine • What’s Next? (Intermediate) Policy Developments in Health The Intersection of Public Care Fraud, Waste, and Abuse— Health and Health Care: The Congress and Beyond Role of Law In-House Counsel Sponsored by Jarrard Phillips Cate & Starting June 5, 2015 28Program Hancock Marriott Marquis Washington DC Brought to you by AHLA’s Public Washington, DC • Overview of CMS’ Audit and Interest Committee and Systems Affinity Group. Presented in HealthCare Appraisers, Inc. has provided Enforcement Strategy collaboration with the CDC’s Public sponsorship in support of this program. Sponsored by Navigant Health Law Program, and The Network for Public Health Law. In-House Counsel • From Inception Through Litigation: Practice Group Luncheon Keeping Peer Review, QA, and QI This six-part series will focus issues such Sponsored by HealthCare Appraisers Inc. Materials Confidential as federally qualified health centers, Sponsored by MediTract, Inc prescription drug overdose prevention, Needs Assessments, June 29-July 1 and domestic legal preparedness and July response related to Ebola. Each webinar Annual Meeting will provide both a public health and health care perspective, and will feature Marriott Marquis Washington DC Annual Meeting— Washington, DC 1 Practice Group Luncheons lawyers representing health departments, hospitals, and health systems. • Pragmatic Strategies to Enable Sponsors: Annual Meeting— Hospitals to Continue Physician 29 Practice Group Luncheons Affiliations and Mitigate the Risks of • Roundtable Discussion of Hot Legal Being the Next St. Luke’s Case Topics in Behavioral Health Sponsored by First Chesapeake Group

• Health Information Privacy • The Shift from Fee-for-Service and Security: Successes and to Value–and Quality-Based Challenges in a Changing Health Payments Care Environment • Halfway There: Problems and Best Practices for Hospitals Complying with 501(r) by Year-End Sponsored by Wipfli LLP

Distance Learning Member Event For more information on all Free Networking, Reception AHLA events and to register, go to www.healthlawyers.org/events In-Person Program, Training Registration Cost or call (202) 833-1100, prompt #2. Leadership Opportunity Volunteer Opportunity

6 AHLA Connections June 2015 Compliance Hot Seat Radiology, Cardiovascular, and Orthopedic/Spine

How confident are you that your hospital would 5 Compliance withstand surveyor scrutiny during a RAC audit, Hot Buttons CMS survey, or whistleblower case investigation? 1. Medical necessity of diagnostic tests and procedures OIG, CMS, and DOJ have set their compliance investigative priorities. 2. Documentation supports Fraud and abuse within radiology, cardiovascular, and orthopedic/ coding and medical spine top their lists. necessity

A common thread among the compliance hot buttons is the need 3. Physicians have exhausted for documentation and course of treatment to support the medical conservative, non-surgical necessity of tests and procedures. routes of treatment 4. RAC audits focused External peer review as a compliance audit especially in CA, FL, IL, An audit of medical cases conducted by an external peer review LA, MI, MO, NC, NY, PA, organization can help identify any weaknesses or risks that potentially OH, TX expose you to surveyor scrutiny or noncompliance. 5. Whistleblower cases The Greeley Company is uniquely qualified to help you with external peer review for this purpose. For over 25 years, we have:

• Provided exceptional external peer review services

• Advised hundreds of healthcare organizations in preparing for Contact us and responding to the standards, surveys, and actions of CMS Contact us today at and every healthcare accreditor 888-749-3054 or [email protected] with • Served as an Independent Review Organization (IRO) for many your questions related to hospital clients regulatory compliance or • Provided objective, expert assistance to determine whether peer- any other external peer to-peer case reviews are objective and evidence-based—and review needs. thereby in compliance with regulations

Leadership Seminars Interim Consulting & Onsite Education Staffing 75 Sylvan St., Suite A-101 Danvers, MA 01923 External Peer Outsourcing The Greeley [email protected] Review Solutions Membership www.greeley.com Program 888-749-3054 ©2015healthlawyers.org The Greeley Company 7 in-house counsel program & annual meeting June 29-July 1, 2015 | Marriott Marquis Washington DC | Washington, DC

General Session Presenters

Year In Review (Case Law) 2014-2015

Ezekiel J. Emanuel Elizabeth Carder-Thompson Jack Schroder Jr.

Networking and social events at the program 2015 In-House Counsel Program and Annual include: Meeting Sponsors and Exhibitors

❯❯ Altegra Health ❯❯ Jarrard Phillips Cate & ❯❯ Welcome Reception, Sponsored by Cain Brothers & ❯❯ ASLME Hancock Company, LLC (Sunday) ❯❯  ❯❯ Bloomberg BNA LexisNexis Applied Discovery ❯❯ Celebrating Diversity+Inclusion Reception, ❯❯ Berkeley Research ❯❯ MD Ranger Inc. Sponsored by Deloitte (Monday) Group LLC ❯❯  ❯❯ Cain Brothers & MediTract, Inc. ❯❯ Off-Property Reception at National Air and Company LLC ❯❯ NACVA Space Museum, Sponsored by AHLA Member ❯❯ Carnahan Group ❯❯ Navigant Law Firms (Monday) ❯❯ CBIZ Healthcare ❯❯ Ntracts LLC Valuation ❯❯ Pinnacle Healthcare ❯❯ Performance by The Capitol Steps comedy ❯❯ CHAN Healthcare, Consulting troupe, Sponsored by Coker Group (Tuesday) a subsidiary of Crowe ❯❯ PYA Horwath ❯❯ Networking Breakfasts ❯❯ Spectrum ❯❯  Coker Group HealthPartners LLC ❯❯  ❯❯ Public Interest Silent Auction–Bidding opens soon! Deloitte ❯❯ Sullivan Cotter and ❯❯ First Chesapeake Group Associates, Inc. ❯❯ FTI Consulting ❯❯ Veralon, Formerly DGA ❯❯ HealthCare Appraisers, Partners Inc. ❯❯ VMG Health ❯❯ HORNE LLP ❯❯ Wipfli LLP Register at www.healthlawyers.org ❯❯ Huron Business or call (202) 833-1100, prompt #2. Advisory

8 AHLA Connections June 2015 •

• •

healthlawyers.org 9 2015 AHLA Top Honors

AHLA Top Honors recognizes the organizations behind our members—those law firms, organizations, plans and companies that consistently and enthusiastically encourage and sustain their members’ and employees’ affiliation with AHLA. These lists are determined by using the number of members as of April 30, 2015. Top 10 Firms 1 King & Spalding LLP 265 2 Polsinelli PC 261 3 Hall Render Killian Heath & Lyman PC 177 4 Baker Donelson Bearman Caldwell & Berkowitz PC 163 (tie) Waller Lansden Dortch & Davis LLP 163 (tie) 5 Husch Blackwell LLP 152 6 Squire Patton Boggs 140 7 Epstein Becker & Green PC 126 8 McGuireWoods LLP 123 9 Mintz Levin Cohn Ferris Glovsky & Popeo PC 121 10 Morgan Lewis & Bockius LLP 107 Honors

Bass Berry & Sims PLC 105 Nixon Peabody LLP 28 McDermott Will & Emery LLP 105 Arnall Golden Gregory LLP 27 Hogan Lovells LLP 87 Ropes & Gray LLP 25 Garfunkel Wild PC 86 Smith Moore Leatherwood LLP 25 Sheppard Mullin Richter & Hampton LLP 86 Taft Stettinius & Hollister LLP 23 K & L Gates LLP 84 Reed Smith LLP 22 Nelson Mullins Riley & Scarborough LLP 80 Skadden Arps Slate Meagher & Flom LLP 22 Drinker Biddle & Reath LLP 71 Kutak Rock LLP 20 Bradley Arant Boult Cummings LLP 65 Hooper Lundy & Bookman PC 61 Hancock Daniel Johnson & Nagle PC 56 Also Recognized Jones Day 54 Arent Fox LLP 19 Crowell & Moring LLP 52 LLP 19 Bricker & Eckler LLP 51 Powers Pyles Sutter & Verville PC 19 Foley & Lardner LLP 47 Akerman LLP 18 OBER | KALER 44 Greenberg Traurig LLP 18 Alston & Bird LLP 42 Womble Carlyle Sandridge & Rice LLP 18 Holland & Knight LLP 42 Groom Law Group Chartered 17 DLA Piper LLP (US) 41 Balch & Bingham LLP 16 Baker & Hostetler LLP 39 Barnes & Thornburg LLP 16 Ogletree Deakins 39 Burr & Forman LLP 16 Venable LLP 34 Dorsey & Whitney LLP 16 Davis Wright Tremaine LLP 33 Parker Poe Adams & Bernstein LLP 16 Akin Gump Strauss Hauer & Feld LLP 32 Stevens & Lee PC 16 Norton Rose Fulbright 32 von Briesen & Roper SC 16 Dentons US LLP 30 Brach Eichler LLC 15 Quarles & Brady LLP 29 Broad and Cassel 15

10 AHLA Connections June 2015 2015 AHLA Top Honors

Breazeale Sachse & Wilson LLP 14 Consulting Firms Buchanan Ingersoll & Rooney PC 14 Berkeley Research Group LLC 18 Fox Rothschild LLP 14 PYA 16 Krieg DeVault LLP 14 HealthCare Appraisers Inc 15 Latham & Watkins LLP 14 Navigant Consulting Inc 14 Lathrop & Gage LLP 14 Analysis Group 9 LeClairRyan 14 NERA Economic Consulting 7 Sullivan Stolier Knight LC 14 FTI Consulting Inc 5 Verrill Dana LLP 14 Huron Consulting Group Inc 5 Clark Hill PLC 13 Hinshaw & Culbertson LLP 13 Iseman Cunningham Riester & Hyde LLP 13 Federal Government Katten Muchin Rosenman LLP 13 Office of Medicare Hearings and Appeals 445 Reinhart Boerner Van Deuren SC 13 HHS/OGC 295 Thompson Coburn LLP 13 DHHS Office of the Inspector General 77 Wyatt Tarrant & Combs LLP 13 Centers for Medicare & Medicaid Services 16 US Department of Health & 7 Accounting Firms Office of Personnel Management 5 PricewaterhouseCoopers LLP 18 KPMG LLP 13 Health Plans BKD LLP 12 Anthem Inc. 52 HORNE LLP 10 Health Care Service Corporation 50 Ernst & Young LLP 8 UnitedHealth Group Inc 25 CBIZ MHM LLC 7 Humana Inc 22 CliftonLarsonAllen LLP 7 Aetna 17 Dixon Hughes Goodman LLP 5 Kaiser Foundation Health Plan Inc 15 Elliott Davis Decosimo 5 HealthPartners Inc 12 Somerset CPAs PC 5 Tufts Health Plan 10 Wipfli LLP 5 Hospitals & Health Systems Colleges & Universities HCA Holdings Inc 34 Drexel University Thomas R Kline School of Law 23 Intermountain Healthcare 26 University of Washington 20 Tenet Healthcare Corporation 25 Indiana University 16 Community Health Systems Professional Services 23 University of Wisconsin 14 Corporation University of Florida 13 Mayo Clinic 22 University of 13 Sutter Health 21 University of Arkansas for Medical Sciences 12 Dignity Health 20 University of Cincinnati Health 11 BJC HealthCare 19 University of Pennsylvania 11 Catholic Health Initiatives 19 Emory University 10 North Shore-LIJ 19 University of Iowa 10 Providence Health & Services 19 University of Massachusetts 10 Carolinas HealthCare System 16 University of Michigan 10 MedStar Health 15 University of Mississippi Medical Center 10 Novant Health 15 Trinity Health 15 Companies & Corporations Sanford Health 14 McKesson Corp 20 Express Scripts 18 State Government Walgreen Co 13 Medicaid Fraud Control Unit of Virginia Office of the 23 Texas Health Resources 10 Attorney General CVS Caremark 9 Harris County Attorney’s Office 12 DaVita Inc 8 SC Department of Health and Human Services 9 Kindred Healthcare 8 Fresenius Medical Care North America 6 Medicaid Fraud Control Unit of North Carolina Office 8 Medtronic Inc 6 of the Attorney General TeamHealth 6 DC Department of Health Care Finance 6 Walmart Stores Inc 6 Hennepin County Attorney’s Office 6 CVS Health 5 Iowa Department of Inspections and Appeals 6 Mississippi Division of Medicaid 5

healthlawyers.org 11 2015 AHLA Top Honors

100% Involvement

This Honor Roll represents the firms and organizations that have 100% of their health law practice group members who belong to AHLA. If you believe your firm or organization has 100% membership in AHLA and should be listed, email [email protected].

Ankner & Levy PC Kozak & Gayer PA Baker & Hostetler LLP Mellette PC Baird Holm LLP Miles & Peters PC Balch & Bingham LLP Mintz Levin Cohn Ferris Glovsky and Popeo PC Baudino Law Group PLC Law Offices of Nathan Mubasher Benesch Friedlander Coplan & Aronoff LLP Murphy Austin Adams Schoenfeld LLP Blalock Walters PA National Association for Home Care and Hospice’s Center BLANCHARD|MANNING LLP for Health Care Law Blankenship Health Law LLC Norton Rose Fulbright Breazeale Sachse & Wilson Nutile Law & Associates Cohen Compagni Beckman Appler & PLLC OBER|KALER Law Offices of William Mack Copeland LLC Ogletree Deakins Nash Smoak & Stewart PC Coppersmith Brockelman PLC Parker Poe Adams & Bernstein Crowell & Moring LLP, Health Care Group Phillips Lytle LLP Lewis W. Fishman PA Polsinelli Florida Health Law Center Popovits & Robinson FriedemannFoarde PLLC Powers Pyles Sutter & Verville PC Garfunkel Wild PC Rappel Health Law Group PL Alice G. Gosfield and Associates PC Rogaliner Law Offices PC Hancock Daniel Johnson & Nagle PC Rogers Mantese & Associates PC Hall Render Killian Heath & Lyman PC Law Offices of Lynne M. Rasmussen PLLC The Health Law Firm Schwartz Law LLC Husch Blackwell Squire Patton Boggs Joy & Young LLP Sullivan Stolier Resor Kovata LC Harold E. Kaplan, MHA, JD Tinsley Bacon Tinsley LLC Kathleen DeBruhl & Associates LLC Tsoules Sweeney Martin & Orr LLC Kelly Law Firm PC Waller

12 AHLA Connections June 2015 2015 AHLA Top Honors

Honor Roll of Firms By Region Largest firm memberships per state; items in bold are largest for the region.

NORTHEAST SOUTHEAST CT Robinson & Cole LLP 9 AL Bradley Arant Boult Cummings LLP 20 DE Bailick & Bailick LLC 3 FL Broad and Cassel; Squire Patton Boggs (tie) 15 DC King & Spalding LLP 74 GA King & Spalding LLP 108 ME Kozak & Gayer PA; Verrill Dana LLP (tie) 6 KY Wyatt Tarrant & Combs LLP 14 MD OBER|KALER 36 MS Baker Donelson Bearman Caldwell & 26 MA Mintz Levin Cohn Ferris Glovsky & 74 Berkowitz PC Popeo PC NC K & L Gates LLP 37 NH Hinckley Allen & Snyder LLP; Sulloway & 3 SC Nelson Mullins Riley & Scarborough 34 Hollis PLLC (tie) TN Waller Lansden Dortch & Davis LLP 154 NJ Sills Cummis & Gross PC 21 NY Garfunkel Wild PC 71 PA Morgan Lewis & Bockius LLP 32 SOUTH CENTRAL RI Donoghue Barrett & Singal PC; Hinckley 3 AR Kutak Rock LLP; Mitchell Williams Selig Gates 6 Allen & Snyder (tie) & Woodyard PLLC (tie) VT Primmer Piper Eggleston & Cramer PC 5 CO Polsinelli PC 22 VA Hancock Daniel Johnson & Nagle PC 55 KS Foulston Siefkin LLP 9 WV Flaherty Sensabaugh Bonasso PLLC; 3 LA Baker Donelson Bearman Caldwell & 17 Spilman Thomas & Battle PLLC; Steptoe & Berkowitz PC Johnson LLP (tie) MO Polsinelli PC 114 OK Conner & Winters LLP; McAfee & Taft PC (tie) 7 TX Husch Blackwell LLP 34 NORTH CENTRAL IL Polsinelli PC 45 IN Hall Render Killian Heath & Lyman PC 103 SOUTHWEST IA Brown Winick Graves Gross Baskerville & 5 AZ Polsinelli PC 10 Schoenebaum PLC ; Dorsey & Whitney LLP CA Sheppard Mullin Richter & Hampton LLP 67 MI Hall Render Killian Heath & Lyman PC 31 HI Torkildson Katz Moore Hetherington & Harris 4 MN Fredrikson & Byron PA 12 NV Holland & Hart LLP; Nutile Pitz & Associates (tie) 2 NE Baird Holm LLP 11 NM Montgomery & Andrews PA 4 ND Vogel Law Firm 3 UT Parsons Kinghorn Harris; Ray Quinney & 3 OH Bricker & Eckler LLP 51 Nebeker PC (tie) SD Siegel Barnett & Schultz LLP 2 WI Hall Render Killian Heath & Lyman PC 29

NORTHWEST AK K & L Gates LLP; Sonosky Chambers Sachse 2 Enderson & Perry LLP (tie) ID Beard St. Clair Gaffney PA 5 MT Crowley Fleck PLLP 4 OR Stoel Rives LLP 6 WA Davis Wright Tremaine LLP 17 WY Aron & Hennig LLP; Dray Dyekman Reed & 2 Healey PC (tie)

healthlawyers.org 13 2015 AHLA Top Honors

Top Five Firms or Companies by AHLA Practice Group Enrollment

Academic Medical Centers & Teaching Health Care Liability and Litigation Hospitals King & Spalding LLP 56 Hall Render Killian Heath & Lyman PC 10 Baker Donelson Bearman Caldwell & Berkowitz PC 42 King & Spalding LLP 8 Husch Blackwell LLP 40 The Children’s Hospital of 7 Hall Render Killian Heath & Lyman PC 23 BJC HealthCare 6 Polsinelli PC 21 Ropes & Gray LLP 6 Association of American Medical Colleges 5 Health Information and Technology Norton Rose Fulbright 5 Polsinelli PC 40 University of Pennsylvania 5 Hall Render Killian Heath & Lyman PC 32 King & Spalding LLP 13 Antitrust Epstein Becker & Green PC 9 Crowell & Moring LLP 10 Husch Blackwell LLP 9 Hall Render Killian Heath & Lyman PC 10 Bricker & Eckler LLP 8 Wilson Sonsini Goodrich & Rosati PC 10 King & Spalding LLP 7 Hospitals and Health Systems NERA Economic Consulting 7 Polsinelli PC 80 Polsinelli PC 7 Hall Render Killian Heath & Lyman PC 65 Analysis Group 6 King & Spalding LLP 25 Epstein Becker & Green PC 6 Bradley Arant Boult Cummings LLP 23 Jones Day 5 Baker Donelson Bearman Caldwell & Berkowitz PC 20 McDermott Will & Emery LLP 5 Bass Berry & Sims PLC 20 Hinckley Allen & Snyder LLP 4 Hooper Lundy & Bookman PC 4 In-House Counsel Intermountain Healthcare 4 Intermountain Healthcare 15 Stevens & Lee PC 4 Hall Render Killian Heath & Lyman PC 14 Trinity Health 10 Business Law and Governance BJC HealthCare 9 Polsinelli PC 55 Epstein Becker & Green PC 9 Hall Render Killian Heath & Lyman PC 51 Adventist Health System 8 King & Spalding LLP 36 Integris Health 8 Bradley Arant Boult Cummings LLP 20 LifePoint Health 8 K & L Gates LLP 16 Mayo Clinic 8 Waller Lansden Dortch & Davis LLP 16 Mintz Levin Cohn Ferris Glovsky & Popeo PC 8

Fraud and Abuse Labor and Employment King & Spalding LLP 57 Ogletree Deakins 33 Hall Render Killian Heath & Lyman PC 49 Husch Blackwell LLP 20 Epstein Becker & Green PC 37 Hall Render Killian Heath & Lyman PC 18 Bass Berry & Sims PLC 30 Polsinelli PC 12 Polsinelli PC 28 Epstein Becker & Green PC 11

14 AHLA Connections June 2015 2015 AHLA Top Honors

Life Sciences Post-Acute and Long Term Services King & Spalding LLP 41 Arnall Golden Gregory LLP 17 Polsinelli PC 22 Bass Berry & Sims PLC 17 Husch Blackwell LLP 21 Husch Blackwell LLP 16 Morgan Lewis & Bockius LLP 11 Hall Render Killian Heath & Lyman PC 13 Hall Render Killian Heath & Lyman PC 9 Baker Donelson Bearman Caldwell & Berkowitz PC 11 K & L Gates LLP 9 Polsinelli PC 11 Waller Lansden Dortch & Davis LLP 11 Medical Staff, Credentialing, and Peer King & Spalding LLP 6 Review Hall Render Killian Heath & Lyman PC 16 , Accreditation, and Payment Polsinelli PC 14 Hall Render Killian Heath & Lyman PC 27 OBER | KALER 8 King & Spalding LLP 21 Hooper Lundy & Bookman PC 7 Epstein Becker & Green PC 10 Bricker & Eckler LLP 6 Polsinelli PC 10 Hancock Daniel Johnson & Nagle PC 6 Akin Gump Strauss Hauer & Feld LLP 9 Horty Springer & Mattern PC 6 Bricker & Eckler LLP 9 Foley & Lardner LLP 9 Payers, Plans, and Managed Care Hooper Lundy & Bookman PC 9 Health Care Service Corporation 22 Husch Blackwell LLP 8 Crowell & Moring LLP 21 OBER | KALER 8 Epstein Becker & Green PC 16 Powers Pyles Sutter & Verville PC 8 Groom Law Group Chartered 15 Hall Render Killian Heath & Lyman PC 12 Tax and Finance Hall Render Killian Heath & Lyman PC 20 Physician Organizations King & Spalding LLP 17 Hall Render Killian Heath & Lyman PC 23 Squire Patton Boggs 10 OBER | KALER 8 Baker Donelson Bearman Caldwell & Berkowitz PC 9 Baker Donelson Bearman Caldwell & Berkowitz PC 7 Polsinelli PC 9 Husch Blackwell LLP 7 Bricker & Eckler LLP 8 Epstein Becker & Green PC 6 Husch Blackwell LLP 8 Fredrikson & Byron PA 6 Hooper Lundy & Bookman PC 6 PYA 6 Adventist Health System 5 Bass Berry & Sims PLC 5 Bradley Arant Boult Cummings LLP 5 Burr & Forman LLP 5 Lathrop & Gage LLP 5 Tenet Healthcare Corporation 5 Waller Lansden Dortch & Davis LLP 5

healthlawyers.org 15 2015 AHLA Top Honors

Beyond Top Honors–Firm Profile:

For more than 12 years, AHLA has been compiling the “Top or aggressive collective bargaining if already unionized. With Honors’ of the Association, to recognize the firms, compa- the ambush election rules recently finalized by the Nation- nies, organizations, and others who support participation Labor Relations Board, and other changes which shift the of our members. Every year, our editorial staff also works to playing field in labor’s favor, we think health care employers find ways to recognize more firms that may not be in the “Top are going to continue to need good advice on how to deal Ten,” or may not be the largest in their state, but who are appropriately with labor unions. nonetheless very active in AHLA and who are players in the health law field. Lori A. Bowman This year, we shine a light on one such firm who not only has Shareholder, , CA been involved in AHLA activities for many years, but who has also added significant numbers of new members in 2015. Ogletree Deakins now has 39 AHLA members, a significant jump from their 6 members in 2014. We asked some firm members what may have prompted their increased AHLA What subspecialty areas of health law do you think will involvement, what benefits their members use the most, how be hottest over the next five years? the rise in health care law work has increased at their firm, and Ogletree Deakins does nothing but labor, employment, and to get a few predictions from their experts of upcoming trends. benefits, and thus already operates within a “subspecialty” of health law. But within the world of labor and employment, we expect to see our work in health care increase in the areas of Robert Niccolini traditional labor, wage and hour, disability accommodation, Shareholder, Washington, DC data privacy and alignment of culture as hospitals continue to Co-Chair of Ogletree Deakins’ Healthcare grow through acquisition and merger. Practice Group Member, AHLA Board of Directors Maria Greco Danaher What prompted your firm’s increased involvement in Shareholder, Pittsburgh, PA AHLA this year? Chair, AHLA Labor & Employment Practice In the last several years, our firm came to realize that we have Group a very significant number of lawyers providing labor, employ- ment and benefits advice in the health care industry. Most of these lawyers, however, did not necessarily identify them- What do you and your colleagues find to be the most selves as “health care” lawyers. In an effort to address that, beneficial AHLA benefits? in January of 2014 we formed the Healthcare Practice Group Because our firm focuses on labor and employment law, one within our firm, which now has over 90 members. Recog- of the biggest benefits of AHLA membership for our attor- nizing that the AHLA is the go-to organization for expertise neys is the ability to draw on the expertise and experience in health law, we made an increase in our firm’s membership of attorneys in other fields of law as those fields relate to our and involvement a priority for 2015. health care clients. The Practice Group model of AHLA has been especially beneficial as a cross-reference mechanism, including the ability to review publications and presentations C. Thomas (Tom) Davis in other substantive legal areas. Shareholder, Nashville, TN Co-Chair of Ogletree Deakins’ Healthcare Practice Group

Have you seen a rise in your firm’s health care law work If your firm or company is interested in participating over the last five years? Do you expect to see your health in this type of Q&A, contact Allison Beard at abeard@ law work increase over the next five years? healthlawyers.org and we may include your profile in There has been a definite increase in the level of work done an upcoming issue of AHLA Connections. for health care employers by our firm in the last five years, including wage and hour and employed physician issues. I Interested in establishing a group bill? Pay for multiple myself practice traditional labor law and represent a number new members or renewals at the same time by of health care companies with either a national footprint or a contacting Clark Campbell at (202) 833-0772, large presence in a region. Labor unions have been targeting [email protected]. those types of employers for many years, both for organizing

16 AHLA Connections June 2015 2015 AHLA Top Honors

Top 100 Companies, Firms, and Organizations with Public Interest Donations (2014)

AHLA’s Public Interest Committee is grateful to all companies that have made a corporate gift or have employees who have made an individual gift in support of AHLA’s Public Interest mission during calendar year 2014 (1/1/2014–12/31/2014). Listings are in descending order by total dollars contributed.

King & Spalding LLP Burr & Forman LLP Skadden Arps Slate Meagher & Flom Jayne Koskinas Ted Giovanis Ascension Health LLP Foundation Diego J Loinaz Martin PSC Blue Cross Blue Shield of Florida Husch Blackwell LLP Medical Compliance Associates Inc Duke University/Duke University Health System OBER | KALER Norton Rose Fulbright First Chesapeake Group Inc McDermott Will & Emery LLP ProHealth Care Inc Intermountain Healthcare Epstein Becker & Green PC University of Iowa College of Law Ohio State Medical Association Polsinelli PC Hall Render Killian Heath & Lyman PC SMU/Dedman School of Law Davis Wright Tremaine LLP Kelly Law Firm PC Ogletree Deakins Jones Day Pillsbury Winthrop Shaw Pittman LLP The Health Law Firm AHLA Dentons US LLP Trinity Health Crowell & Moring LLP LeClairRyan Jones Walker LLP Morgan Lewis & Bockius LLP Arnall Golden Gregory LLP Vorys Sater Seymour and Pease LLP Coppersmith Brockelman PLC Hooper Lundy & Bookman PC Jane Reister Conard LLC McKenna Long & Aldridge LLP Miller & Martin PLLC Thomas Jefferson University Integris Health Dykema Gossett PLLC Drinker Biddle & Reath LLP Liss & Lamar PC The Bittinger Law Firm NASMHPD Pepper Hamilton LLP Foley & Lardner LLP OptumRx a UnitedHealth Group Squire Patton Boggs HORNE LLP Company Bass Berry & Sims PLC Smith Moore Leatherwood LLP Bricker & Eckler LLP Community Medical Centers LifePoint Hospitals Inc Godfrey & Kahn SC Bradley Arant Boult Cummings LLP Wiley Rein LLP Harris Immigration Law LLC Blanchard Manning LLP McDonald Hopkins LLC Office of the Inspector General US Reed Smith LLP Dignity Health Department of Health and Human Post & Schell PC Baker Donelson Bearman Caldwell & Services Bon Secours Health System Inc Berkowitz PC Wilentz Goldman & Spitzer PA Hogan Lovells LLP Cooley LLP Louisiana Nursing Home Association Honigman Miller Schwartz and Cohn Ropes & Gray LLP Alice G Gosfield & Associates PC LLP Waller Lansden Dortch & Davis LLP Baird Holm LLP Powers Pyles Sutter & Verville PC Lane Powell PC Duane Morris LLP Broad and Cassel Morehouse School of Medicine Office Fox Rothschild LLP Tufts Health Plan of the General Counsel Catholic Health System Shipman & Goodwin LLP Keenan & Ogden Nixon Peabody LLP Akin Gump Strauss Hauer & Feld LLP Law Office Dale H Cowan MD JD Alston & Bird LLP Baptist Memorial Health Care Law Offices of Kevin McAnaney UMC Health System Corporation The Law Offices of E Michael Flannigan Community Health Systems University of California Professional Services Corporation

healthlawyers.org 17 2015 AHLA Top Honors

State Rankings

Two Largest Firms and Non-Firms by state (2 or more members)

State Top Two Ranking Firms Top Two Non-Firms Alabama Bradley Arant Boult Cummings LLP 20 HealthSouth Corporation 9 Baker Donelson Bearman Caldwell & 12 University of Alabama 7 Berkowitz PC Alaska K & L Gates LLP 2 Alaska Native Tribal Health 3 Consortium Sonosky Chambers Sachse Enderson & 2 State of Alaska 2 Perry LLP Arizona Polsinelli PC 10 Banner Health 9 Coppersmith Brockelman PLC 8 CVS Caremark 8 Arkansas Kutak Rock LLP 6 University of Arkansas for Medical 10 Sciences Mitchell Williams Selig Gates & 6 Walmart Stores Inc. 5 Woodyard PLLC Conner & Winters LLP 4 California Sheppard Mullin Richter & Hampton LLP 67 Sutter Health 23 Hooper Lundy & Bookman PC 51 Dignity Health 15 Colorado Polsinelli PC 22 Catholic Health Initiatives 9 Husch Blackwell LLP 12 DaVita HealthCare Partners Inc. 9 - - University of Colorado 6 Connecticut Robinson & Cole LLP 9 Yale New Haven Health System 7 Murtha Cullina LLP 8 University of Connecticut 4 Wiggin & Dana LLP 8 Delaware Bailick & Bailick LLC 3 Christiana Care Health Services 6 Stevens & Lee PC 2 Nemours 3 District of Columbia King & Spalding LLP 74 George Washington University 7 Hogan Lovells LLP 68 DC Department of Health Care 6 Finance Florida Broad and Cassel 15 Adventist Health System 13 Squire Patton Boggs 15 Baptist Health South Florida 10 Holland & Knight LLP 14 HealthCare Appraisers Inc 10 Georgia King & Spalding LLP 108 Emory University 12 Alston & Bird LLP 27 University of Georgia 8 Hawaii Torkildson Katz Moore Hetherington & 4 Hawaii Health Systems Corporation 3 Harris Alston Hunt Floyd & Ing 3 Hawaii Pacific Health 3 The Queen’s Health Systems 3 Idaho Beard St. Clair Gaffney PA 5 Saint Alphonsus Health System Inc. 5 Holland & Hart LLP 2 Saint Luke’s Health System 4 Moffatt Thomas 2

A1 AHLA Connections June 2015 2015 AHLA Top Honors

State Top Two Ranking Firms Top Two Non-Firms Illinois Polsinelli PC 45 Health Care Service Corporation 26 McDermott Will & Emery LLP 34 Advocate Health Care 13 Northwestern Memorial Hospital 13 Indiana Hall Render Killian Heath & Lyman PC 103 Indiana University Health 9 Krieg DeVault LLP 12 Somerset CPAs PC 5 Iowa Brown Winick Graves Gross Baskerville 5 UnityPoint Health 12 & Schoenebaum PLC Dorsey & Whitney LLP 5 University of Iowa Hospitals & Clinics 6 Davis Brown Koehn Shors & Roberts PC 4 Kansas Foulston Siefkin LLP 9 University of Kansas Medical Center 5 Lathrop & Gage LLP 8 PYA 4 Via Christi Health Inc. 4 Kentucky Wyatt Tarrant & Combs LLP 14 Humana Inc. 19 Stites & Harbison PLLC 9 Kindred Healthcare Inc 9 Louisiana Baker Donelson Bearman Caldwell & 17 Franciscan Missionaries of Our Lady 5 Berkowitz PC Health System Breazeale Sachse & Wilson LLP 14 Louisiana State University Health 5 Science Center Sullivan Stolier Knight LC 14 Ochsner Health System 4 Maine Preti Flaherty Beliveau & Pachios LLP 5 Eastern Maine Healthcare Systems 7 Kozak & Gayer PA 4 MaineHealth 5 Verrill Dana LLP 4 Maryland OBER-KALER 36 Bon Secours Health System Inc. 11 Venable LLP 21 Johns Hopkins Health System 11 University of Maryland Medical 10 System Massachusetts Mintz Levin Cohn Ferris Glovsky & 74 Tufts Health Plan 9 Popeo PC Ropes & Gray LLP 15 Analysis Group 8 Harvard Pilgrim Health Care 8 Michigan Hall Render Killian Heath & Lyman PC 31 Spectrum Health System 13 Dykema Gossett PLLC 10 Trinity Health 11 Warner Norcross & Judd LLP 10 Minnesota Fredrikson & Byron PA 12 Mayo Clinic 14 Stinson Leonard Street LLP 10 Healthpartners Inc. 12 Mississippi Baker Donelson Bearman Caldwell & 26 University of Mississippi Medical 10 Berkowitz PC Center Wise Carter Child & Caraway PA 12 HORNE LLP 8 Missouri Polsinelli PC 114 BJC HealthCare 19 Husch Blackwell LLP 83 Express Scripts 18

healthlawyers.org A2 2015 AHLA Top Honors

State Top Two Ranking Firms Top Two Non-Firms Montana Browning Kaleczyc Berry & Hoven PC 4 Bozeman Deaconess Hospital 4 Crowley Fleck PLLP 4 Health Care Service Corporation 4 Garlington Lohn & Robinson PLLP 3 Kalispell Regional Healthcare 2 Nebraska Baird Holm LLP 11 Children’s Hospital & Medical Center 4 Kutak Rock LLP 9 Catholic health Initiatives 2 Nevada Holland & Hart LLP 2 Renown Health 2 Nutile Pitz & Associates 2 University of Nevada School of 2 Medicine New Hampshire Hinckley Allen & Snyder LLP 3 Dartmouth-Hitchcock Medical Center 4 Sulloway & Hollis PLLC 3 Catholic Medical Center 2 McLane Gaf Raulerson & Middleton PA 2 Elliot Health System 2 Sheehan Phinney Bass & Green PA 3 Exeter Health Resources 2 New Jersey Sills Cummis & Gross PC 21 Barnabas Health 11 Epstein Becker & Green PC 19 Seton Hall University School of Law 10 New Mexico Montgomery & Andrews PA 4 University of New Mexico 8 John D Wheeler & Associates 2 Presbyterian Healthcare Services 3 Miller Stratvert PA 2 SaucedoChavez PC 2 New York Garfunkel Wild PC 71 North Shore –LIJ Health System 18 Epstein Becker & Green PC 31 MVP Health Care Inc 8 North Carolina K & L Gates LLP 37 Novant Health 15 McGuireWoods LLP 23 Carolinas Healthcare System 14 North Dakota Vogel Law Firm 3 Sanford Health 7 Ohio Bricker & Eckler LLP 51 Cleveland Clinic 13 Squire Patton Boggs 46 University Hospitals Health System 13 Inc. Mercy Health 9 Oklahoma Conner & Winters LLP 7 Integris Health 9 McAfee & Taft PC 7 Health Care Service Corporation 4 GableGotwals 6 Oregon Stoel Rives LLP 6 Oregon Health & Science University 5 Schwabe Williamson & Wyatt 5 Legacy Health 3 Pennsylvania Morgan Lewis & Bockius LLP 32 Drexel University Thomas R Kline 17 School of Law K & L Gates LLP 15 University of Pennsylvania 11 Rhode Island Donoghue Barrett & Singal PC 3 Lifespan Corporation 9 Hinckley Allen & Snyder 3 Care New England Health System 4 Duffy & Sweeney Ltd 2

A3 AHLA Connections June 2015 2015 AHLA Top Honors

State Top Two Ranking Firms Top Two Non-Firms South Carolina Nelson Mullins Riley & Scarborough 34 South Carolina Department of Health 9 & Human Services Moore & Van Allen PLLC 7 Greenville Health System 4 Nexsen Pruet LLC 7 Parker Poe Adams & Bernstein LLP 7 South Dakota Bangs McCullough 2 Sanford Health 8 Siegel Barnett & Schultz LLP 2 Avera Health 4 Regional Health 4 Tennessee Waller Lansden Dortch & Davis LLP 154 HCA Inc 29 Bass Berry & Sims PLC 99 Community Health Systems 26 Professional Services Corporation Texas Husch Blackwell LLP 34 Tenet HealthCare Corporation 20 King & Spalding LLP 20 Baylor Scott & White Health 17 Utah Parsons Kinghorn Harris PC 3 Intermountain Healthcare 28 Ray Quinney & Nebeker PC 3 University of Utah 10 Kimball Legal 2 Parr Brown Gee & Loveless 2 Vermont Primmer Piper Eggleston & Cramer PC 5 University of Vermont Health Network 3 Dinse Knapp & McAndrew PC 4 Fletcher Allen Health Care 2 Southwestern Vermont Healthcare 2 Virginia Hancock Daniel Johnson & Nagle PC 55 Inova Health System 11 McGuireWoods LLP 32 Sentara Healthcare 9 Washington Davis Wright Tremaine LLP 17 University of Washington 20 Ogden Murphy Wallace PLLC 10 Providence Health and Services 17 West Virginia Flaherty Sensabaugh Bonasso PLLC 3 Charleston Area Medical Center Inc 4 Spilman Thomas & Battle PLLC 3 West Virginia Healthcare Authority 4 Steptoe & Johnson LLP 3 West Virginia University 4 Jackson Kelly PLLC 2 Thomas Health System 2 Wisconsin Hall Render Killian Heath & Lyman PC 29 University of Wisconsin Hospitals and 6 Clinics Authority von Briesen & Roper SC 15 Marshfield Clinic 5 Medical College of Wisconsin 5 Wyoming Aron & Hennig LLP 2 Cheyenne Regional Medical Center 3 Dray Dyekman Reed & Healey PC 2

healthlawyers.org A4 2015 AHLA Top Honors

International Honor Roll

AHLA’s list of international members is growing every year–AHLA is grateful for the participation of the following members, companies, firms, and organizations.

Australia Health Legal Qatar Sidra Medical and Research Center Brazil Araujo E Conforti Advogados Squire Patton Boggs Associados Gabriela Guz Russian Federation Squire Patton Boggs Salomão Kaiuca & Abrahão Sociedade de Advogados Saudi Arabia Squire Patton Boggs

Canada Carol Anne McKay Singapore Squire Patton Boggs Miller Thomson LLP Thompson Dorfman Sweatman South Korea Seegene Inc LLP Switzerland Juliana Regazzi Gerk Edo China Squire Patton Boggs United Arab Emirates King & Spalding LLP Dominican Republic Squire Patton Boggs Squire Patton Boggs

Germany King & Spalding LLP United Kingdom Mintz Levin Cohn Ferris Glovsky Squire Patton Boggs & Popeo PC Squire Patton Boggs Ireland Mason Hayes & Curran US Virgin Islands DeWood Law Firm Japan Squire Patton Boggs Ogletree Deakins The Russell Law Firm LLP New Zealand AUT University Library

Poland Squire Patton Boggs

Puerto Rico Arroyo & Monrouzeau CSP Ashford Presbyterian Community Hospital Cesar Alcover Hospital Espanol Auxilio Mutuo Julio A Torres McConnell Valdes Medical Card System Inc MMM Healthcare Inc MSo of Puerto Rico Inc Quality Health Services of PR Inc Sanchez-Betances Sifre & Munoz Noya CSP Social Security Administration Toro Palacios Law Office PSC Zayas Mayo Law Offices PSC

A5 AHLA Connections June 2015 2015 AHLA Top Honors

Additional Companies, Firms, and Organizations with Public Interest Donations (2014) (Ranked 101 and higher)

AHLA’s Public Interest Committee is grateful to all companies that have made a corporate gift or have employees who have made an individual gift in support of AHLA’s Public Interest mission during calendar year 2014 (1/1/2014–12/31/2014).

Beaumont Health Flaherty Sensabaugh Bonasso Gallagher Evelius & Jones LLP Dinsmore & Shohl LLP Charleston Area Medical Center Carilion Clinic PLLC Hinman Straub PC DLA Piper LLP (US) Inc Conner & Winters LLP George Washington University Hinshaw & Culbertson LLP Foster Swift Collins & Smith PC Cheyenne Regional Medical Center Liles Parker PLLC Hallmark Health System Jason M Dunn Frost Brown Todd LLC Hanson Bridgett LLP City of Hope National Medical Argus Health Systems Inc Martin Health System - Harvard Pilgrim Health Care Center Huck Bouma PC Corporate Compliance Greenberg Traurig LLP Haynes and Boone LLP Community Health Systems Integris Health Inc Norton Healthcare MemorialCare Health System HealthSouth Corporation Crowe & Dunlevy PC Jacqueline M Melonas Nossaman LLP Regional One Health Iseman Cunningham Riester & Damon Morey LLP Seyfarth Shaw LLP JSA Healthcare/DaVita Pietragallo Gordon Alfano Bosick Hyde LLP Healthcare Partners & Raspanti LLP Dickinson Wright PLLC UnityPoint Health Jackson Kelly PLLC Judith Jurin Semo PLLC Rachel V Rose Attorney at Law Evans Petree PC Yale University Jackson Walker LLP Kean Miller LLP PLLC EvergreenHealth Kutak Rock LLP Kaiser Foundation Health Plan Lahey Health Rush University Medical Center Inc Faegre Baker Daniels LLP Lash & Goldberg LLP Law Office of Deborah Randall The Evangelical Lutheran Good LabCorp Florida Health Law Center Locke Lord LLP Samaritan Society Masonicare Lashly & Baer PC Foster Pepper PLLC Mellette PC University of Florida Mintz Levin Cohn Ferris Glovsky Manatt Phelps & Phillips LLP Frilot LLC Phelps Dunbar LLP Warner Norcross & Judd LLP & Popeo PC McAfee & Taft PC Gachassin Law Firm Sidley Austin LLP Wiggin & Dana LLP Office of the Inspector General Medtronic Inc Garvey Schubert Barer Paul Hastings LLP Williams Mullen Phillips Murrah PC Moore & Van Allen PLLC Genentech Inc Verrill Dana LLP Wise Carter Child & Caraway PA RegionalCare Hospital Partners Musick Peeler & Garrett LLP Gibbons PC DaVita HealthCare Partners Inc Inc Akerman LLP Nationwide Children’s Hospital Gilpin Givhan PC Centers for Medicare & Medicaid Ross Stromberg Roswell Park Cancer Institute Novant Health Golden Living Services Stephen M Blaes Attorney At Strasburger & Price LLP Piedmont Healthcare Gordon Rees Scully Mansukhani Geisinger Health System Law Akron General Health System LLP Presbyterian Healthcare Services Greensfelder Hemker & Gale PC University of Tennessee Albert Einstein Healthcare HCR Manor Care PricewaterhouseCoopers LLP HealthyCT Kurt Salmon Network Health Net Inc Quarles & Brady LLP Katten Muchin Rosenman LLP Fredrikson & Byron PA athenahealth Inc HealthNow New York Inc Rolf Goffman Martin Lang LLP MaineHealth Perkins Coie LLP BKD LLP Hinckley Allen & Snyder LLP Saint Luke’s Health System McGuireWoods LLP Lathrop & Gage LLP Blue Cross and Blue Shield Hogan Marren Ltd Association Saul Ewing LLP Reinhart Boerner Van Deuren SC Maynard Cooper & Gale PC Holland & Hart LLP Blue Shield of California Schiffbauer Law Office Silhol Law Tenet Healthcare Corporation Kindred Healthcare Inc Children’s Healthcare of Atlanta Sentara Healthcare Tucker Arensberg PC The Children’s Hospital of Kitch Drutchas Wagner Valitutti & Bond Schoeneck & King PLLC Philadelphia Dressman Benzinger LaVelle psc Shumaker Loop & Kendrick LLP Sherbrook PC Avera Health Womble Carlyle Sandridge & Foulston Siefkin LLP Sirote & Permutt PC Lifespan Corporation Rice LLP Benesch & Associates LLC Fresenius Medical Care North Texas Health Resources Lindquist & Vennum PLLP Clark Hill PLC America Care New England Health von Briesen & Roper SC Lowndes Drosdick Doster Kantor System Cuddy & Feder LLP Gray Plant Mooty Wachler & Associates PC & Reed PA Carolinas Healthcare System Baylor Scott & White Health Hamline University School of Law Wroten & Associates Marshall & Melhorn LLC Cigna Phillips Lytle LLP HCA Holdings Inc Association of American Medical McElroy Deutsch Mulvaney & Doerner Saunders Daniel & Sanford Health Hunton & Williams LLP Colleges Carpenter LLP Anderson LLP Sullivan Stolier Knight LC Illinois Bone & Joint Institute LLC DHHS Office of the General McNair Law Firm PA FranklinSolutions The MetroHealth System Inspira Health Network Counsel Civil Rights Division Medica Greer Herz & Adams Plunkett Cooney PC Latham & Watkins LLP Law Offices of Mark Bonanno Medical College of Wisconsin LLC Horty Springer & Mattern PC Chiesa Shahinan & Giantomasi MChA Law Office Medstar Health Robinson Bradshaw & Hinson PA Jordan Resolutions LLC PC Office of the Attorney General Memorial Health Federal Trade Commission State University of New York- Kohrman Jackson & Krantz PLL Ohio State University Medical University At Buffalo Memorial Healthcare System Baker & Hostetler LLP Center Law Offices of Michael Dundon Abrams Fensterman Fensterman Mercy Health System Roth LLP Bingham Greenebaum Doll LLP Phoenix Children’s Hospital Attn: Eisman Formato Ferrara & Methodist Hospital Office of General Counsel Northern Arizona Healthcare Cozen O’Connor PC Einiger LLP Miami Children’s Hospital Potter Anderson & Corroon LLP NYU Office of General Counsel Cull & Hayden PSC Adventist Health System Miller Health Law Group Sarah C Harlan CPA Sutter Health Gjerset & Lorenz LLP Advocate Health Care Mitchell Williams Selig Gates & Swedish Covenant Hospital Kennedy PC Law Offices SCL Health System Allina Health System Woodyard PLLC The Rozovsky Group Inc Kozak & Gayer PA Sumrell Sugg Carmichael Hicks American HealthCare LLC Morris Manning & Martin LLP & Hart PA HealthCare Appraisers Inc Krieg DeVault LLP Athens Regional Medical Center Mount Carmel Health System The Health Law Partners PC Health Law Center LeadingAge Inc Beard St Clair Gaffney PA Murphy Austin Adams Whiteford Taylor & Preston LLP Baker Donelson Mirick O’Connell DeMallie & Best Best & Krieger LLP Schoenfeld LLP Whyte Hirschboeck Dudek SC Balch & Bingham LLP Lougee LLP Blalock Walters PA North Kansas City Hospital CH Baker Law BJC HealthCare Nexsen Pruet LLC Blue Cross Blue Shield O’Connell & Aronowitz PC Irwin Birnbaum Breazeale Sachse & Wilson LLP North Shore-LIJ Health System Massachusetts Olympus Corporation of the Sedgwick LLP Americas Cabaniss Johnston Gardner Premier Health Partners Medical Center Dumas & O’Neal LLP Robinson & Cole LLP Allegaert Berger & Vogel LLP Brennan Manna & Diamond LLC Pam May Law Firm PSC Carpenter Law Firm PC Stites & Harbison PLLC Arnold & Porter LLP Buchanan Ingersoll & Rooney PC Parker Hudson Rainer & Dobbs LLP CHE Trinity Health Thompson & Knight LLP Banner Health Butzel Long PC Peterson & Myers PA Christofolo Schermer Consulting Thompson Coburn LLP Baptist Health South Florida Capital District Physicians Health Poyner Spruill LLP College of Medicine University University of Rochester Benesch Friedlander Coplan & Plan Inc of Tennessee Health Science Aronoff LLP Caplan and Earnest LLC Preti Flaherty Beliveau & Pachios Parker Poe Adams & Bernstein LLP Center LLP Berkeley Research Group LLC Carlton Fields Jorden Burt PA Primmer Piper Eggleston & Connect Hearing Inc Brach Eichler LLC Brownstein Hyatt Farber Schreck Carmody Torrance Sandak LLP Cramer Ltd Dina B Ross Law Offices Covington & Burling LLP Hennessey LLP Butler Snow LLP Pullman & Comley LLC DST Health Solutions LLC CVS Caremark Centene Corporation

healthlawyers.org A6 2015 AHLA Top Honors

PYA Chilivis Cochran Larkins & Bever Jennings Strouss & Salmon PLC Reliant Care Management Jolley Law Group LLC Reid & Riege PC LLP Johns Hopkins Health System Company LLC 360 Law Rhoads & Sinon LLP CIGNA Corp Johnson Duffie Stewart & Renown Health A Dubrick MD JD Schwabe Williamson & Wyatt Clark Mize & Linville Chartered Weidner Rex Healthcare Aaron Gianna PLC ScottHulse PC Cline Williams Wright Johnson & Joy & Young LLP Robinson Brog Leinwand Greene Acadiana Management Group Oldfather LLP Genovese & Gluck PC Seigfreid Bingham PC Judee Gallagher Attorney At Law Active Management Commonwealth Medicine / Roper St Francis Healthcare Smith Haughey Rice & Roegge Kaiser Permanente Acute Care Inc University of Massachusetts Ryan Smith & Carbine Ltd Snell & Wilmer LLP Medical School Kalogredis Sansweet Dearden Adam B King Attorney at Law PC and Burke Ltd Samson & Powers PLLC Spencer Fane Britt & Browne LLP Community Health Systems Inc Adams and Reese LLP Kathleen L DeBruhl & Associates Sanchez-Betances Sifre & Munoz Spotts Fain PC Copeland Cook Taylor & Bush PA LLC Noya Adena Health System Stevens & Lee PC Cox Smith Matthews Keating Jones Hughes PC Sanders Rehaste Sternshein & Adler Pollock & Sheehan PC Incorporated Stinson Leonard Street LLP Kegler Brown Hill & Ritter Harvey LLP ADR Services, Inc Crain Miller & Wernsman Ltd Summa Health System Kessenick Gamma & Free LLP Sante Health System Advanced Eye Care Centers of Troutman Sanders LLP Cross Gunter Witherspoon & Schwartz Law LLC Cleveland Inc Galchus PC Kettering Medical Center Tydings & Rosenberg LLP Network Scott E. Hultstrand LLC AdvancedMed Corp Daniels and Porco LLP UAW Retiree Medical Benefits Kramer Rayson LLP Shands Healthcare Legal Adventist Health Danziger & Markhoff LLP Trust Langdale Vallotton LLP Services Adventist Health System Davis Graham & Stubbs LLP UC Health Law Offices of Sheryl Story Shands Jacksonville Medical Adventist Healthcare Inc Dinse Knapp & McAndrew PC Center University of Miami LCMC Health Affordable Care Inc Vidant Health Dixon Hughes Goodman LLP Shannon Gracey Ratliff & Miller Aiken Bridges Attorneys Lerch Early & Brewer Chtd LLP WellCare Health Plans Inc Donoghue Barrett & Singal PC Akron Children’s Hospital LifeCare Management Services Sheridan Healthcare Inc WellStar Health System Dorsey & Whitney LLP LLC Albany Medical College Sherrard & Roe PLC Wheaton Franciscan Healthcare Drexel University College of Lone Star Circle of Care Alderman Devorsetz & Hora PLLC Medicine Signature Medical Group Wolff & Samson PC Loyola University Health System Alexian Brothers Health System Dunn Carney Allen Higgins & Smith Anderson Blount Dorsett CentraState Healthcare System Tongue LLP Macaulay & Burtch PC Mitchell & Jernigan LLP Allegan General Hospital Jan Thompson Attorney At Law Eastern Maine Healthcare MacDonald Illig Jones & Britton Southwestern Vermont Allegheny Health Network McKesson Technologies Inc Systems Maricopa Integrated Health Healthcare Allen McCain & O’Mahony PC Saint Louis University School Elliott Davis Decosimo System Spartanburg Regional Healthcare Allergy Partners PA Of Law Eskenazi Health Marshall Dennehey Warner System Allison MacKenzie Pavlakis Salem & Green PC Coleman & Goggin PC Extendicare Health Services Inc Spears Moore Rebman & Wright & Fagan LTD Sedor Wendlandt Evans & Filippi Martin Health System Williams PC Federal Hearings and Appeals Alperstein & Covell PC LLC Services Inc Massachusetts Hospital Spectrum Health System Alverson Taylor Mortensen & Tulane University Association Feldesman Tucker Leifer Fidell St Charles Health System Sanders University Hospitals Parma LLP McCandlish & Lillard PC St Vincent’s Health System American Academy of Medical Center Firelands Regional Medical McDonald Group LLP State University of New York At Orthopaedic Surgeons Baptist Health Care Center MCG Health Inc Stony Brook American Association of Adams Lynch & Loftin PC Fitzpatrick Lentz & Bubba PC Medcor Inc Steward Health Care System LLC Orthopaedic Surgeons Affiliated Monitors Inc Fowler White Boggs PA Medical Faculty Health Alliance Strategic Management Services American College of Physicians Air Methods Corporation Freed Maxick CPAs PC Medical Systems Inc LLC American Medical Association Albany Medical Center Froedtert Health Inc MedManagement LLC Sullivan Cotter and Associates American Pathology Partners Inc Inc American Health Care Fultz Maddox Hovious & Dickens Mednax Inc American Renal Associates Sulloway & Hollis PLLC Association PLC Meridian Health System Inc American Speech Language Sussman Shank LLP Hearing Association Ankner & Levy PC GableGotwals Methodist Le Bonheur Healthcare Taggart Rimes & Graham PLLC American University Washington Ann & Robert H Lurie Children’s Gammage & Burnham Methodist Physicians Clinic Hospital of Chicago TeamHealth College of Law GeneralCounselWest PC Metrohealth Medical Center Ardent Health Services Teresa P Sappinton Consultant American Urological Association Gentry Locke Rakes & Moore LLP Metropolitan Jewish Health Arent Fox LLP America’s Health Insurance Plans Gilliland & Hayes LLC System Texas Hospital Association Arkansas Children’s Hospital Amerigroup Corporation Goodman Allen & Filetti PLLC Millennium Laboratories Inc Texas Tech University Arnold I Friede & Associates Amy Hudspeth Esq Goodsill Anderson Quinn & Stifel Millikin & Fitton Law Firm The Health Law Consultancy Asante Health System Analysis Group Goodwin Procter LLP Milling Benson Woodward LLP The Kreager Law Firm Axley Brynelson AnMed Health Goulston & Storrs PC Mitchell Day Law Firm Tucson Medical Center Bailey Cavalieri LLC Applied Economics Grady Health System Moffitt Cancer Center Universal American Corp LLP Arak Law Graham & Graham Ltd Montefiore Medical Center University of Arkansas for Baptist Health System Medical Sciences Archcare Gray Robinson PA Mount Sinai Hospital Baptist Healthcare Counsel University of Colorado Health Archstone Law Group PC Graydon Head & Ritchey LLP Nemours Children’s Hospital Baptist Healthcare System University of Pennsylvania Arnall Golden Gregory Greenville Health System Nemours Foundation Baudino Law Group PLC University of Virginia Physicians Arnstein & Lehr LLP Hall Booth Smith PC Neubert Pepe & Monteith PC Baylor College of Medicine Group Aron & Hennig LLP Hancock & Estabrook LLP North Mississippi Health Services Beatty Bangle Strama PC University of Wisconsin Medical Arthur J Gallager Hay Group Inc Northside Hospital Foundation Beaumont Hospital Artz Health Law HCA Nuyen Tomtishen and Aoun PC Van Meer & Belanger PA Benton Benton & Associates LLC Asbury Communities Inc Health Systems Inc Ohio Supreme Court Vantage Health Plan Inc Blue Cross of Northeastern Ascension Health Ministry SVC Healthcare Legal Counsel LLC Page Wolfberg & Wirth Pennsylvania Varnum Riddering Schmidt & CTR HealthPlus of Michigan Panza Maurer & Maynard PA Howlett LLP BlueCross BlueShield of AspenPointe Vaughn & Associates LLC Tennessee Henry Ford Health System Parkview Health Athas Healthcare LLC Via Christi Health Inc Brouse McDowell LPA Heyl Royster Voelker & Allen Pecore & Doherty LLC Atkinson Haskins Nellis Brownstein Hyatt Farber Schreck Higgs Fletcher & Mack LLP Peoples Health VMG Health Brittingham Gladd & Fiasco Bryan Cave LLP Holmstrom & Kennedy PC Phoebe Putney Health System Walgreens Co AtlantiCare Health System Buchalter Nemer Holy Cross Hospital Phoenix Children’s Hospital Wallace Jordan Ratliff & Brandt AtlantiCare Regional Medical LLC Center Buerger Moseley & Carson PLC Hospital for Special Care Pinnacle Healthcare Consulting Wilkinson Goeller Modesitt Houston Harbaugh PC Presbyterian Medical Services Attorney & Counsellor At Law Calfee Halter & Griswold LLP Wilkinson & Drummy Howard Wershbale & Co Prevea Health Attorney At Law California Medical Association Williams & Jensen PLLC Hufford Horstman Mongini Priority Health Attorney General’s Office, UW Carls McDonald & Dalrymple LLP Wilson Elser Moskowitz Edelman Parnell & Tucker PC Division Catania Mahon Milligram & Rider Providence Health & Services & Dicker LLP Hurwitz & Fine PC Aurora Health Care PLLC Public Consulting Group Inc Wipfli LLP Indiana Health Care Association Ausley & McMullen PA Catholic Health Initiatives Rappel Health Law Group PL Ziprick & Cramer LLP Jacobs & Dembert PA Avamere Health Services LLC Centura Health Ray & Sherman LLC Christian Companies LLC Jameson & Powers Baker & McKenzie LLP Children’s National Medical Reingruber & Company PA Kilpatrick Townsend & Stockton Baker Healthcare Consulting Inc Center JAMS The Resolution Experts LLP

A7 AHLA Connections June 2015 2015 AHLA Top Honors

Balick & Balick LLC Bunger & Robertson Childrens Hospital Los Angeles David Levenstein Law PC Executive Resources LLC Bangs McCullen Butler Floyd & Burch Porter & Johnson PLLC Children’s Hospital of Orange David R Campbell & Associates Exeter Health Resources Inc Simmons LLP Burke Warren MacKay & Serritella County LLC Express Scripts Baptist Community Services PC Children’s Hospital of Wisconsin Davis & Kuelthau SC Exusia, Inc. Baptist Health Care Corporation Burnheimer & Company PC Children’s Hospitals and Clinics Davis Brown Koehn Shors & Fairfax Neonatal Associates PC of Minnesota Roberts PC Baptist Healthcare System Inc Burns Anderson Jury & Brenner Family Residence & Essential Baratz & Associates PA LLP Children’s Medical Center Day Pitney LLP Enterprises Inc BARKLEY - CCBD Group Butler Health System Children’s of Alabama DC Department of Behavioral Federation of American Hospitals Health Barley Snyder LLC Butler University COPHS Christiana Care Health Services Felt Martin Frazier and Weldon De La Parte & Gilbert PA Barnes & Thornburg LLP Buttaci & Leardi LLC Christie Clinic PC C Craig Cole & Associates Christie Pabarue & Young DeCotiis Fitzpatrick Cole & Wisler Fenigstein & Kaufman Barnett Benvenuti & Butler PLLC LLP Cadence Health Churchill LLC Fenner Consulting Barranti Law Group Dekalb Medical Barris Sott Denn & Driker Cain Hibbard & Myers PC Ciena Healthcare Management Ferguson & Widmayer PC Inc Dell Graham Bates White California School of Law: Santa Ferro Labella & Zucker LLC Barbara Cigna-HealthSpring Delta Dental of Virgina Battle Winslow Scott & Wiley PA Finley Miller Cashman Et Al California Western School of Law Cincinnati Children’s Hospital Dennis Wenger & Abrell PC Baxter Healthcare Corporation Fisher-Titus Medical Center Calvert Memorial Hospital Medical Center Department of Veterans Affairs Baxter Regional Medical Center Fletcher O’Brien Kasper & Camden Clark Memorial Hospital Clark Hill PC Dermatology Associates of Nottage Baylor Scott & White Health Wisconsin SC Cameron & Mittleman LLP Clark Law Offices Florida Cancer Specialists PL Law Dept Medical Center Campbell DeLong LLP Clark Nuber PS Florida Hospital BBNA Devine Millimet & Branch Campbell Law Firm Clearwater Compliance LLC Florida Hospital Association Beebe Medical Center Diagnostic Imaging Group Campbell University - Norman Cleveland Clinic Florida Hospital Medical Group Berenbaum Weinshienk & Eason Diakon Lutheran Social Ministries PC Adrian Wiggins School of Law Cleveland State University Floyd Medical Center DiCaro Coppo & Popcke APLC Berenstein Law Firm Campbell Yost Clare & Norell PC Coding Compliance Solutions Foley & Mansfield PLLP LLC Dignity Health Legal Dept Berger Singerman Camrud Maddock Olson & Foley Hoag LLP Larson Ltd Cohne Kinghorn PC Dilworth Paxson LLP Berkshire Health Systems Inc Ford & Harrison LLP Capital BC College of American Pathologists Dimension Healthcare System Berlandi Nussbaum & Reitzas ForensiCorp Capital Senior Living Corporation Collora LLP Executive Offices LLP Foundation Healthcare Inc Capital University Law School Colorado Ambulatory Surgery Direct Supply Inc Bernstein Shur Sawyer & Nelson Four Square Healthcare Ltd Caplin & Drysdale Chartered Center Association Diversified Search Bershtein Volpe & McKeon PC Fraley & Fraley LLP Capozzi Adler PC Combs Greene PA Dixon Hughes & Goodman LLP Bert Campbell Attorney at Law Frances Cullen PC Cardinal Innovations Healthcare Commonwealth Care Alliance Inc DLPadget Enterprises Inc Beth Anne Jackson Esq LLC Francis Ridgell & Totusek LLP Cardinal Innovations Healthcare Commonwealth Laboratories Inc Doctors Hospital at Renaissance Beth Israel Deaconess Medical Franciscan Alliance Center Solutions Community Care Network Inc Dolchin Slotkin & Todd PC Cardiovascular Research dba Matrix Medical Network Dominion Diagnostics Franciscan Missionaries of Our Betsy Stevens Lady Health System Foundation Community Care Network of Donahue Durham & Noonan PC BHHS Legacy Foundation Virginia Inc Franczek Radelet Care Management Strategies Donna Meyer Bienvenu Bonnecaze Foco Viator LLC Community College of Fraser Stryker Law Firm and Holinga APLLC Dowling Aaron Incorporated Care Pharmacy Solutions Philadelphia Fraser Trebilcock Davis & Dunlap Billings Clinic Doylestown Hospital CareCore National LLC Community Healthcare System PC BioScrip Inc DRA Imaging PC CareFirst Compliance Law Group PLC Fred Hutchinson Cancer Birzon Strang & Associates Dresnick Rodriguez & Perry PA Research Center CareGroup Healthcare System Concentra Blaney and Tweedy PLLC Driscoll Children’s Hospital Fredrickson & Byron Caremark Rx Inc Concord Law School Blood Systems Inc Duke University Office of Counsel Freeman & MacLean PC CareSource Cone Health Bloomberg BNA Dunkiel Saunders Elliott FriedemannFoarde PLLC Caretel Inns of America Connecticut Department of Blount Memorial Hospital Education Raubvogel Hand Froedtert Health Medical Group Caris Life Sciences Blue Cross and Blue Shield of Connors Morgan PLLC East Tennessee Children’s Fulbright & Jaworski LLP Carlock Copeland & Stair LLP Hospital Arizona Constance M Greaney Esq Fultz Maddox Dickens PLC Carlton Fields Jorden Burt Eastman & Smith Ltd Blue Cross Blue Shield MA Constitution Surgery Centers LLC Fust Charles Chambers LLP Carney Badley Spellman PS Eberle Berlin Kading Turnbow & Blue Cross Blue Shield Michigan Continuum Health Partners Inc Gale Gale & Hunt LLC Carolinas Health System McKlveen Chtd Blue Cross Blue Shield North Conway Medical Center Gallagher & Kennedy PA Carolina Carroll McNulty & Kull LLC Eden Park Health Services Inc Cook County Risk Management Gardere Wynne Sewell LLP Blue Ridge HealthCare Case Western Reserve University Edgarton St Peter Petak & Cook Group Incorporated Rosenfeldt Gardner Law Firm PA Blumberg Ribner Inc School of Law Casey Chapman PLLC Cook Yancey King & Galloway Edmunds & Williams Gardner Skelton PLLC Bodman LLP APLC Catholic Health East Edwards Life Sciences Garfunkel Wild PC BOLLINGER CONNOLLY Cooke Kobrick & Wu KRAUSE CCHN dba Matrix Medical Egan Flanagan & Cohen PC Gargiulo / Rudnick LLP Cookeville Regional Medical Booz Allen Hamilton Network Egerton McAfee Armistead & Gastro Health Center Davis PC Boston College Law School Cengage Learning Geisinger Health Plan Cooley Dickinson Physician eHealth Data Solutions Bottom Line Systems Centers for Control and Hospital Organization (CDPHO) Geisinger Medical Center Prevention Eisenhower Medical Center Bowditch & Dewey LLP Cooney & Crew LLP Genova Burns & Giantomasi Centolella Lynn D’Elia & Temes El Camino Hospital Genova Burns LLC Bowles Rice McDavid Graff & LLC Cooper & Scully PC Love LLP Elap Services LLC Genzyme a Sanofi Company CentraCare Health Cooperative of American Boyle Brasher LLC Physicians Inc Ellick Jones Buelt Et Al Georgia Department of Public Central California Faculty Medical Elsner Law Firm PLLC Health Brach Eichler LLP Group Copeland Thompson & Farris PC Emergency Medicine Physicians Georgia Hospital Association Bradley & Riley PC Central Georgia Health System Coppersmith & Brockelman PLC BRG Health Analytics Inc Cornelius & Collins LLP Emory University Office of the Georgia Regents Health System General Counsel Bristol Hospice LLC Central Maine Medical Center Costello Porter Hill Heisterkamp Georgia Regents University Encompass Home Health Britthaven Inc Central Ohio Primary Care Bushnell & Carpenter LLP Geppert McMullen Paye & Getty Eric Moore Brodek & Gillard SC Physicians Inc Coventry Diagnostics LLC Getnick & Getnick Erlanger Health System Brogan & Gray PC LLO Certilman Balin Adler & Hyman Craven Regional Medical Center Gettry Marcus CPA PC LLP Ernst & Young LLP Bronson Healthcare Group Creighton Fox Johnson & Mills Giarmarco Mullins & Horton PC Chang Iwamasa & Chui LLP PLLC Ervin Cohen & Jessup LLP Brookdale Senior Living Gilchrist Donnell PLLC Charlotte Radiology PA Creighton University Eskenazi Health Brooks Pierce McLendon Gilmore Jasion & Mahler LTD Humphrey & Leonard LLP CharterCARE Health Partners Criterion Health Inc Esse Health Gimbel Reilly Guerin & Brown Broward Health Chemed Corp Crowley Fleck PLLP Estates At Carpenters Glankler Brown PLLC Brown Hay & Stephens LLP CHG Healthcare Services Inc Crozer-Keystone Health System Evans Garvey Lackey & Ochs GlaxoSmithKline BU School of Public Health CHI Franciscan Health Legal Damrell Nelson Schrimp Pallios Excalibur Business Consultants Glenn Rogers PLLC Services Pachen & Silva LLC Bulkley Richardson and Gelinas Gockerman Wilson Saylor & LLP Chicago Kent College of Law Daniel Barks Excela Health Hesslin PC Illinois Institute of Technology

healthlawyers.org A8 2015 AHLA Top Honors

Godbey Griffiths, LLLP Hodges & Davis Jupiter Medical Center Law Offices of Robert L Brent McLane Graf Raulerson & Goldberg Segalla LLP Hodgson Russ LLP Kahn Dees Donovan & Kahn LLP Law Offices of Teresa Ford PC Middleton Professional Association Gong Nashed Pascoe Inc Holbrook & Osborn PA Kaiser Foundation Hospitals and Law Offices of Tin Kin Lee McLeod Health Gonsalves & Kozachenko Holcombe Bomar PA Health Plan Inc Law Weathers McPhillips Fitzgerald & Cullum Goodman & Goodman Holland Home Kaiser Permanente/The Leah R Gates PC Permanente Medical Group Inc LLP Gordon Rees LLP Holt Ney Zatcoff & Wasserman LeBarLaw LLC Karafin Gruenstein PC MDwise Inc Gordon Simonds Attorney At Law LLP Lee Memorial Health System Katten Borgeest Ryan LLP MedAmerica Inc Grace Healthcare LLC Holy Name Medical Center Leitner Williams Dooley & Katz Sapper & Miller LLP Medical Card System Inc Grant Thornton LLP Holyoke Medical Center Napolitan PLLC Katz Teller Brant & Hild Medical Care Management GrayRobinson PA Home Levett Rockwood PC Corporation Kaufman & Canoles PC Grayson Thomas LLC Home address Levine Law Group PLLC Medical Center Clinic Keenan & Associates Greater New York Hospital Horger Barnwell & Reid LLP Lewis Brisbois Bisgaard & SMith Medical Clinic of Houston LLP Kelley Wolter & Scott PA Association Horn Aylward & Bandy LLC Lewis Rice LLC Medical College of Wisconsin- Greenbaum Rowe Smith & Davis HORNE Health Care Kelly Remmel & Zimmerman Lewis Roca Rothgerber LLP Risk Management LLP Horton Knox Carter & Foote LLP Kennedy Pier Knoff Loftus LLP Lewis Thomason Medical Facilities of America Greenspoon Marder Law Hospital Espanol Auxilio Mutuo Kentucky Association of Health LHC Group Medical Mutual of Ohio Care Facilities Gregg C Waddill III Hospital Sisters Health System Liberty Healthcare Management Medical Services of America Inc Kerr Russell & Weber PLC Griffin & Hackett PA Houlihan Lokey LifeBridge Health Inc MedStar Health Inc Legal Kettering Health Network Griffin Faculty Practice Plan Houston Methodist Hospital LifeNet Health Department Kevin Pierce Grodsky & Olecki LLP HRSI LifePoint Health MedStar Washington Hospital Kimball Legal Center Gunster Firm Hufford & Horstman Mongini LifePoint Hospitals Kindred Medxcel Gutnicki LLP Parnell & Tucker PC Lincoln Derr PLLC Kinetic Concepts Inc Meissner Tierney Fisher & Nichols Gwynedd Square Nursing Center Huie Fernambucq & Stewart LLP Linda S Consolo & Associates Kings Daughters Medical Center SC H Lee Moffitt Cancer Center Humana Group Health Care LindenGrove Inc Plan Inc Kittleman Thomas Melnik Legal Hagwood Adelman Tipton Littler Mendelson PC Humana Inc Klein DeNatale Goldner Cooper Meltzer Purtill & Stelle Halifax Health Medical Center Lockridge Grindal Nauen PLLP Rosenlieb & Kimball LLP Memorial Health Legal Halloran and Sage LLP Humphrey Anderson Law Firm Knox McLaughlin Gornall & Loma Linda University Health Department Hanger Prostetics & Orthotics Inc Hunter MacLean Exley & Dunn PC Sennett PC Loma Linda University Medical Memorial Health University Harbin Clinc LLC Center Medical Center Ian Wilson - Legal Affairs Kootenai Health Harkins & Associates London & Amburn PC Mercy Health Ice Miller LLP Kozyak Tropin & Throckmorton Harrang Long Gary & Rudnick PC Lorraine Molinari & Assoc Mercy Medical Center Illinois Attorney General Kraft Healthcare Consulting LLC Harris Health System Los Angeles Care Health Plan Mercy Physician Services Illinois Department of Human Kramer Green Zuckerman Harris Shelton Hanover Walsh Services Greene & Buchsbaum PA Louise B Zeuli PA Meridian Senior Living LLC PLLC Illinois State Medical Society Kramon & Graham Lowenstein Sandler LLP Meritus Health Harrison & Held LLP Independence Blue Cross Kronick Moskovitz Tiedemann Loyola University Meritus Medical Center Harter Secrest & Emery LLP & Girard Independent Health Association Lundy Beldecos & Milby PC Merzbach Law Office PC Hartford Healthcare Corporation Inc Krugliak Wilkins Griffiths & Lurie Besikof Lapidus & Co PLLP Messer Caparello PA Harvard Vanguard Medical Dougherty Co LPA Indiana University Health Lynch & Tanner LLP Methodist Hospitals of Dallas Associates KTConnolly & Associates LLC Indiana University Health Goshen Lynch Schwab PLLC Meyer Capel PC Hawaii Medical Service Kyler Pringle Lundholm & Association Ingalls Health System Durmann M Bruce Stokes PC Miami Dade County Attorney’s Office Hawaii Pacific Health Inglis Foundation LA Care Health Plan MAAMA MedCorp Compliance Network Michael H Cohen Attoney At Law Haynes & Boone LLP In-House Legal Services LLC Lamb & Kawakami LLP Inland Northwest Health Services MacFarlane Ferguson & MicroVention Inc Haynsworth Sinkler Boyd PA Lambeth & Associates PLLC McMullen Integrated Healthcare Strategies Midwest Administrative Services Health Care Law Associates PC Lancaster General Hospital Magellan Health Services Invacare Corporation Milestone Healthcare Health Care Service Corporation Laney Legal Services LLC Main Line Health Miller Canfield Paddock & Stone Health Data Insights Jackson & Campbell PC Lanier Ford Shaver & Payne PC Maine Hospital Association PLC Health Law & Resolution Center Jackson Health System Laurel K Call MaineGeneral Health Miller Shakman & Beem LLP LLC Jackson Madison County Law Office of Al Meyer PA Maloney McHugh & Kolodgy Ltd Miller Stratvert PA Health Legal General Hospital Law Office of Catherine I. Manning Fulton & Skinner PA Milwaukee Radiologists Health New England Inc Jacobson & Associates LLC Hanson, A PC Mark H Price PC Minnesota Hospital Association Health Partners Plans Inc James R Westbury Jr PC Law Office of Hilary Huebsch Mark O Dietrich CPA PC Minnesota Medical Association Analytics LLC Jankoff & Gabe PC Cohen APC Marsh & McClennan Companies Minor Bell & Neal Health Policy Strategies Inc Jarrard Phillips Cate & Hancock Law Office of Ila S Rothschild Martha R Cooper PC MiraMed Global Services Inc Healthcare Association of New Jay A Ziskind PA Law office of Karina P Gonzalez York State Jay E Levy Attorney PA Martin Pringle Oliver Wallace & Mississippi Division of Medicaid Bauer LLP Healthcare Supply Chain Jazz Pharmaceuticals Law Offices of Andrew E Grimm Mississippi State Department Mary H Thompson of Health Association Jeffers Cowherd PC Law Offices of Barbara A Weiner Mary Stewart Healthcare Mitchell Blackstock Ivers HealthEast Care System Jefferson School of Population Law Offices of Cheryl Consulting LLC Sneddon & Marshall PLLC Executive Office Health Wagonhurst HealthFirst Law Offices of Christopher S Massachusetts Depart of Mental MKA Executives Planners Jen Modjeska Health Lucas LLC Moffatt Thomas Barrett Rock & HealthPartners Inc Jennifer M Newman PC Law Offices of Christopher Massachusetts Hospital Assoc Fields Chtd Hearst Corp. (Hearst Health) Jesse Green Spevak PLLC Matthew R Hubbell Attorney Molloy Schmidt LLC Helmsing Leach Herlong JMD at Law Newman & Rouse PC Law Offices of Daniel H Willick Monmouth Ocean Hospital John D Wheeler & Associates Maury Regional Hospital Service Corp Helton Law Group APC Law Offices of Diane B Lawrence John Muir Health Law Offices of Fred Herman Mayo Clinic Global Products and Montana Health Care Association Hemmer DeFrank PLLC Services John Parman Montgomery Purdue Blankinship Hennepin County Medical Center Law Offices of Gary I Fields Johns Hopkins HealthCare LLC McBrayer McGinnis Leslie & & Austin PLLC Hershner Hunter LLP Law Offices of Gordon J Apple Kirkland PLLC Johns Hopkins Medicine PC Moritt Hock Hamroff LLP Heywood Hospital McClelland Law Firm PC Johns Hopkins University Law Offices of Kevin J Keenan Morris & Titus Law Firm PC LLO H-Five Consulting LLC McConnell Vald?s Johnson Graffe Keay & Moniz Law Offices of Lyn E. Beggs, Motion Picture & Television Fund Hillcrest Health Services McConville Considine Cooman & Johnson Insurance PLLC Moyle Law Firm PA Hinkle Law Firm LLC Morin PC Johnston Allison & Hord PA Law Offices of Mandy C MTBC Hinman Howard & Kattell LLP McCue Pauley PC Rosenblum Much Shelist Denenberg Ament Johnstone Adams Bailey Gordon McCumber Daniels Buntz Hartig Hirschler Fleischer Law Offices of Mark S Joffe & Rubenstein & Harris LLC & Puig PA Hirschler Fleischer PC Law Offices of Martha Swartz Munsch Hardt Kopf & Harr PC Jones Wallace LLC McGinnis Lochridge Hiscock & Barclay LLP Law Offices of Peter A Lewis PL Murtha Cullina LLP JTaylor McGladrey LLP Hoagland Longo Moran Dunst & Judicial Dispute Resolution Law Offices of Pullano & Farrow MVP Health Care Doukas LLP PLLC MVP Health Care Inc

A9 AHLA Connections June 2015 2015 AHLA Top Honors

Myers & Jenkins PC Office of the General Counsel- PreCheck Inc Rose Sundstrom & Bentley Sonosky Chambers Sachse Myers Brier & Kelly LLP Office of the Governor for the Premier Inc Rosenstein Fist & Ringold Inc Enderson & Perry LLP State of Arkansas Nall & Miller LLP Presence Health Roshka DeWulf & Patten Sorling Northrup Office of the General Counsel Southcentral Foundation Nancy Weinman OhioHealth Corporation Prime Healthcare Services Inc Rothberg Logan & Warsco LLP National Association for Home Princeton HealthCare System Rusing Lopez & Lizardi PLLC SouthEast Alaska Regional Ogden Murphy Wallace PLLC Health Consortium Care & Hospice Principle Valuation LLC Ruskin Moscou Faltischek PC Ohio Hospital Association SoutheastHEALTH National Government Services Proactive Medical Review & Rutgers University New Ohio State University Wexner Sparrow Health System National Guardian Life Insurance Medical Center Consulting LLC Brunswick Sparrow Hospital Navigant Consulting Ohio University Procopio Cory Hargreaves & Rutland Regional Medical Center Navigant Consulting Inc Savitch LLP Ryan Swanson & Cleveland PLLC Spartanburg Regional Health OhioHealth Corp Care Services District Inc Neider & Boucher Professional Risk Management Sacks Tierney PA OhioHealth Corporation Services Inc Spectrum Health Hospitals Neighborhood Health Plan of Sacopulos Johnson & Sacopulos Olsson Frank Weeda Terman Progressive Acute Care Spectrum Health Partners LLC Rhode Island Matz PC Sacred Heart Health System Prohealth Physicians Spilman Thomas & Battle PLLC Nelson Mullins Riley & O’Melveny & Myers LLP Sacred Heart Hospital Scarborough LLP ProMedica Health System Springpoint Senior Living Inc O’Neil Cannon Hollman DeJong Safety Net Hospitals for Nemours/Alfred I. duPont & Laing SC Promise Healthcare Pharmaceutical Access St Anthony Medical Center Hospital for Children Oregon Department of Justice Promise Healthcare Inc Saint Francis Health System St Francis Hospital & Health Neosho Memorial Regional Prospira PainCare Inc System Medical Center Oregon Health & Science Saint Francis Hospital University Providence Hospital St John Health System New Directions Behavioral Health Saint Joseph Mercy Oakland Orlin & Cohen Orthopedic Provident Resources Group Inc St Jude Children’s Research LLC Saint Josephs Healthcare System Hospital Associates LLP Publix Super Markets Inc New Haven Community Medical Saint Luke’s Episcopal Health St Louis University Group Ortho Carolina Purchase Anesthesia PSC System OSF Healthcare System St Luke’s Hospital & Health New Jersey Dental Association Quality Reimbursement Services Salud Para La Gente Network Ottenwess Taweel Schenk PLC New Orleans Center for Clinical Quarles Law Firm Samuels Yoelin Kantor LLP St Mary Medical Center Research Overton Russell Doerr and Questcare Medical Services PA San Francisco General Hospital St Mary’s Health Care System Inc New York Blood Center Donovan LLP Racine Olson Nye Budge & Bailey San Juan Regional Medical St Michael’s Medical Center Inc Health and Ozarks Medical Center Chtd Center St Raphael Healthcare System Hospitals Corporation P V Kent & Associates PC Radia Sanchez-Betances Sifre & Munoz New York Hospital of Queens PAAS National Inc Noya CSP Stafford Piller Murnane Kelleher & Rady Children’s Hospital & Health Trombley PLLC New York Medical College Pacific Medical Inc Center Sandberg Phoenix & Von Gontard PC Stammer McKnight Barnum & New York Presbyterian Hospital Pagosa Springs Medical Center Rady Children’s Hospital San Bailey LLP Diego Schenck Price Smith & King LLP New York State Department of Palmarella Curry & Kelly PC Stanford University Medical Financial Services Palmetto GBA LLC Randall L Hughes Schiff And Bernstein PC Center New York State Office of the Palmetto Health Rawls McNelis & Mitchell PC Schilt & Heinrich LLP Starnes Davis Florie LLP Medicaid Inspector General Palmetto Health Alliance Ray Howard & Associates Schmiedeskamp Robertson Neu State of Nebraska DHHS Legal New York University Hospitals Ray Quinney & Nebeker & Mitchell Services Center Palos Community Hospital Ray Quinney & Nebeker PC Schneider Smeltz Ranney & State of New Hampshire New York University Langone Pamela Bray Basconi PLLC LaFond PLL Realty Trust Group State University of New York Medical Center Pamela Popp Schwartz Manes Ruby & Slovin Reed Tinsley CPA Central Upstate Medical New York-Presbyterian Hospital PAML Scripps Health University Newby Lewis Kaminski & Jones Parkland Health & Hospital Reed Weitkamp Schell & Vice PLLC Seattle Children’s Hospital State Volunteer Mutual Insurance Newman Dierst Hales PLLC System Company Reese Pyle Drake & Meyer Security Health Plan of Wisconsin Newton General Hospital Parks Bauer Sime Winkler & Inc Stathopulos & Associates Fernety LLP Refuah Health Center NHRMA Mutual Select Medical Corporation Stephen B Awalt PA Parrish Law Offices Refuah Health Center Inc NHRMA Mutual Insurance Self Regional Healthcare Steptoe & Johnson LLP Parsonage Vandenack Williams Regency-Pacific Management Company Sell & Melton LLP Steven J Marcus & Partners LLC Regional Health Nix Health Care System Senior Care Centers Stewart Courington Dugger Dean Parsons Behle & Latimer Rehabilitation Institute of Chicago Nixon Peobody LLP Shaheen & Gordon, P.A. PLLC Parsons Kinghorn Harris Reilly Wolfson Sheffey Schrum & Norman Hanson & DeTroy LLC Stinson Leonard Street Parsons Kinghorn Harris PC Lundberg LLP Sharon Loftus Norman Regional Hospital Stinson Morrison Hecker LLP Partners Healthcare System Reinhardt Whitley Wilmot & Sharp Healthcare Norris McLaughling Marcus PA Stoll Keenon & Ogden PLLC Patient First Corporation Summerlin PC Sheehan Phinney Bass & Green North Carolina Hospital PA Stoll Keenon Ogden PLLC Patzik Frank & Samonty Ltd Reliant Medical Group Inc Association Sherman Silverstein Kohl Rose & Stony Brook University Hospital Patzik Frank & Samotny Ltd RezLegal LLC North Dakota University System Podolsky Strayer University / Old Dominion PeaceHealth Rhode Island Health Care North Mississippi Health Services Association Shindler Neff Holmes Worline & University Inc Pediatrix Medical Group Mohler LLP Richards Rodriguez & Skeith LLP Stroock & Stroock & Lavan LLP North Oaks Health System Penn State Milton S Hershey Shuttleworth & Ingersoll PLC Ridenour Hienton & Lewis PLLC SUNY Stony Brook Office of Northwest Community Medical Center Shutts & Bowen LLP General Counsel Rindler Morgan PC Healthcare Penn Stuart & Eskridge Siddel Law Survey Management Services Riverside Medical Center Northwestern Memorial Hospital Pennington PA Siegel Barnett & Schultz LLP Susan B Collingwood Attorney Rivkin Radler LLP Norton Healthcare Inc Pennsylvania Medical Society Signature Healthcare Corporation at Law Robert A Auclair PC Norwalk Hospital Peoples Health Network Signature HealthCARE LLC Susan M Schaffer Attorney at Robert G Eaton JD MBA FACHE Law PA Norwegian American Hospital Peter H Wickersham PC Singularity Legal PLLC Robert N Meals PLLC Susan Sugar Nathan PA Notaro & Laing PC Phelan Tucker Mullen Walker Siskind Susser PC Novant Health Legal Affairs Dept Tucker Gelman LLP Robert Valencia A Professional Taggart Morton Law Corporation Sisters of Mercy Health System Novant Health Legal Dept Physicians Choice Laboratory Inc Taggart Morton LLC Services Robert W Rasch PA Novitas Solutions SK Operating Partners LLC Tallahassee Memorial Healthcare Robert Wood Johnson Hospital Physicians Insurance A Mutual Taylor Healthcare Consulting Nutile Pitz & Associates Company Hamilton Skilled Healthcare LLC Taylor Porter Brooks & Phillips Nutter McClennen & Fish LLP Robert Wood Johnson University Sklar Williams PLLC Pierce & Mandell PC LLC Oakwood Healthcare Inc Hospital Smith & Nephew Inc Pierce Atwood LLP Taylor Porter Brooks & Phillips Robertson Overbey Smith Duggan Buell & Rufo LLP Ochsner Health System Pima County Attorney’s Office LLP Robinson Memorial Hospital Smith Gambrell & Russell LLP O’Conco Healthcare Consultants Pioneer Health Services Inc Team Health Robison Curphey & O’Connell Smith Hulsey & Busey O’Connor Thomas Plews Shadley Racher & Braun Tenet Health LLC Smith Moore Leatherwood Office of General Counsel LLP Tennessee Health Management Rockford Health System Office of the Attorney General- Popovits & Robinson SmithAmundsen LLC Inc Roetzel & Andress LPA Dep Health and Mental Porter Wright Morris & Arthur LLP Smolker Bartlett Schlosser Loeb Texas A&M College of Medicine Rogers Lewis Jackson Mann & & Hinds Office of the El Centro City Post Acute Medical Texas Association of Community Attorney Quinn LLC Posternak Blankstein & Lund LLP Snellings Breard Sartor Inabnett Health Centers Office of the General Counsel Rogers Towers PA & Trascher PoynerSpruill LLP Texas Department of State Health Rogers Townsend & Thomas PC Solaris Health System Services

healthlawyers.org A10 2015 AHLA Top Honors

Texas Medical Association Eastern District of Wisconsin VantagePoint HealthCare Wood & Smith PC Texas Organ Sharing Alliance United States Attorney’s Office Advisors Worden Thane PC Texas Woman’s University for the Middle District of Varnum LLP WVU Healthcare Tennessee The American Orthopaedic Venable LLP Wyoming Medical Center UnityPoint Health - Methodist Association Veralon Partners Yale New Haven Health System Universal American The Brooklyn Hospital Center Vertex Pharmaceuticals Z Management Group Ltd Universal Health Services Incorporated The Caribbean Kidney Center Zayas Mayo Law Offices PSC The Carle Foundation Universal Health Services of Vestevich Mallender DuBois & Delaware Inc Dritsas PC Zeigler Cohen & Koch The Children’s Mercy Hospital University General Counsel Via Christi Health Zuckerman Spaeder LLP The Cummings Law Practice University Health Care System- ViaHealth Rochester General Zuger Kirmis & Smith The Curtis Group Inc Non-Profit Health System Dodd L’Hommedieu & McGrievy The Falvello Law Firm PC University Hospitals Health Vibra Healthcare LLC LLC The Forsyth Institute System Inc Virginia Hospital and Healthcare Gray Reed & McGraw PC The Gilliland Law Firm PC University Missouri KC Association Law Offices of Justin L Gordon The Greater Fairbanks University of Alabama Virtua Health Inc Community Hospital University of Detroit Mercy Visiting Nurse Service Foundation Incorporated School of Law Vividus LLC The Greenberg Dresevic Iwrey University of Florida Office of Vogel Law Firm Kalmowitz & Pendleton Law General Counsel Group Von Dohlen Group University of Houston Law Center The Guthrie Clinic W Thomas Boyd Jr PA University of Houston School The Health Group of Law Wagner Myers & Sanger PC The Health Law Offices of University of Illinois Wake Forest Baptist Medical Anthony C. Vitale Center University of Kansas Hospital The Hospital of Central Walder Hayden & Brogan PA Connecticut University of Kansas Medical Center Research Institute Waldman Trigoboff Hildebrandt The Joint Commission Marx & Calnan PA University of Kentucky The Lancaster Group LLC Walgreen Co University of Maryland Medical The Law Offices of Louise T Center Wall Esleeck Babcock LLP Jeroslow PA University of Maryland Medical Walmart Stores Inc The Moran Company System Ward Murray Pace & Johnson PC The Nathanson Group PLLC University of Massachusetts Washington Health Care Assn The Permanente Medical Group Medical School Washington State Medical The Queens Health System Legal University of Memphis Cecil C Association Dept Humphreys School of Law Washington University in St Louis The Queen’s Medical Center University of Missouri Watkinson Laird Rubenstein The Rufus Choate House University of Missouri Healthcare Baldwin & Burgess PC The Shelnutt Law Firm PC System Watson Blanche Wilson & Posner The University of Kansas Hospital University of Nevada School of LLP Medicine Theresa Zimmerman Consultants Watts Donovan & Tilley PA LLC University of Pennsylvania Office Weber & Nelson PLLC of the General Counsel Thompson Hines LLP Weill Cornell Medical College Ofc University of Pittsburgh Tibbetts Keating & Butler LLC of Univ Counsel University of Richmond School Timberline Billing Service LLC Weinberg Wheeler Hudgins Gunn of Law & Dial LLC Torkildson Katz University of Southern California Well Point Inc Toro Palacios Law Office PSC University of Texas MD Anderson Wellmark BCBS Touro Infirmary Cancer Center WellStar Health System Inc Tracy Mabry Law PA University of Utah West Penn Allegheny Health Trenam Kemker University of Utah Health Care System Triad Isotopes Inc University of Utah Hospitals & West Tennessee Healthcare Clinics TriCenturion West Virginia University University of Virginia Medical Trillium Community Health Plan Westchester General Hospital Inc True Guarnieri Ayer LLP Center University of Washington Western Connecticut Health Tucker Chiu Hebesha & Ward PC Network Updike Kelly & Spellacy PC Tufts Medical Center WESTMED Medical Group Tufts University School of US Department of Health & Human Services Whechel Dunlap Jarrard & Walker Medicine LLP Turek DeVore PC US Department of Health and Human Services Whelchel & Carlton LLP Turner Padget Graham & Laney Whiteman Osterman & Hanna PA US Department of Veterans Affairs LLP Tutera Senior Living & Health US Oncology Whitfield & Eddy PLC Care LLC Wiggin and Dana LLP U.S. Department of Health and US Renal Care USA Healthcare Willamette Management Human Services Associates UB Associates Inc USC School of Medicine University Specialty Clinics Williams Kastner UC Davis School of Medicine Williams Kastner & Gibbs PLLC UCHastings College of the Law UTMB T Galveston UW Medical Foundation Williams Parker Harrison Dietz UCLA Health System & Getzen UCSF Fresno Risk Management Vafiades Brountas & Kominsky LLP Williams Turner & Holmes PC UHS of Delaware Inc Valley Baptist Health System Williams Williams Rattnert & Ulmer & Berne LLP Plunkett Valley Children’s Hospital UMass Memorial Health Care Windsor House Inc ValueOptions Inc. UMass Memorial Healthcare Wisconsin Hospital Association Van Osdol Magruder Erickson & UNC - Chapel Hill Redmond PC WithumSmith & Brown UNC Health Care System Van Winkle Buck Wall Starnes WL Gore & Associates Inc UNC School of Law & Davis Wolcott Rivers Gates United Church Homes Inc Vanderbilt University Medical Wolf Haldenstein Adler Freeman & Herz LLP United Health Services Inc Center Wolpert & Associates Inc United Healthcare Vandeventer Black LLP Wood & Lamping LLP United States Attorney’s Office

A11 AHLA Connections June 2015 2015 AHLA Top Honors

2014 Honor Roll of Public Interest Donors

AHLA’s Public Interest Committee is grateful to the following individuals and corporations for their generous support of the Association’s Public Interest mission during the calendar year 2014 (1/1/2014-12/31/2014). Their contributions make possible the creation and distribution of several educational resources that are available for free to the public at large. Check out the digital issue of this magazine to see those in the Friend ($100 - $249) and Sustaining Contributors ($99 and under) giving clubs. Visit www.healthlawyers.org/donors to see the complete list of donors.

Special thanks to the following individuals who Jerry A. Bell Jr. Michael A. Cassidy James Franklin Owens Timothy P. Blanchard Alex M. Clarke Karen R. Palmersheim have pledged their support to AHLA Public Michael H. Cook Edward Steele Clayton, IV Jarrod W Pearson Interest with automatic monthly donations Almeta E. Cooper Robert L. Coffield Kimberly E. Peery through campaigns like our 12 for 12 Campaign. Dr Dale H. Cowan H. Guy Collier John R. Phillips Michael H. Cook Harry L. Dadds Jane Reister Conard Carol A. Poindexter Gregory M. Duckett Thomas S. Crane Kathleen M. Premo Brian D. Gradle Barbara J. Duffy Auburn K. Daily David B. Pursell Margaret M. Manning J. Kay Felt Maria Greco Danaher Deborah A. Randall Teresa A. Williams Edward Michael Flanagan Anthea R. Daniels Richard D. Raskin Nancy P. Gillette Harold J. Daub Jr. Lisa Pierce Reisz Lois Wischkaemper Wendy C. Goldstein Jennifer Andrews Demaree Mary Holloway Richard Marc D. Goldstone John J. Dempsey Vicki L. Robinson Brian D. Gradle Petra Lee Dodd Linda G. Rodrigue Corporate Donors Douglas J. Hammer Joseph A. Donchess James Roosevelt Jr. Anne W. Hance Todd M. Ebersole Dina B. Ross Silver ($1,000 - $2,499) Lisa A. Hathaway J.D. Epstein Linda S. Ross Husch Blackwell LLP J. Reginald Hill David Florin Michael D. Roth Rick L. Hindmand James F. Flynn Ross E. Sallade Leonard C. Homer Nancy E. Forbes Michael F. Schaff Bronze ($100 - $999) Alan C. Horowitz Donna D. Fraiche Beth J. Schermer The Rozovsky Group Inc Thomas K. Hyatt Jeanne F. Franklin Susan O. Scheutzow The Health Law Firm John R. Jacob Lloyd A. George Suzanne J. Scrutton The Bittinger Law Firm Clevonne M. Jacobs Stuart Yael Gordon Judith Jurin Semo Laura F. Laemmle-Weidenfeld Dr. Eric B. Gordon Albert W. Shay Medical Compliance Associates Inc Robert F. Leibenluft Emily Black Grey Nancy J. Sheehan Diego J Loinaz Martin PSC Arthur N. Lerner Anna M. Grizzle Jerrold Shenkman Baptist Memorial Health Care Corporation David T. Lewis Christina Hage Thomas N. Shorter Alice G Gosfield & Associates PC Melissa L. Markey Claire Cowart Haltom Michael L. Silhol Patricia A. Markus Kristen A. Harris Stuart I. Silverman Tom Mayo Tiffany Hetland H. Terrence Smith Kevin G. McAnaney William W. Horton ross Ross E. Stromberg Hal McCard David J. Hyman G. Thomas Sullivan Individual Donors Rachel Nosowsky Tracy C Ivers T.J. Sullivan Michael W. Paddock Jody E. Joiner Sarah E. Swank Visionary Patron Rebekah N. Plowman Michael J. Jordan Michaela Tabela ($2,500 or more) ($500 - $999) Dorthula H. Powell-Woodson Andrea M. Kahn-Kothmann Karl A. Thallner, Jr Theodore N. Giovanis Gail B. Agrawal Robert L. Roth Jeffrey L. Kapp Melissa M. Thompson James W. Boswell Monica R. Salusky Julie E. Kass Jane Hyatt Thorpe Benefactor Richard J. Brockman Asha B. Scielzo Carol A. Kenney Eugene Tillman ($1,000 - $2,499) David S. Cade Dr Richard F. Tompkins Thomas J. Kenny Robert J. Tomaso Barry D. Alexander Curt J. Chase Cavender C. Kimble James L. Touse John T. Brennan Jr. Lois Dehls Cornell Friend William A. Kindorf III Cori Casey Turner James Michael Cole Dawn R. Crumel ($100 - $249) Patricia D. King Lisa Diehl Vandecaveye Gary W. Eiland Paul R. DeMuro Lisa J. Acevedo Richard G. Korman Thomas D. Vaughn Douglas A. Hastings Thomas C. Fox S. Allan Adelman Alan D. Lash Howard T. Wall III S. Craig Holden Joel M. Hamme Timothy B. Adelman Joanne R. Lax Judith A. Waltz Robert G. Homchick Kerry B. Hoggard Gregory D. Anderson Amy S. Leopard Elizabeth S. Warren Mark A. Kadzielski Ann T. Hollenbeck Briggs W. Andrews Daniel E. Lohr Katherine G. Watts Marilyn Lamar James P. Kelly Michael F. Anthony Kim Harvey Looney Stephanie Ann Webster Jay A. Martus Christine A. Lay Dennis M. Barry Gregory M. Luce Charles R. Whipple David E. Matyas Peter M. Leibold Daniel H. Beck Kevin D. Lyles Barbara Straub Williams Kathleen McDermott Margaret M. Manning Elisabeth Belmont Douglas M. Mancino Lisa Ohrin Wilson Charlene L. McGinty David Marx Jr. Katherine Benesch William H. Maruca Lois Wischkaemper Peter A. Pavarini Joel L. Michaels John T. Bentivoglio William T. Mathias Cynthia F. Wisner Glen A. Reed Barbara L. Miltenberger Ann M. Bittinger Peter M Mellette Patricia Yakimo Kristen B. Rosati Dinetia M. Newman Stephen M. Blaes Jacqueline M. Melonas Richard L. Shackelford Cynthia Y. Reisz Bonnie S. Brier Heather Siegel Miller Sanford V. Teplitzky Edward F. Shay Jason E. Bring Jeffrey S. Moore Teresa A. Williams Toby G. Singer Edwin E. Brooks Linda Sauser Moroney Craig H. Smith Teresa Meinders Burkett E. Haavi Morreim Harvey M. Tettlebaum Kathy H. Butler Lewis Morris Ralph V. Topinka Neil B. Caesar Andrew J. Murray Eric Zimmerman Michael R. Callahan Robin Locke Nagele Contributor Terri Wagner Cammarano Paul Gustav Neumann ($250 - $499) Laura A. Carpenter Charles B. Oppenheim

healthlawyers.org A12 2015 AHLA Top Honors

Sustaining Contributor Lenis L Archer Robert F. Barron Lester Blumberg Keith Hamilton Brinkley ($99 and under) Jeanine M. Arden-Ornt Gertrude C. Bartel Rud Blumentritt James Broadway Elyse Aasen Joseph L. Ardery Jennifer Lea Bartnesky-Smith Julian D. Bobbitt Jr. Bernadette M. Broccolo Hasanah Abdul-Mani Christopher L Arellano Pamela Basconi George W. Bodenger Arthur P. Brock J. Mark Abernathy Timothy B. Arellano Jonathon Bashford Steve Thomas Boell Jeffery R Brodek Brenda Glaser Abrams Stephanie Anne Argoitia Patricia A. Bass Lisa S. H. Boero Timothy E. Brogan Donald L. Abrams Maria Arista-Volsky Bryan K Bassett Judith Lynn Boes Jeffrey S. Bromme William Richard Abrams W. Darrell Armer Alexander G. Bateman Barron P. Bogatto Nyda S. Brook Jennifer J. Abrell Bruce D. Armon Heather Bates Holly Jo Bohannan James Craig Brooks Terri L. Ackerman Craig R Armstrong Reed R Bates Kristin Bohl William F. Brossman Jr. Susan M.C. Adams David J. Armstrong Robert J. Baudino, Jr Julia P Boisvert Kristie Brotherton Anca Adams Norman Armstrong, Jr Jonathan H. Bauer Francie E. Boland Christopher E Brown Beverley Adams Bruce G. Arnold S. Derek Bauer Deirdre J. Boling-Lewis Anne M. Brown Neal W. Adams Diane Steele Arsenault Kelly Makins Baugh Katharine S. Bolland Eshghi Brooke Brown Rodney K. Adams Charles I. Artz David B Baxter Paul Bollinger David E. Brown Rebecca Adelman, PLLC Tricia A. Asaro Cynthia Paige Bayer Jennifer G. Bolton Deborah A. Brown Mitchell A. Adler William J. Aseltyne Kenneth S. Bayer Kari M. Bomash Gary W. Brown Carole M. Agee David C. Ashburn Robert M. Beachy Tate M. Bombard Laura Brown Sara J. Agne Shane Ashby John R. Beal Mark A. Bonanno Lowell C. Brown Melinda A. Agsten Anthony Ashenhurst Winston V. Beard Carol Ruth Bonebrake Matthew K. Brown Vickie B Ahlers Laura Ashpole Stanton M. Beatty Nancy Elizabeth Bonifant Matthew Collin Brown J Boone Aiken III Dr. Carl F. Asseff Myralinn Beaver-Scofield Dawn Bonnecaze Nathan A. Brown Nicole J Aiken Vickie S. Atkins Kate L. Bechen Judith A. Borenstein Paul R. Brown Dan Alan Akenhead Reagan C. Atwood David C. Beck Claire Bornstein Robert F. Brown Jr. Constance L. Akridge Evan Kent Auberry Steven N. Beck Stacey A. Borowicz Theodore C. Brown Carla Knight Alaee Robert A. Auclair Alice J. Becker Mark A. Borreliz Venel D. Brown Dr Erin L. Albert Marcia L. Augsburger Kris M. Becker Sean Bosack Ann Bruzzese Leslie D Alderman III Cynthia L. Augustyn Thomas C. Becker Miss Celia S. Bosco Laura Brymer Jeffery M. Alexander Sally N. Austin David D. Becsey Alyssa Boss Joseph A. Bubba Lisa Alexander Donald R. Auten Lyn Beggs Perry Boulier Carol A. Bucci Marci A. Alexander Stephen B. Awalt Norman R. Belanger Jodi N. Bourque Kathryn Bucher R. Alan Alexander Gary L. Ayers William A. Bell Francesca Bove Barbara Hayes Buell Scott D. Alfree Neil E. Ayervais Juan C. Bellido Kenneth T Bowden II John Edward Buerkert Jr. Beverly Rice Allen Tiana Gibson Ayotte Jenifer A. Belt Carol E. Bowen Thomas N. Bulleit Jr. Heidi S Allen Robert Brian Azar Paul R. Belton Kate Bowen Mark T. Bullock Mary Ellen Allen Sharon P Azurin Dawn G. Benson Hilary N Bowman Katherine S. Bunn Jared W. Allen Craig M. Babbitt James Barrett Benton Michelle N Boyd Christian Kizer Burbank Brittany Allison Thomas J. Babbo Sandra H. Benzer Ann Boyd Jennifer Downs Burgar Stephen P. Allison Matthew D. Babcock Caroline J Berdzik William Thomas Boyd Cathy L. Burgess Allen D. Allred Cara Conway Bachenheimer Bradley J. Berg Wm. Stephen Boyd Marilyn H. Burgess Michelle Almeida Radha V. Bachman Jesse A. Berg Lisa M. Boyle Michael A Burian William J. Alsentzer Jr. Ivy Baer Andrew R. Berger Gregory Boyle Rebecca L. Burke William M. Altman Amber W. Bagley Bruce J. Berger Robert Joseph Bozeman Daniel E. Burke Virginia C. Alverson Allana L. Bailey Mary J. Berger Donald L. Bradfield Denise D. Burke Lauren Ambler James Thomas Bailey Donna Potts Bergeson Angela Bradley Kathleen M. Burke Cindy M. Amedee Renee D Baine Carl Bergetz John S. Bradley Virginia M. Burke Anastasia Kralovec Anderson Heide A Bajnrauh Sara Cooper Berkson Melissa M. Bradley David A. Burlage Michael D Anderson Constance H. Baker Brian L. Berlandi Kathy C. Bradley-Wells Richard B. Burnham Bruce A. Anderson Jessica M. Baker Daniel M. Bernick Jennifer Gimler Brady Mark Burnheimer Cynthia C. Anderson Dale Baker Michael H. Bernstein Shannon Larner Brainard Lawrence P. Burns Jeannine Anderson Michael J. Baker Steven E. Bernstein Amy Branaman Carrie L. Burnsed Joan Humphrey Anderson Susan Cresto Baker Daniel L. Berry Anne Novick Branan Meredith Mlynar Burris John A. Anderson Timothy H. Baker Aaron Jay Besen Catherine A. Brandon Eric R Burris Judith D Anderson Gilda Baldwin Brian C. Betner Gail Friend Brandt Meagen Burrows Kelly R. Anderson Thomas Baldwin Amanda Surojnie Bhikhari Simone Brathwaite Barbara S. Burstein Laura D. Anderson Rian Balfour Isabelle Bibet-Kalinyak Kurt E Bratten Misti Burton Michaela Bantilan Andrawis Melinda A Balian Diane E Bieri Saralisa C. Brau Sara Buscher Briar A. Andresen Adam Balick Antoinette G. Biglang-Awa Jeffrey P. Braud Roxane C. Busey Nicole Andreson Yoel H. Balter Neville M. Bilimoria Jessica Flax Braunstein Dr. John D. Busowski Laura Miller Andrew Edo Banach Gerald J. Billow Lisa J. Bray Catherine M. Butler Bruce W Andrews Ellie Bane Janet N. Billups Wendy E. Brazil David L. Butler April Andrews-Singh Steven F. Banghart Beverly H. Binner Kent Breard Jr. Jennifer L. Butler Janis E. Anfossi Kenneth B. Banks Jackie Olson Bird Paul Breaux Timothy F Butler Stephanie Summer Angeloni Paula J. Banks Irwin M. Birnbaum James Patrick Bredehoft Richard L. Butler Lianne Ankner Robert A. Barba Mitchell Jan Birzon Martin Bree Wesley R. Butler Mazda Antia Sally Nan Barber Brian W Bisignani Elizabeth A. Breen Vincent N. Buttaci Mary Powers Antoine Jennifer S. Bard Caroline E. Bissett Robert L. Brent Jason A. Butterworth James M. Antoun Ronald R. Barkley Catherine M. Bitzan Andrew Ross Brenton Terrance K Byrne Hema Rao Anwar Serina Quinones Barkley Eric Bixler Christopher P. Brewer Michael P. Byrne Joseph T Aoun, S.J. Daniel Clayton Barks Jehanne M Bjornebye Robert G. Brewer Jr. Jill Quattlebaum Byrum David R. Aplington Warren L. Barnes Erich Blackburn Aaron J Brezko Rene Cabral-Daniels Rosemary Apol-Hoezee Drew Barnholtz Barbara Blackmond David R. Brickman Fran Cadez Albert M. Appel Collin P. Baron Douglas A. Blair G. Ross Bridgman Maureen E. Cafferty II Gordon J. Apple Stephanie Marie Barr Michael L. Blau Frank J. Brier Timothy J. Cahill Ginger Appleberry Kirsten Erath Barranti Tyrina D Blomer Jeremy S. Brieve Patricia S. Calhoun Sydney F. Arak Robert Barrett Susan B. Blum Jefferson Brinker Laurel K. Call

A13 AHLA Connections June 2015 2015 AHLA Top Honors

Elizabeth C. Callahan Christen C. Church Todd Cox Anthony George E. Lanier Drew Mary Calzaretta Dr Ann Leslie Claesson Robert J. Craddick Demetracopoulos, JD Toni M. Mileo Drohan Cynthia L. Cambron Edward Clancy Janet A. Craig Andrew J. Demetriou Matthew Drouin Jennifer Cammarano Donna S Clark Kathleen M. Cramer Martin Demos Lindsey Tomlinson Druhan Amy Tannery Campbell Evan L. Clark Michael Dean Cranwell Sr. Lauren C. DeMoss Anton J. Dubrick Bert L. Campbell Lisa W. Clark David Nathaniel Crapo Mollye M. Demosthenidy Michael Duddy David R. Campbell Nancy S Clark H Dale Anthony Crawford Laurence W. Dempsey Kathleen Duffett Forrest W. Campbell Robert B. Clark John Creighton III Monica R. Dempsey Jerry R. Duffie M. Douglas Campbell Jr. Thomas P. Clark Michael D. Crew Michael M. Denbow Courtney Duffy Mark Andrew Campbell Tom Clark Lisa M Cribben Aimee E Dendrinos Erin M. Duffy William J Cannici Jr. Mary Beth Claus Charles J. Cronan, IV Daniel T. Dennehy Daniel J Dufresne Robin L Canowitz Martin M. Clay Robert C. Cross Linda D. Denomme R. Keith Dugger Jeanne L. Cantalin Roger R. Clayton Christopher L. Crosswhite Brett J. Denton Matthew Stephen Duke Richard J. Canter Kelly M Cleary Eric Johnson Crowder Lloyd G. DePew Charles C. Dunham, IV Ramon M. Cantu Miriam L. Clemons Mary Elizabeth Crum John F. Derenbecker Jason M. Dunn Melania M. Capone Steven E Clifton Julie B Cude Nicole Dermer Michael G. Durham Michael R. Capone Patrick C. Closson Mary Nell Cummings Tricia Morvan Derr John J. Durso Louis J. Capozzi Jr. Sarah A Coble Melissa Jean Cunningham David A. DeSimone James R. Dutro Michael R. Cardenas Kathryn R. Coburn Mark A. Cunningham Sandra DeSimone Adam M Dworkin Charles L. Carder III Dr R. Gregory Cochran Stewart A. Cunningham Terri A. DeSio Sue M. Dyer Kristen E. Carl Suzanne Cochran William T. Cuppett Meghan DesLauriers Dennis F. Dykhuizen Fred M. Carmichael Daniel A. Cody Ann M. Curran Patrick C. Devine Jr. Kathleen Eastberg Frank N. Stockdale Carney Allison Marie Cohen Holly Turner Curry Robyn Whipple Diaz Catherine Mode Eastham Damon Carpenter Laurie Tangora Cohen John B. Curtis Jr. Sonya Diaz Judith Eastridge Laurie Boreanaz Carra Aaron Cohen Thomas Curtis Florence L. DiBenedetto George Eaton Frances M. Carroll Hilary Huebsch Cohen Thomas M. Curtis John J. DiBernardi Jr. Robert Garcia Eaton Joseph J. Carroll Joanna L Cohen Io C. Cyrus Leonor Y Dicdican Shelley Ebenal Daniel O Carroll Michael Howard Cohen Sheryl Tatar Dacso Vincent L. DiCianni Jane Eckels Cecile Carson Michael S. Cohen Riza I Dagli Kyle Dickerson Therese Flynn Eckford Frank W. Carsonie Nancy E. Cohn Raymond R. D’Agostino Joseph A Dickinson Chad N Eckhardt Robert B. Carter Jesse Coleman Lisa L. Dahm Jean Diedrich Jennifer Rudenick Ecklund Walter Hammond Cartin Tracy E. Coleman John Dalbey Michael Diedrich Georgeann Edford Elizabeth Rada Carver Travis R. Collier Robin Dale Thomas Dierling Roxanne Baus Edling Henry M. Casale Susan B. Collingwood Naomi C. Dallob Mark O. Dietrich Susan Alexis Edwards Joan Casciari John D. Colombo Kenda Brashear Dalrymple James A. Dietz Calvin Edwards Patrick Shannon Casey Waldemar Antonio Comas Thomas Dame Sarah K. diFrancesca Gregory Thomas Edwards Regina Casey Steven P Combs Ernani J. D’Angelo Amy J. Dilcher Lisa Edwards Kevin L. Cash Rhonda L. Comer Don L. Daniel III Kevin J. Dill Christina M Egan Michael Casner Daniel P Condon Michele Daniele Nicole F. DiMaria Peter A. Egan Matthew William Caspari Brittany H. Cone Benjamin Martin Daniels Susan Marie DiMickele Shannon Coleman Egle Claire E. Castles Kathleen Theresa Connolly David E. Daniels Charles F. Dingman J. Scot Eibel Michelle R Caswell Kristin Connors Michael J. Daray Janice M. Dinner Gary Eiben Zachary I Cattell Julie Meredith Conrad John A. Darrow Arlene J. Diosegy Gregory Eich Sharon E. Caulfield Raymond G Console Richard L. Dashefsky Joseph DiVincenzo Jack A. Eiferman Tandy Causey Linda S. Consolo Carol A. Daubner Donald R. Dixon Alan H. Einhorn Anthony R. Cawiezell Roberto Contreras Eugene F. Dauchert Jr. Vu T. Do Erin McAlpin Eiselein David A. Centafont Karen P. Conway Bethan M. Davies Kirk H. Doan Carly Beth Eisenberg Jason J. Centolella Emily Jane Cook Donald A. Davies Kirk L. Dobbins Neil H. Ekblom, Sr Gregory M Chabon Chad Bryan Cook Derek S. Davis Stefanie A. Doebler Andrea L Eklund Marilu Chaez-Abreu K. Marshall Cook F. Kelly Davis James F. Doherty Eugene E. Elder, Esquire Ann Chaglassian Emily L Cooke Jennifer S. Davis Marshall J. Doke, Ph.D. Alison K Elk Kristin Chambers Andrew Cookingham Karen Davis Jerry H. Dolchin Jessica A. Ellel Thomas S. Chambless Kevin S. Cooman Nancy E. Davis William E. Doll Jr. David Ellenbogen Aaron R. Champney Cheryl L. Coon William Davis William A. Dombi Dan Elling Vivek Chandra Amy Elizabeth Cooper Dianne J. De La Mare Kirk Domescik Eileen I. Elliott Wesley Y.S. Chang Cary Rodman Cooper Louis David de la Parte Caroline T Donahue Cameron Ellis Amy Charley Elizabeth G. Cooper Bruce A. Dean Ian Donaldson Stephen Elwell John M. Charnecki Martha R. Cooper Julia A Dean David W. Donnell Edwin G. Emerson Michael W. Chase Carlo Coppo Thomas S. Dean Thomas M. Donohoe Karen O. Emmanuel Kathy Chavis Evan A. Coppola Jon P. DeBardeleben Robert E Dooley Keith E. Emmons Matthew A Chayt Erin Coppola Michelle Wilcox DeBarge Kenneth P. Doran Kathryn W. Enchelmayer J. Richard Cheney Terry L. Corbett Susan Leach DeBlasio Leilani M. Dornfeld Sally A. Enevoldson Limo T Cherian Susan M. Corle Kathleen L. DeBruhl Angelique P. Dorsey Kathleen Tobin Erb Michael J. Cherniga Kristina R. Corlette Patricia Bunn Decensi John H. Dotson Joanne B. Erde Alisa Lieberman Chestler Kevin A. Cornish Mandy Decker Melody Dougherty Jody Erdfarb Julie E. Chicoine Dorothy Hubbard Cornwell Mary Lee Decker, JD Katherine Douglas Francis M Ervin II Mark R. Chilson Jody J. Corry Felicia DeDominicis Michael E Douglas Laura DeMartini Eschleman Jason Chimon Margaret F. Costella Michael E. DeFrank Thomas E. Dowdell Donald R. Esposito, Jr Charles Robert Ching Danielle Costello Leanna Degenhart Thomas M. Dowling Beth Essig Mary Ann Chirba Jessica D. Cottey Matthew DeGioia Jenna Marie Downey Eric Essley Anthony H. Choe Alicia Cottrell James C. DeGlee Timothy H. Downie David A. Ettinger Perry Oswin Chrisman Christopher Leon Cottrell, Jr Pamela Del Negro John P. Doyle Jr. Thomas L Eure Laurie L Christensen Mary Jane Bendon Couch Mark N. Delevie Shannon L. Drake Molly S. Evans Charles John Chulack Thomas R. Courage Gerald E. DeLoss Nancy Drapalski Sara B Evans Julianne Chun Elliott Coward David W. DeLuce Danielle Erin Drayer Dana R. Ewing Beau M Chung Kamron C Cox Christopher Dean DeMeo Nancy M. Dregne Gregory C. Ewing Mark A. Dresnick

healthlawyers.org A14 2015 AHLA Top Honors

Michael J. Exler Jessica Forster Philip M. Gassel E. Lynn Gordon Linda Hake Sherry A. Fabina-Abney C Bradford Foster III Joan Gates Elliot K. Gordon Kathy A. Hales Eric D. Fader Kerry Foster Leah R. Gates Jill H. Gordon Kent A. Halkett Henry C. Fader Robin Van Winkle Foster Maniya Gatmaitan Andrew S. Gordon Michelle Lynn Hall Mary Kathleen Fagan James G. Fouassier Deborah Gavron-Ravenelle Paul A. Gordon Kathryn Haller Robert Emmett Fagan Jr. Amy E. Fouts John W. Geismar Justin Lee Gordon Barry D. Halpern Shari J. Fagen Brian D Fowler Benjamin Geizhals Charles X Gormally, Esq Ann M. Halphen James B. Falahee Jr. Justin Fowler Mark E. Gelfand Louis Barry Gorman Sarah L Ham Adam J. Falcone Steven J. Fox Lisa Atlas Genecov Alice G. Gosfield Frances W. Hamermesh Lynda P. Faldmo, RN Martha J. Frahm Teresa Generous Gerard R. Goulet Jonathan P. Hammond Theodore C. Falk R. Scott Fraley Timothy F. Gens Alan W Gracie William S. Hammond Martin J. Fallon William H. Fralin Jr. Christopher R. Genther Arey W Grady III Sara M. Hankins Thomas M. Farah Laura L. Frame, RN Elizabeth M. George Mona Patel Graham Sherry Hanley Barbara Dianne Farb John Franceschi Thomas M. George D. Collier Graham Jr. Katherine M. Hanna Kelsey Susan Farbotko John A. Francis Stephanie Gerber T. Andrew Graham Susan Hannasch Shannon W Farr Gloria H. Frank Stacy Gerber Ward Lori R Gramley Brad L Hansen Brett E. Farrow Robert S. Frank Robert A. Gerberry Paul Grana Kurt F. Hansen Samuel Trent Favre Philip R. Frankfort Malinda Paige Gerich Carmin D. Grandinetti Stephen A. Hansen Taylor D Fawns Marlene Franklin Debra A Geroux Harvey Granger Catherine I. Hanson Ramy Fayed Natalie Anne Franks Michele B. Gerroir David W. Grauer Mark J Hanson Frank P. Fedor Thomas R. Frantz Ruth Gershon Steven D. Gravely Cori R Haper Mark Feingold James Franz Shari Gerson Clay Grayson Dr Jack Lazare Harari J. Corey Feist Kenneth S. Frazier Ralph Gerstein Katherine Grayson Jennifer L. Hardester Janet K. Feldkamp Richard T. Frazier Neil V. Getnick Taunula Charnelle Grayson Heather Hardin-Theus John Fenner Katherine Frech Gregory Gheen Constance Mary Greaney Soyon Hardy John R Feore III Paul W. Frederick Frank D. Giardini Catherine M. Greaves Daniel C. Harkins Karen J. Ferguson James J. Fredman John H. Gibson Amy E. Greeley Sarah C. Harlan Lori C Ferguson Douglas S. Free Caroline D. Giddings Ashley Green Christopher B. Harmon Thomas Ferrante Melesa A. Freerks Roy Francis Gilbert Darcy Green Stacy N Harper Andrea M. Ferrari Lisa M. Frenkel Alan G. Gilchrist Gerald L. Green Susan Harper Carol A. Ferri Bruce Merlin Fried Tracie Butler Giles Jesse Green James G. Harrigan Christopher Graham Fete Kathryn Fried Elaine Gilmer Mitchell F. Green Michael Harrington, USN Debra F. Fields Robin Beth Fried J. Matthew Gilmore Daniel Ray Green Jr. Josephine Nelson Harriott Gary I. Fields Arnold I. Friede Alexis S. Gilroy Eli D. Greenberg Gregory Y. Harris Brian J. Fields Benjamin M. Friedman Patrick J. Giordano Christopher T. Greene Paul R. Harris Cherie M. Fieri David R. Friedman Robert Victor Giunta Jr. Alan I. Greene Susan Feigin Harris Robert P. Fine Joseph Friedman Denise W. Glass Robert Michael Greene C. Wade Harrison George A. Finkle Stacy A Friedman Robert W. Glass Marsha R. Greenfield Brenda Evans Hart Kristy Kay Finlayson Gilbert M. Frimet Michael Glasstetter Thomas W. Greeson Timothy A. Hartin Robert F Firestone Eric J. Frisch Kristin Olds Glavin Carol Grelecki Alison Hartley Matthew J Fischer S. Gregory Frogge Randall M. Glenn Peter L Griffith Laurie E. Hartman Samuel C. Fish Jeffrey Frost Victoria R. Glidden Robert A. Griffith Patricia J. Hartman Matthew Fisher Laura B. Frost Becky Friedrick Glitman Sarah P. Griffith Caitlin Hartsell Daniel Edward Fisher Michael J Fuchs Ralph L. Glover II Jess H. Griffiths Cory Hartsfield Diane Fisher Erin E. Fuller-Werries Marshall J. Gluck Abigail Wong Grigsby Judd A. Harwood Eric S. Fisher Dr Shawn L Fultz Steven Goby Andrew E. Grimm Sharon Sheets Harwood Shea Fitzekam Fred D. Furman Anuj K. Goel Brian Grimm Judi K. Hatcher Daniel P. Fitzgerald Carolyn Jacoby Gabbay Lauren Goff H. Theodore Grindal Dr Paul Andrew Hattis Mary Fitzgerald Jay M. Gabriel Ira S. Goffman David E. Grisham Fred J. Haupt Edward Fitzgerald Lindsey E Gabrielsen Julia Goings-Perrot Samantha Groden Amanda Haverdink Susan M. Fix Nicholas Gachassin III Avitai Gold David Gross Dr. Weldon E. Havins Christopher J. Flanagan Larry S. Gage Jeffrey S. Gold Samantha Gross Sterling Hawkins Jonathan D. Fleece Catherine A. Gale Kimberly J. Gold Jennifer L. Groves Carleta R. Hawley Kelli C. Fleming Judee Gallagher Martin B. Goldberg Brian D. Grubb Samuel Hawley Linda L Fleming Edward Gallagher Alan S. Goldberg Debra Lynne Gruenstein Gordon W Hawthorne Lisa Fleming Thomas M. Gallagher Evan Raskas Goldfarb Thomas J. Gryzbek Charles R. Hay Melissa W. Fleming Mark H. Gallant Jared A. Goldman Calla Wilson Gudeman Marian J. Hayden Nancy Fletcher Vivian M Gallo Jesse A. Goldner Nicole Blanche Guerin Amanda Hayes Kate Flewelling Marshall A. Gallop Jr. Alan Jay Goldstein Ricardo M. Guevara Daniel J. Hayes Gregory M. Fliszar Frederick B. Galt Neal T. Goldstein Frank Gumina Mark L. Hayes Abigail L Flitter Frank E. Gamma Steven M. Goldstein James F. Gunn Somer Hayes Andrea Flynn Meredith Gammill Merton G. Gollaher Jr. Amanda W. Gusart Brian A. Hayles Mary P. Foarde Gilbert F. Ganucheau Bethany Marie Gomez Tim Gutenberger Wilson Hayman Richard Fogelson Adrienne L Ganucheau Paul A. Gomez Robert A. Guy Jr. David D. Haynes Jr. James L Fogle Alan Gapinski Maileidy Gomez German Mark A. Guza Laura K. Haynes Kelsey E. Fohner Marco F. Garavaglia Denise V. Gonick John R. Gyllenhammer Kevin Healey Elizabeth Foley Julie Garcia Hilda Gonzalez Daniel R. Hackett Kathleen Gleason Healy Elizabeth M. Foley Preeti A. Garde Karina P Gonzalez Sylvia L Hackl Richard A. Hearn Patricia J. Foltz Chris Gardner Maria E. Gonzalez - Knavel Linda Haddad Brian M. Heaton Chacey Ford Deborah Kantar Gardner Warren L. Gooch Patrick J. Haddad H Edward Heckman Peggy Ford M. Craig Garner Jr. Michael Lawrence Goodman Helen Hadley Mark S. Hedberg Teresa I. Ford Donna Garr Stanley Goodman Thomas L. Hafemeister Jacqueline Hedblom Daniel Fordham Patti M Garrett Howard A Gootkin Mark A. Hagemeier Jim Heekin Patrick Formato Michael S Garrison Lisa Gora Rose Hager Maureen Brown Heffernan Daniel M. Formby Michelle M. Garvey Cecile L. Gordon Agnes D. Hagerty Jeffrey L. Heidt Katherine H. Forseth Brandie J. Gasper Crystal Gordon James L Haines Buck Heim

A15 AHLA Connections June 2015 2015 AHLA Top Honors

Elizabeth Margaret Hein Daniel Honberg Robert S. Iwrey Louise M. Joy Oliver Kim Catie Hilton Heindel Heath Hoobing Laura M. Jackman Mark Francis Juba Priscilla E. Kimball Matthew A. Heinle John Ryan Hood Beth Anne Jackson Carmen Jule Anne S. Kimbol Kerry L. Heinrich Paula L. Hooper John Zen Jackson Jeffrey R. Jury Marilou M. King Ruth Heitz Michael Ryan Hoover Rebecca L. Jackson Edward J. Kabala Dr Jaime King Jordan Heller Timothy W Hoover Shelley Jackson Thomas W. Kahle Adam Bruno King Chad W. Helmick Stuart Hopen Wes Jackson Joseph M. Kahn Richard J. King Jr. Jeanne E. Helton Margaret Lynch Hopkins William O. Jackson James R. Kahn Warren E. Kingsley Jean C. Hemphill John Hopkins Kyle J. Jacobi Carol Ann Kalish Eric Kintner Michael C. Hemsley Jonn D. Hoppe Carolyn Jacobs Vasilios J. Kalogredis Allyson Hancock Kinzel Jennifer R. Henderson Michael T. Horan James S. Jacobs James W. Kaminski Crane D. Kipp Christy L. Hendricks Joy M. Hord Frederick J Jacobs Christopher N. Kanagawa Kimberly Short Kirk John Wade Hendricks Robert R. Horger Seth A. Jacobs John R. Kancilia Charlotte Suzann Kirkland Glenn P. Hendrix Dr. Jennifer Horner Tina Jadhav Robert John Kane Thomas L. Kirkland Jr. Susan Baldwin Hendrix Mark J. Horoschak Andrea M. Jahn Alan M. Kanter Anna Kirkman Carol A. Hendry Michelle Gosselin Horrigan Hunter Jamerson Brendi E Kaplan Andrea Kirshenbaum Suzanne E. Hennessy Patrice M. Horstman Terry Mitchell James III Karin Chernoff Kaplan Kari M. Klasen Christian F. Henning Jr. Tamara Reinglass Horton Susan G James Morris J. Kaplan Tracey L. Klein Brent L. Henry Brandon M. Horvath Daniel O. Jamison Peggy Crespi Kaplan Donna G. Klein Steven D Henry Eve T. Horwitz John H. Jankoff Harry Kapralos Mathew R. Klein Jr. Paul Douglas Henson II Aila Hoss Christopher G. Janney Thomas J. Kapusta Matthew Klein John Herchenroder Theresa Marie Hottenroth Carl S. Jean-Baptiste Shellie Karno Michael F. Klein Miriam W Hermann John I. Houseal Jr. Norman Jeddeloh Tanya E. Karwaki Robert H. Klein Jr. Teresa Hernandez Damian Hovancik Matthew D. Jenkins Gina M. Kastel Roger Brink Barry S. Herrin Dr John S. Howard Jill Gossin Jensen Katherine M Katchen Sharon R. Klein Donn H. Herring Jeffrey L. Howard Allan D. Jergesen Francine Halushka Katz Lauren Klemm Mary Elizabeth Herring Kathleen Marie Howard Paul Jernigan Laura L. Katz Michael Joseph Kline Thomas E. Herrmann Dana C Howells McFadden Louise T. Jeroslow William R. Kauffman Andrew D. Kloeckner Gary W. Herschman Thomas A. Hoy William R. Jewell David Andrew Kaufman Mary R. Knack Tina Batra Hershey Sharon A. Hoyle Michael Joachim Michelle Stark Kaufman Gary E. Knight Catherine L. Hess John Huang Meredith Jobe Ron S. Kaufman Patrick J. Knight Thomas W. Hess Matthew Robert Hubbell Nicole K Jobe Pamela S. Kaufmann Teresa Knoedler John Paul Hessburg Ben C. Huddleston Mark S. Joffe Gregory S. Kaupp Kevin C. Knowlton Matthew C. Hesse Richard A. Hudson Chris A Johlie Rose Marie Kavalchuck William A. Knowlton Daniel J. Hettich Amy R. Hudspeth Ryan S. Johnson Peter M. Kazon Jennifer Knudson Timothy L. Hewson John Huffman Annette B. Johnson Jordan Kearney Julie A. Knutson Steve E. Hicks Christina Hughes Daryl P. Johnson Robert M. Keating Gary D. Koch Cynthia C. Higgs Michael Hughes Elizabeth A. Johnson Margaret A. Keavney Susan F Koch Tizgel K. S. High James L Hughes Jennifer Johnson William P. Keefer Valerie Gutmann Koch Meghan N Highfield Randall L. Hughes Kristin M Johnson Marie Keeley Patrick F Koenen Angela Fenton Hill Rose Hughes Laurie B Johnson Elizabeth Keenan Anaheeta Zubin Kolah George Russell Hill Tisa Hughes Margaret Johnson Kevin J. Keenan Kathryn Sullivan Kolar Robert J. Hill William Hulse Mildred L. Johnson Joseph Bradley Keillor E. Raymond Kolarsey Jennifer L. Hilliard Scott E. Hultstrand Jeremy L Johnson Peter E. Keith Tracy Vigness Kolb Mary Anne Hilliard David M. Humiston John A. Johnson Anisa P. Kelley Daniel M. Koliadko Jr. Bethany J. Hills Lillian S. Hummel Roberta R. Johnson Douglas A. Kelley Kathleen W. Kolodgy Latasha G Hines Robin Humphries Rodney A. Johnson Alden Kellogg Russell A. Kolsrud Bradley Scott Hinkle Susan R. Huntington Sandra T. Johnson John E. Kelly Jr. Tomer Konowiecki James Stephen Hinkle Jeffrey Gilbert Hurd Stephen E. Johnson Scott Kelly Bernadette M. Konzelman Claudia A. Hinrichsen Patrick J Hurd Steven L. Johnson Beth Kelsch David E. Kopans Loretta M. Hinton Catherine A. Hurley Timothy A. Johnson Jackie M. Kendinger Mark S. Kopson Robbie Hinz Kendall B Hussey Vanessa L Johnson Martha M. Kendrick Andrea J. Kosloski Daniel Pierce Hiser Jennifer C. Hutchens Christopher C. Johnston Joanne Kenna Barry N Koslow William O. Hochkammer Thomas N. Hutchinson Christian W Johnston Craig A. Kennedy Tomek Koszylko Lucy C. Hodder Cynthia B. Hutto Pamela L. Johnston Dennis P. Kennedy Philip Koutnik Elizabeth F. Hodge Albert D. Hutzler, IV Peter S. Johnston Cornell Kennedy Charles B. Koval Garrick Hodge Thuy P. Huynh John F. Jonas G. Marshall Kent, Jr Laura Kowal Robert M. Hoffer Carol A. Hyde Carolynn R Jones Kathryn M. Kenyon Paul Kozachenko Shannon Hoffert David M. Hyman Celeste T. Jones Alex John Keoskey Joseph M. Kozak Ashley Filip Hoffman Sara Elizabeth Hyre Diane R Jones Christopher L. Keough Deborah A Kozemko David N. Hoffman Laurence J. Iacueo Dr Andrea Denise Jones John C. S. Kepner Jennifer A. Kozinn Marta J. Hoffman Bernabe A. Icaza Jessica L. Jones Emilia Keric Daniel A. Kracov Max R. Hoffman Jr. Katherine B. Ilten Leslie R. Jones Stuart G. Kertzner Richard C. Kraus Patricia S. Hofstra Steven E. Imbriaco Linwood L. Jones J Paige Kesman Joan H. Krause Carla E. Hogan Frances A. Impellizzeri Luther G. Jones III James M. Kessler Michael Krause Dr Noel C Hogan Gabriel L. Imperato Matthew C. Jones Anastasia G. Khokhryakova Katherine Betz Kravitz John M. Hogan George F. Indest III C. Scott Jones Alexandra Khorover Michael L. Kreager Heidi Hohendorf, JD Stevens L. Ingraham Keith McCloud Jones Maryann P. Kicenuik Raymond J. Kreichelt Janet S. Holcombe Lucie Ingram Richard T. Jones Geralyn A. Kidera Jennifer Kreick John R. Holdenried Scott K Intner Stephen D. Jones J. Richard Kiefer Eric Kreimer Danielle E. Holley Hilary L. Isacson Wilson G. Jones Kim Kikkawa Jacque Krejci Judy Hollingsworth Teri Ann Isacson Harold W. Jordan II Brian J. Kilbane Stephen R. Kretschman Catherine T Hollis Harold N. Iselin Charles M. Jordan Jr. Carrie Norbin Killoran Cynthia Kretz Edith H. Holloman Robert H. Iseman Naomi Jorgensen Grant C Killoran Clara J. Kridle Eileen L. Holloway Mark A. Ison James M. Jorling Allen R. Killworth Alfred E Kritter, Jr Michael R. Holzhueter John C Ivins Jr. William Jourdain Karen Kim Allen J Krouse III

healthlawyers.org A16 2015 AHLA Top Honors

Todd A. Kruger Laurie J. Levin Cory D. Macdonald Michelle McBroom Leslie M. Meserole Caroline Elizabeth Kubovy Joel R. Levin David M. Mack Andrew M. McCarthy Carolyn Victoria Metnick Kathleen Kuha Jan P. Levine Grace D. Mack Kelly A. McCarthy Elizabeth B. Metz Jeffrey C. Kuhn Michael C. Levine Charles F. MacKelvie Leslie McCarthy Margaret Ann Metzger Dan Kuninsky Rosemaria Levinsky Erin F. MacLean Kelly Lee McClelland Albert R Meyer Sarah Kleaveland Kupczak David Jeffrey Leviss Michael D. Macomber Daniel Mead McClure Christopher R. Meyer Michael A. Kurs Bruce A. Levy Kevin M. Madagan Nicholas S. McConnell Diane Meyer Margaret A. Kurzyniec Jay E. Levy Michael Madsen Carmen McCormick Donna J. Meyer Diane Kutzko Sally Kaplan Levy Julia H Magda Thomas Lynn McCormick Zachary J. Meyer Kris Kwolek Gerald T. Lewandowski Gregg C. Magera William P. McCormick John A. Meyers Thao La Loretta B. Todzia Lewin Ashley R Maguire Lela McCoy Nicholas H Meza Robert B. Labe Anne M. Lewis Sheryl S. Mahaney Stephen C. McCoy Joline Miceli-Mullen Robert L. Lackey Browne C. Lewis Joseph C. Maher Timothy M. McCrystal C. Kim Michael Ronald B. Lahner Dr. Douglas Augustus Lewis Dennis P. Maher David McCue Elaine M. Michaud Christopher Lai Heather Sanderson Lewis Sally L. Maher Andrew R. McCumber Carol P. Michel Linda C. Laing John Alan Lewis Catherine Mahoney David L. McCune Jeffrey G. Micklos Jessica C. LaManna Peter Allan Lewis Jr. Mary O’Toole Mahoney James D. McDonald Jr. Jenna Mihm Brett Lamb Mary L L’Hommedieu Tony R. Maida Kelly A. McDonald Claire F. Miley David W. Lamb Kimberly A. Licata Gwendolyn Roberts Majette John P McDonald Tracy E. Miller Bruce D. Lamb Julie Lichte Bobby Majumder Lisa McDougall Don E Miller Jordan Lambert Mary Michelle Lickteig Benjamin P. Malerba Michael J. McDougall Janet L. Miller Rebecca K. Lambeth Robert J. Lightfoot II Lindsay Maleson Ryan McGary Jeremy N. Miller Barry S. Landsberg Scott Lilly Betsy R. Malik Timothy A. McGeath Kendall Miller Brian Laney Meredith Dibert Lindaman Daniel A Malkoff Jon McGough Joseph Miller Paul A. Lang Erik P. Lindberg Michael S Malloy Megan McGovern Marvin G. Miller Mark S. Lange Eric A Lindenauer Thomas F Maloney Gertrude C. McGowan Nancy J. Miller Robert M. Langer James Lindsey Brenda M. Maloney Shafer Devin Jennifer McIlwee Susan A. Miller John T. Lanier Mary Therese Link Clare M. Mamerow Daniel J. McInerney Jr. Tracy A. Miller Kyle Lanning Lisa Linville William M. Mandell Kelly S. McIntosh Wayne J. Miller Francis J. LaPallo J. Robert Liset J. Anthony Manger Chad Brian McIntosh Robert F. Millman Deborah W. Larios Barry D. Liss Brandy Schnautz Mann Robert McKague Matthew T Milone Candace LaRochelle Elizabeth G. Litten Elizabeth Mann Carol Anne McKay Linda R. Minck Mariella LaRosa JoAnne K. Little Kenneth A Manning Craig M. McKee Steven T. Mindlin Greg Larson Nicole G Litton Felicia Valerie Manno T. Braxton McKee Jay Douglas Mitchell Lee F. Lasris Catherine E. Livingston Jessica Mantel Allen Joseph McKenna Jennifer Orr Mitchell Kevin M. Lastorino Travis Grainger Lloyd Michelle Ann Mantine Sean R. McKenna John D. Mitchell Katherine A. Lauer A. Russell Localio Kris D’Ann Maples David B. McKinney LeeAnne M. Mitchell Jodi B. Laurence Camille Lockhart, CPA Prof Ann Marie Marciarille Rhonda B. McKinnis Gregory S Mitchell Diane Lawrence Alexis Lockshin Kenneth R. Marcus Madison McKissick Philip D. Mitchell John H. Lawrence Jr. David E. Loder Steven J. Marcus Carrie S. McLain Suzanne Mitchell Sonya Lawrence Sharon M. Loftus Scott J. Mariani Lori McLaughlin William R. Mitchelson Jr. Katherine M. Layman Robert P. Lombardi Ari J. Markenson Patricia McLean Marianna Miyazaki Ellen Luepke Layton Catherine Eleanore London Carin A. Marney Jeffrey McMahan John W. Mize Mark W. Leach Amy L. Longo Thomas S. Marrion David W. McMillan Lisa C. Mock Robert E. Leamer Lawrence L. Lopardo Brianne L Marriott Melissa Sampson McMorrow Jen L. Modjeska Colin Leary Hector R. Lopez Tricia Marriott Marshall A. McMullen Jr. Diane Bissonnette Moes David K. Leatherberry Angie E. Lord Christopher Marsh Patrick J. McNamara Daniel J. Mohan Philip H. Lebowitz John S. Lord Jr. Douglass A. Marshall Dr Kathleen W. McNicholas, M.D. Michael J. Mohr Leon E. LeBreton Ted Lotchin Lois A. Marshall Keely R. McNulty Lorraine Molinari Bruce J. Lederman Gary F. Loveridge Mary R. Marta Steven L. McPheeters Russ Molloy Brooke Jennifer Ledger Susan E. Lovern Carrie L. Martignetti Lisa Adrian McPherson Grace P. Monaco David B. Lee Richard A. Lowe Alson R. Martin Miss Karen McPherson Timothy E. Monaghan Tin Kin Lee Charles A. Luband Amie Ryan Martin Linda S. McPike Donna M. Moniz Tracy Avis Lee-Huber Janeanne C. Lubin-Szafranski James A. Martin Jr. Gary J. McRay Jennifer C. Monroe Michael P. Lehman Carol K. Lucas Peter J. Martin Amy Olson McReynolds Valerie B. Montague S. Ruth Lehr Christopher S. Lucas Phillip A. Martin Mark A. McSally Miss Amelia Rose Montgomery Lance O. Leider Mimi Deaton Lucas Renee H. Martin Stephen A. McSween Renee J. Montgomery Kurt A. Leifheit Rachel D. Ludwig Amanda J. Martinez Holland N. McTyeire Susan Purcell Montiel Russell M. Lein Krista Ludwikoski Bradley V Martorana Robert N. Meals Melinda M. Montoya Brett Leitner Richard H. Lugli Marguerite A. Massett Steven Means Alice Keith Moore Reid D. Leitner Dr Tammy Lundstrom John J. Masternick Jr. Maxwell J. Mehlman Eric Moore Catherine A. Leitzel Ann E. Lundy Lori E. Masterson Kristin Meier Mary Ann E. Moore Michele LeMoal-Gray Holley Thames Lutz Tracy Mathis Daniel Meier Robert Meredith Moore James Andrew Lemons Kathryn Rooney Lyaker Kristin E. Matisziw Arthur Meisel Stephen T. Moore Maureen Lenihan Kathleen Lynaugh Roseanne M. Matricciani Jeremy Meisel Patricia Moore-Boyette Adam Mansfield Lentz Dennis M. Lynch Rebecca A. Matthews Dr. Hagop S. Mekhjian Cecilia H. Morgan Alyson M. Leone Karina V. Lynch Mark L. Mattioli Christopher J Melcher Kevin D. Morgan Patricia B. LePore Mary Beth Lynch Rachael Maxwell-Jolly Mitch H. Melfi D’Andrea J. Morning Gregg J. Lepper Patricia M. Lynch-Epps Marilyn May David R. Melloh Michael A. Moroney Janet L. Lerman Mona Ma Kenneth May Tatiana Melnik Denis Morrill Bradley Ethan Lerner Marilyn Maag Judy W. Mayer Dr. Mark Charles Menadue Riikka E Morrill Bruce Leshine Stephen J Maag J. Robert McAllister III Arnold I. Menchel David T. Morris Susan K. Lessack Donna Maassen Elizabeth L McAmis W. Carl Mendenhall John B. Morris Ronald L. Lester Billy J. Mabry Thomas R. McAskin Rachelle S. Mercier Julia Caldwell Morris Paul E. Levenson Tracy J. Mabry Laura C. McBride Scott R. Mertie Stanley L. Morris David A. Levenstein Alexander M. Macaulay Andrew F. McBride III Ralph K. Merzbach Susan Morris

A17 AHLA Connections June 2015 2015 AHLA Top Honors

Kelly J. Morrison Janet M. Norton Alan D. Pauw Cara W. Powers Leo E. Reichert Martin B Morrissey Mark Novak Mike Pavlakis John E. Powers II Kelly B. Reilly Kathleen A. Morse Valerie Novales W. A. Payne Jr. Matthew F. Powers Emily Elizabeth Reiners Saul J. Morse Michael A. Novo Wilford A. Payne III Trenton J. Poynter Claudia E. Reingruber David J. Mortensen Gerard M. Nussbaum David B. Pearce Lucy Prashker John B. Reiss, Ph.D. Nathan C. Mortier Maria Nutile Reid Pearlman Richard Prebil Gaibrelle Reissland Mark Allan Mosby Joseph G. Nuyen, Jr Ashley Denise Pearson David R. Prechtel Timothy Resch Jeffrey D. Moseley Debby Thetford Nye George Louis Pearson Marshall Vernon Preddy Terri L. Rexrode Marie Crepeau Moseley Ellwood F. Oakley III Cynthia Folse Pechon Mary E. Prentnieks Lesley Carol Reynolds Nancy E. Moser Harold B. Oakley Jeffrey M. Pecore Margaret Price Max M. Reynolds Robert D. Mosher Timothy J. O’Brien Elizabeth L. Pedersen Mark H. Price Vanessa A. Reynolds Tricia J Mueller Kimberly O’Connell Patrick J. Pedro Michael O. Price Penny J. Rezet Anjali Mulchandani-West Teresa Ann O’Connell Philip Peisch Sandra A. Price Kathleen M Rhoads Daniel Mulholland Richard T. O’Connor Maria J. Pekar James J. Pringle Eytan R. Ribner William Joseph Mulkeen Nanette O’Donnell Meg S.L. Pekarske Patricia Jones Pritchett Paul F. Richard Karen Ann Mullin Anne P. Ogilby Jess Martin Pekarski Glenn P. Prives Amy K Richards Michael Andrew Mullins Lisa Lattal Ogorzalek, jd Robert A. Pelaia Richard Probert Jeffrey Scott Richardson Jennifer Belcher Munsey Kirk Ogrosky Benjamin Peltier David D. Proctor Lesley Ford Richer Myra M. Munson Grace E. Oh Sonya C. Penley Ashley Williams Provost Collin Richmond Robert W. Muren Tonya Okon Gregory J. Pepe Andrew H. Prussack Edward D. Rickert Elizabeth Cheever Murphy Jody E Okrzesik Ann Peraud Cooke Steven Paul Przybyla Michelle Rider Karen Elizabeth Murphy George G. Olsen Jerrold R. Perchik Yvonne K. Puig Joe Don Ridgell Kathleen E. Murphy Margaret A. Olsen Matthew Perreault Marcelo Puiggari Karen S. Rieger Patricia M Murphy Arden J. Olson Wade B. Perry Jr. Katherine L Pullen Gray Wright Rifkin Paul R. Murphy Patricia M. Olsson Edward V. Pershing Janet L. Pulliam R. Terry Rigsby Philip J. Murphy Deborah D Olszewski Douglas A Pessefall Ivan J. Punchatz Ethan E. Rii Stacey L. Murphy Kevin P. O’Mahony Mark W. Peters Ann Purdy Jason S. Rimes Cornelius Murray Michael John O’Malley Brian M. Peters Robert E. Puterbaugh Alan B. Rindler David J. Murray Daniela J O’Mara Gerald R. Peters Karen A. Putnal Anthony F. Ringold Maureen Demarest Murray Chara Moore O’Neale Daniel W. Peters Jacqueline Quam Linda L. Rippey-Moore Melinda G. Murray Robert J. O’Neil Carolyn Petersen Denise L Quarles Joseph T. Ritchey Jerry J Musheno Samuel D. Orbovich Richard N. Peterson Dr. Donald E. Quigley Malcolm E. Ritsch Jr. Rodney Alan Myer Kris Ordelheide Tracy Nicole Peterson Thomas J. Quinlan Albert R. Riviezzo Regina Myers Susan B. Orr Marc L. Peterzell James L. Quinlan Ayman Rizkalla Charles F. Myers Becky Orttel Kami M. Petitgoue Thomas B. Quinn Katherine Rizzo Dinah Myers Timothy J. O’Shaughnessy Bruce I. Petrie Patricia Quinn Brian L. Robare Michael Myers Heather M. O’Shea Dana P. Petrillo Kathleen Quiroz David B Robbins Elizabeth M. Myers Jamie Ostroff Mary M. Petrinjak Diane M. Racicot Mary K Robbins-Kralapp Silpa Myneni Stephanie P Ottenwess Stephen C. Petrovich Linda Raclin James Roberts Kari L Myrold James M Otto Brian Petry Laurie G. Radler Lori R. Roberts Ken M. Nanney Langdon T. Owen Jr. Thu T Pham Daniel P. Rafferty Matthew B. Roberts Jonathan Napier Karen C. Owens Eileen Hayes Phelps Karen C. Rainey Michael G. Roberts Abby S. Nash Marcus S. Owens Mark T. Phelps Sonja C. Rajki William J. Roberts Susan Sugar Nathan Dennis L Padget Michael D. Phillips Christine M. Ramatowski William E. Roberts Margery F. Nathanson Erik C. Pahl P. Scott Phillips Todd C. Ramberg Clifford E Robertson II Jeffrey Paul Natterman Scott C. Palecki Mary S. Philp Theresa J. Rambosek Rosetta B Robins Barbra Zan Nault Karen L. Palestini Kristie E Piasta Andrew R. Ramirez Alice Robinson Eugene R. Naylor Ernest D. Palmarella Gregory R. Piche Dr. Ronald L. Ramsdell Deborah J. Robinson Marian Pearlman Nease Thomas Palmer Stephanie A. Piel Lance J. Ramsey Charles Arthur Robinson II Jonathan A. Neiditz Lisa Panah Jessica D. Pierce Rhea K. Ramsey Alicia M. Robles de La Lama Robert Kaiser Neiman Mario L. Paniagua Kevin Pierce Zachary S. Ramsey Patricia A. Roche Kimberly L. Nelson Alexandra I. Papasifakis Melissa K. Pifko Reed Cullen Randel Damian M.P. Rodgers Laura Nelson Leonore Tavill Paragas Susanna S Piller Laura Range Kathy A. Roe Nancy Lee Nelson Nancy E. Paridy Elisabeth A. Pimentel Kanika Mehta Rankin Alan T. Rogalski Ward W. Nelson Ann Paris James M. Pinna Cynthia Ransburg-Brown John F. Rogers Jennifer M. Nelson Carney Michael H. Park Christopher Pirtle August J. Rantz, IV Julie Lin Rogers Melanie Neumeyer Gigi Parke Justin D. Pitt Kevin E. Raphael Carol Rolf Ann H. Nevers Lawson S Parker II Kathy Pitts Michael T. Rapp Gerardo R. Rollison John D. Newman Sandra L. Parker William Pivik Dr Robert Rappel Martha C Romney Nolan Newman Sharon C. Parker Normand F. Pizza Craig Marc Rappel Curtis Rooney Nancy Constance Newman John P. Parman Kathy Plaksin Jill M. Rappis Leighton P. Roper III Deirdre Newton Laurine Symula Parmely Deborah S. Platz Robert W. Rasch Noemí Rosado Robert R. Niccolini Gabriel M. Parra Thomas K. Pobgee Ann L. Rasenberger Lorilyn Marie Chaneco Rosales- Brian D. Nichols Christopher A. Parrella David Pointer Gregory J Rastatter Menzel Charles Scott Nichols Debra M. Parrish Joanne E. Pollak Michael P. Rauchwarg Jerry P. Roscoe Dwight Dewayne Nichols Jeffery D. Parrish Earl Pomeroy Katea M. Ravega Adam C. Rose Virginia Rosalie Nicholson Brian M. Parrott James M. Pool John W. Ray Jr. Rachel Veronica Rose Sara Noel Mary P. Parsons Pamela W. Popp Mary C. Raymond Tonya Oliver Rose Julie E Nolan Jeffrey B Parsons Kathy L. Poppitt Stephen G. Reardon Doris Roseindra Lori K. Nomura Michael S. Passet Joel C. Porter Sally A. Reavely Beth S. Rosenbaum Marianne Noonan David C. Pate Robert J. Portin Elizabeth Amy Reddell Gary A Rosenberg Timothy Scott Noonan Lenora W. Pate Sharon L Post Bonnie A. Redder Philip Rosenberg Shelley Catherine Nordling Shilpa S Patel Anita O. Poston Matthew J Redding Alan G. Rosenbloom Abigail Norris Colleen O’Connor Patzer James G Potter Linda Reddington Mandy C. Rosenblum DeAngelo Norris Elizabeth A. Pauchnik Thomas E. Powell II James L. Reed Jr. John L. Rosenthal, Esquire Lisa Norris Michael E. Paulhus Apriel R Powell Martin Brian T. Regan Stephen D. Rosenthal

healthlawyers.org A18 2015 AHLA Top Honors

Paul J. Roshka Jr. James R. Schiffer Juli K. Shields Michael A Smith David G. Stobb Eve Ross Andrew Schilder Machelle D. Shields Philip J. Smith Bruce C. Stockburger Hilary H. Ross Andrew Schillinger Cindy Shifflett Richard C. Smith M. Bruce Stokes Lawrence M. Ross Karen C. Schimpf Shelly L. Shiflet Sandy J. Smith Jack Mark Stolier Darryl Ross Devin Schindler Douglas Shin Stacy Smith Robert M. Stone Brad M. Rostolsky Elizabeth Schlaff Justan R Shinkle Steven R. Smith David D. Storey Zachary Rothenberg C.J. Schmidt III Benjamin H. Shipley Thomas B. Smith Tillery Stout Phillip A. Rothermich Timothy B. Schmidt E. William S. Shipman Charles Smouse Brenda T. Strama Ila S. Rothschild Peggy F. Schmitt Robert K Sholl Karina C Smuclovisky Miriam Straus Mary L. Rotunno Michael K. Schmitt Erin M. Shoudt Carmen L. Snell Cynthia F. Strauss James C. Rowan Randal D. Schmitt Tara A Shuman Erin P. Snyder Sally S. Strauss Mary R. Rowe Robert Charles Schneider Catherine Sicker Margaret Snyder Lisa Stravinskas Lauren Marie Rowinski Bryan A. Schneider Keith Siddel Melissa S. Snyder Alexandra Jane Streznewski Barbara Rowland Ronald W. Schneider Linda L. Siderius Alan J. Sobol Marshall P Strisik Robert M. Rozier Elizabeth Swinton Schoen Sharon A Siefert Kenneth J. Sodaro Brian Seth Strohl Fay A. Rozovsky Margot P Schoenborn Stephen H. Siegel Sheila Sokolowski Wallis S. Stromberg Maureen Anne Ruane Joseph Schohl Richard W. Siehl Ishra Solieman Ariane Strombom Kimberly S. Ruark Deidre A. Schonfeldt John Sier Ayman Soliman Tracy M Strong Wendy L. Rubas Lance D. Schreiner Richard Siever Jane E. Solly Robert S. Stroud Breanne Marie Rubin Carole C. Schriefer Jamie Sifre-Rodriguez Darrell J. Solomon Katharine E Struck Lori A. Rubin Joel A. Schuessler Bob Siggins Susan V. Sommers Sarah D. Strum Leigh J. Rubinstein Karen Duke Schuller Gerald M. Sill Matthew R. Sorrentino Donald B. Stuart Ross E. Rudolph Randal L. Schultz Francisco Javier Silva John T. Soshnik Jennifer K. Stuart Jonathan L. Rue Spencer Schulz Tracy E. Silverman Weissman Frank T. Sossi Deborah L Stuck Gary K. Ruff Douglas A. Schur Kyle A. Silvers Stephen Sozio Stephen A. Studer Orly R. Rumberg William P. Schurgin Frank J. Silvestri Jr. Sidney Spaeth Thomas S. Stukes Brenda J. Runner Theresa M. Schurman Jeffrey L. Silvestrini Bruce Darwin Spector Edward A. Stumpp Valerie S. Rup Richard L. Schuster Austin Sim E.L. Clark Speese Peyton M. Sturges Andrew P. Rusczek James Schuster Julie A. Simer Gwendolyn J. Spencer Nicole Stuver Marie Boyce Russell Andrew Joseph Schwab Clifford Simmons Lora Spencer Rachel Juhas Suddarth Carlos Anthony Russo Robert W. Schwaneberg Adrianne J. Simon Christopher Spevak Richard A Sugarman Kelly A. Ryan Jeffrey B. Schwartz Gordon Simonds Dean Allen Spina Joel I. Suldan Neda M Ryan Daniel A. Schwartz Rebecca L. Simone Richard B. Spohn Brian L. Sullivan Sheridan L Ryan Robert H. Schwartz Allison C. Simpson Theresa Marie Sprain Dr Walter Gerard Sullivan Janice L. Ryba Andrew D. Schwartzkopf Dana E. Simpson Jolie C. Spring Kelly R Sullivan Houeida Saad David E. Schweighoefer Elizabeth A. Simpson Sarah C Spurlock Stephen M. Sullivan Richard Sabath George W. Scofield Jennifer L. Simpson-Oliver Elizabeth R St. Clair Lois Snyder Sulmasy Christopher C. Sabis Jeff Sconyers Marguerita Brunson Sims John A. St. Peter Karen H. Summerlin Mary Frances Sabo Dennis S. Scott Lawrence E. Singer Norman S. Stachelek Jr. Robin P. Sumner Michael J. Sacopulos Marjorie J. Scott Pete Spencer Singer Kristen M. Staikos Andre B. Susla Jeffrey C. Sacra Phillip D. Scott John A. Siracusa Melinda Fox Staley David A. Sutherland Scott M. Safriet Mary F. Scranton LaKeisha Sisco-Beck Angela R Standish Summer D. Swallow Jennifer Sala Thomas A. Scully Gregory H. Siskind Lynn A. Stansel Kathleen Swanson Julia Salahshour Kimberlee A. Seah Laura K. Sitar James P Stanzell Lynn Swanson Christine Salimbene Bethany Seeboth Richard L. Sites Catherine Yong Starks Charles J Swartwout James A Saling Donald Segal Chris Skagen Lynn M. Stathas Martha S. Swartz Payam Saljoughian Cynthia L. Sehr Heather Skelton Andrew Stathopulos Charles L. Sweeris John H Samalik Jr. Robert Chase Seibel Michael E. Skindrud Perry R. Staub Jr. Rochelle Sweetman Jean A. Sampson Richard Seiden Elizabeth Skinner Zachary Thomas Steadman Peter Swenson Roland F. Samson III Rachel A. Seifert Honey Jacobs Skinner Daniel P. Stech John B. Swihart Gabriela Sanchez Michael D. Seitzinger Alan C. Sklar Kevin Steck Douglas B. Swill Paula G. Sanders Temple Sellers Darren Skyles Nathan W. Steed Ann Marie Carr Swindler Amy Sanders Paul A. Seltman Debra Slater Richard A. Steffen Stephanie N. Switzer Elizabeth Sandoval Francis J. Serbaroli Eve Slattery Jill A. Steinberg Laura J. Sy Robert O. Sands Gracelyn Sessions Terrence M. Slaven Hillary Stemple Kathryn Sylvia Lcdo. Carlos A. Santiago Rosario Daniel K. Settelmayer Robert E. Slavkin Suzanne K. Sterling Julie K. Szeker Richard Ernest Santora Nancy B. Sever David G. Slezak Jennifer M. Sternshein Norman G. Tabler Jr. Katherine Carter Santos Michael B. Sexton Stanley Slipakoff Daniel Z. Sternthal Robert Taflinger Teresa P Sappington,FACHE,F Douglas J. Shaeffer Jayson S. Slotnik Betsy M. Stevens R. Andrew Taggart Jr. AAPM,MBA,MCPM,CPHQ,C Bhavi A. Shah William Smart Jr. Jason D. Stevens Jessica A Talati PMSM Raj Shah Marcia B. Smith Robert G. Stevens Ashoke S. Talukdar M. Elizabeth Sassano Alexandra Shalom Michael L. Smith Stacy Lyn Stevens Thomas J. Tamburelli Lisa Satterfield Erika Fisher Shamash Alissa D. Smith Gelvina Rodriguez Stevenson Gregory R. Tapfar Mark S. Saudek Thomas B. Shapira Barry Lynn Smith Casey S Stevenson Carol A. Tarnowsky H. Carol Saul Daniel M. Share Bruce A. Smith Robert A. Stevenson Lisa Taylor Keith J. Saunders Ozair M Shariff Cambria A. Smith Ellen E. Stewart Bernard Taylor Sr. Karen McKeithen Schaede Alexander D. Sharnoff Charlotte A. Smith John Darin Stewart Earnesta L. Taylor Karen B. Schapira Christopher J. Shaughnessy Clifton Smith Leah B. Stewart Hillary Taylor Jennifer Scharf Elizabeth D. Shaw Elise D. Smith Mary H. Stewart Jerry W. Taylor Laura E Schattschneider Daniel F. Shay Elizabeth Thomas Smith Timothy William Stewart Lorraine T. Taylor Gordon B. Schatz Carolyn Shearer Elizabeth Truesdell Smith William B. Stewart Darrell W. Taylor Marc J. Scheineson Erin Davis Shedd Fred Smith William H. Stiles Nancy E. Taylor Jane S. Schelberg Ronald B. Sheff Gregory James Smith William J. Stilling Grant Teegarden Jennifer L. Schenk William R. Shenton Gregory L. Smith Ferrier R. Stillman Juliann Tenney David L. Schick Kristoffer B. Shepard Jodie E. Smith Linda M. Stimmel Sarah E. Terrace Anthony Hunter Schiff Judith S. Sherwin Keith Alan Smith Jordan A Stivers Christopher T. Terrell William G. Schiffbauer

A19 AHLA Connections June 2015 2015 AHLA Top Honors

Jeffrey L. Terry Joseph H. Uberuaga II Tobin N. Watt Dennis P. Williams Theresa M. Zimmerman Maureen Testoni William Ullrich Richard D. Watters Bryan K. Williams William F. Ziprick Soleil E. Teubner Jon A. Unroe Rachael W Watts Denise Williams Jay A. Ziskind Karen Smith Thiel Karen A Unver James F. Weadick Lani Lee Williams Ann H. Zucker Sally L. Thieman Matthew Philip Utecht Robert E. Weatherford Mark S. Williams Judy Fricks Zybach Ashley Thomas Nicole G. Vaccarella Maureen Weaver Robert V. Williams Edward J. Zych Elizabeth T. Thomas Robert R. Valencia Mark L. Weaver Walter L. Williams Hugh R. Thomas Anthony Valle Rebecca A. Weaver William O. Williams James W. Thomas Paul Van Den Heuvel Michelle Moore Webb Deborah J. Williamson William R. Thomas Thomas H. Van Dis Dale S. Webber Keith H. Williamson Jan S. Thompson John Van Lonkhuyzen Emily K. Weber Daniel H. Willick Gina A. Thompson Thomas J. Van Meer Matthew G. Weber Angela S. Williford Mary H. Thompson Jennifer Beth Van Regenmorter Dan G. Webster III Stephanie D Willis Donald M. Thompson Lorelei Van Wey Laura Weeden Taunja Willis-Miller Richard L Thompson Jeanne L. Vance Grant Weimer D. Brent Wills Scott Thompson Ronald Lee Vance Morris Sandy Weinberg Jr. Bonnie L. Wilson Terence W. Thompson Mary E. Vandenack Barbara A. Weiner Ian Wilson Berryl Thompson-Broussard Anurag Varma William L. Weiner Laura J. Wilson Daniel Thomson David M. Vaughn Jennifer L. Weinfeld Mark E. Wilson Michael C. Thornhill Jean Wright Veilleux Nancy M. Weinman Molly McCartin Wilson D. McCarty Thornton Noreen Vergara Gadi Weinreich Eric J Wilson Eugene Thornton III Lawrence W. Vernaglia Jeffrey A. Weinstein Richard M. Wilson Leslie A. Thornton Greg R. Vetter Judy Weinstein Stacy Wilson John L. Thorpe Nancy R. Vidal Karen R. Weinstein David L. Wing Jeffrey C. Thrope Christina Calderwood Vigil Laurie E. Weinstein Kathryn K. Wire Peter L. Thurman Jr. Marta E. Vila Baez Barry Weiskopf Madeline S. Wirt Prof. Lance Tibbles Catherine L. Villalobos Russell E. Weitz Lorina Wise Justin B. Tilley Charles G. Vogel Patricia D. Weitzman Michael A. Wodrich Reed Tinsley Stuart J. Vogelsmeier Melissa E. Welch Lynne Anne Wolf Tammie J Tischler William Joseph Volonte Sidney S. Welch Douglas M. Wolfberg Edwin Tisdale Jim Voltz Alan L. Weldy Daniel Ray Wolfe, Jr Bernadette Tiso Timothy D. Von Dohlen Paul J. Welk Lisa Wolff Scott B Tittle Lee Voorhees Nathaniel Bradford Wells Doug Wolford Diane A. Todd David M. Vukadinovich Heidi Ann Wendel Frederick S. Wolfson Louis B. Todisco Andrew B. Wachler Peg Wendell Karen L.P. Wolfson David C. Tolley Adine B. Waddell Kristian Andrew Werling Bruce A. Wolpert Deborah Tolomeo Gregg C. Waddill III Jonathan C. Wertz Kevin M. Wood Eli Z Tomar Julie Wagner Kelly M. Wessell Ivan Wood Jr. Jean Tomasco Laura Wagner Howard P. West Jane Pine Wood Mindy S. Tompkins Cheryl L. Wagonhurst Sharon Lynn West Lane Wood Kristi L Tonn Catherine Walberg Whitney West Kenya S. Woodruff Anne Toomey James R. Walczak James R. Westbury Jr. Kristen McDermott Woodrum Bruce J. Toppin Glenn J. Waldman Donna S. Wetzler Shawn C. Worden Paul M. Torgerson Jeff Waldo Andrea W. Wever Clay Wortham Donna J. Torsney Daphne Walker Erin Whaley Christine Worthen Benjamin P. Townsend Donald J. Walker Cristina R. Wheat Jessica Leigh Wray Cristal Trackwell Gordon J. Walker Norma L. Wheelehon Ashley Tormoen Wright Regina Trainor Susan E Walker George T. Wheeler Jr. Harry S Wright, IV Thuy Ha Tran Yuri Nicholas Walker Jeffrey W. Wheeler Mark R Wright Ronald G. Trayner Jaime Walkowiak John D. Wheeler Kippy Wroten Donna Tribble James D. Wall Christine L. White Matthew Yanovitch Tamara L. Trimble John H. Wallace Annette M. White Denise C. Yarborough Dr William L. Trombetta McLain Wallace Benjamin T. White Douglas C. Yohe Gretchen Ackerman Tromp Thomas E. Wallace Craig White Jennifer Yoo J. Guthrie True Adele A. Waller Debra R. White William E. Young Tim Trysla Edward M. Waller Jr. Dr Alan White Howard J. Young Ernest L. Tsoules, Jr W. Challen Walling Dr. Bruce D. White James C. Young Brianna L Tsukamoto Michael Walters Janet Lynn White Hilary H. Young Theodore J. Tucci Lisa Walton Brian D. White Jack L. Young Dmitry Tuchinsky Jacqueline R Walus-Wigle Richard O White III James A. Young Campbell Tucker Rachel Ward K. Kelly White Bryant Kenneth L. Young R. Gehl Tucker Ann E. Ward James L. Whitlatch Melissa A. Young Richard M. Tucker Billee Lightvoet Ward Mary Jane Whitt Edward Yun Christopher J Tully Kristi Ward Caroline Wick Alan R. Yuspeh Thomas A. Tupitza Laura E. Ward Peter H. Wickersham H Christopher Zaenger Cynthia L. Turco Susan C. Ward Stuart M. Widman Melissa M. Zambri Claire Turcotte Jennifer R. Warden Herbert Kathryn M Widmayer Kari B. Zangerle Douglas Turek Jody Ward-Rannow Michael G. Wiethorn Joan Zanzola Matthew Turetzky Cinde Warmington Donald P. Wilcox Hedy S. Zaragoza Spencer K. Turnbull Dennis M. Warren Sylvia Robertson Wilcox Lu Zawistowich Dr Karen Dianne Turner Kevin Warren Lawrence H. Wilhite Luis Francisco Zayas-Marxuach Kenneth M. Turnipseed John R. Washlick Charles A. Wilhoite Anne Manie Zembrzuski Adam J. Tutaj Susan L. Watchman Tyler K Wilkinson Cara Zemenak M. Todd Tuten David E. Waters B. Curtis Wilkinson Louise B. Zeuli Cleve B. Tyler Lissa Wathen Brad T. Willbanks Craig J. Zicari Elizabeth D. Tyrrell Tom W. Watson Isaac M. Willett Colin J. Zick

healthlawyers.org A20 Mentoring

AHLA Mentoring Committee Year in Review–A Successful Year

By Dinetia M. Newman, AHLA Mentor/Mentee Database Mainte- where Ethan Rii led a panel discus- Mentoring Committee Chair nance and Matching sion of mentor/mentee best practices, When the 2014-2015 year began, it was and panel members identified rewards As we end AHLA’s 2014-15 evident from the number of unmatched each had received from participating Fiscal Year, AHLA’s Mentoring mentees and mentors that analysis was in AHLA’s Mentoring Program. Also Committee is looking back on our necessary to determine whether some during the Fundamentals program, recent activities. Since its launch six number of members of both groups Committee members Tony Choe and years ago, AHLA’s Mentoring Program had lost interest. Committee members Dinetia Newman spoke on health care has grown to include more than 751 Dan Kuninsky and Tony Choe, along research, with a particular focus on member mentors and mentees. Thanks with AHLA staff, focused on “cleaning Medicare research, to an audience of to the members of this year’s Committee up” the mentor database, determining predominantly new health care attor- (Tony Choe, Dan Kuninsky, Travis which mentors wanted to continue neys. Committee member Sarah Swank Lloyd, Jarrod Pearson, Ethan Rii, Sarah their involvement. Additionally, staff also wrote an article and the text for Swank, Kevin Wood, Maigan Wright, members worked to pair unmatched a new member and renewing member Craig Holden, and Jay Young, the mentees with mentors. Through these marketing piece. Program is stable and moving forward. efforts, we were able to achieve a lower This year the Committee and staff number of unmatched mentees. Online Portal/Platform Evaluation focused on several Program elements Committee member Jared Pearson requiring attention: outreach, mentor/ Practice Group Engagement reviewed the online mentoring portal, mentee maintenance (database cleanup), Committee members Jay Young, Travis and also looked at how new technology matching, AHLA Practice Group (PG) Lloyd, and Craig Holden formed a work solutions for mentor matching might engagement, training and tools, and group to set a goal of raising the visi- help the AHLA program. We are pleased an evaluation of the online portal and bility and participation in the Mentoring to report that a new vendor has been platform. Program among AHLA Practice Group selected for the Mentoring Program’s chairs, vice chairs, and related Affinity online home. It will operate on the same Outreach Group leaders and members. Informa- platform as the AHLA Communities At the 2014 Annual Meeting, the tion was provided on PG leadership discussion lists, and will use the same Committee established goals for the calls, PG and Affinity Group open login and password as AHLA’s website year. A primary goal was outreach, membership calls, and Practice Group (making the user experience that much particularly to new AHLA members, luncheons. Practice Group chairs were easier). Look for the new look in the law students, young professionals, and also encouraged to foster participation coming months. longtime AHLA members. As a starting in the Mentoring Program in their stra- point, Committee workgroup members tegic planning. Where is the Mentoring Program Maigan Wright and Kevin Wood, Now? along with AHLA staff, finalized a new Mentor and Mentee Training and AHLA’s Mentoring Program is a Mentoring brochure and Committee Tools continuing work in progress; we are members focused on outreach efforts, The need for additional mentor and poised to blossom significantly in the including networking receptions during mentee training and tools was exam- coming fiscal year with our improved AHLA’s Fundamentals of Health Law ined by a work group that included platform, enhanced features, and program (including the fun Mentoring Committee members Sarah Swank and updated marketing material. Our goal is “Bingo” game). The Mentoring Program Ethan Rii. They developed training to continue providing outreach to new was also showcased during Young and supporting materials to facilitate mentees and mentors through a variety Professionals’ networking receptions mentors’ and mentees’ understanding of of outlets, and to focus on the continued in Dallas and Philadelphia as well as at their respective roles and commitment, improvement of the Program as a signifi- several AHLA in-person programs. In and focused on the best mode of delivery cant benefit for AHLA members. AHLA Connections, regular columns for these resources, exploring in-person have both identified the benefits of programs, networking receptions, or mentorship and the need for additional other forums. This included a panel mentors to support the volume of new discussion held at the Fundamentals of lawyers joining the Program as mentees. Health Law program in November 2014,

18 AHLA Connections June 2015 Mentoring

AHLA Mentors FY15

Thank you to the many members who served as AHLA Mentors this past fiscal year. We appreciate your willingness to guide the next generation by sharing your experiences and expertise.

Sandra L. Adams, Signature HealthCARE LLC, Louisville, David S. Cade, American Health Lawyers Association, KY Washington, DC Timothy B. Adelman, LeClairRyan, Annapolis, MD Michael R. Callahan, Katten Muchin Rosenman LLP, Matthew Ewan Albers, Vorys Sater Seymour and Pease LLP, Chicago, IL Cleveland, OH Anthony H. Choe, Morgan Lewis & Bockius LLP, Cynthia A. Alcantara, University of Illinois, Chicago, IL Washington, DC Kelly R. Anderson, Baptist Healthcare System, Louisville, John R. Christiansen, Christiansen IT Law, Seattle, WA KY R. Gregory Cochran, Nossaman LLP, San Francisco, CA Andrea C. Barach, Baker Donelson Bearman Caldwell & Patrick S. Coffey, Whyte Hirschboeck Dudek SC, Chicago, Berkowitz PC, Nashville, TN IL Kalisa B. Barratt, Kalisa Barratt, Montague, MA Barney Ira Cohen, Barney Cohen Esquire, Chicago, IL Kelly Cavazos Barreto, Jackson Walker LLP, Austin, TX Emily Jane Cook, McDermott Will & Emery LLP, Los Troy A. Barsky, Crowell & Moring LLP, Washington, DC Angeles, CA Joi-lee K. Beachler, Polsinelli PC, Dallas, TX Michael H. Cook, Liles Parker PLLC, Washington, DC Scott Becker, McGuireWoods LLP, Chicago, IL Thomas W. Coons, OBER | KALER, Baltimore, MD Elisabeth Belmont, MaineHealth, Portland, ME Lois Dehls Cornell, Tufts Health Plan, Watertown, MA Katherine Benesch, Benesch & Associates LLC, Princeton, Margia K. Corner, Hogan Lovells LLP, Washington, DC NJ Thomas S. Crane, Mintz Levin Cohn Ferris Glovsky & Caroline J. Berdzik, Goldberg Segalla LLP, Princeton, NJ Popeo PC, Boston, MA Brian C. Betner, Hall Render Killian Heath & Lyman PC, Dawn R. Crumel, Shipman & Goodwin, Washington, DC Indianapolis, IN Maria Greco Danaher, Ogletree Deakins, Pittsburgh, PA Deborah Biggs, University of Wisconsin School of Medicine Anthea R. Daniels, Baker Donelson Bearman Caldwell & and Public Health, Madison, WI Berkowitz PC, Cleveland, OH Ann M. Bittinger, The Bittinger Law Firm, Jacksonville, FL Afsheen Davis, Texas Children’s Hospital, Houston, TX Barbara Blackmond, Horty Springer & Mattern PC, Nancy A. Dean, Nancy Dean, Rahway, NJ Pittsburgh, PA Gerald E. DeLoss, Clark Hill PLC, Chicago, IL Ryan P. Blaney, Cozen O’Connor PC, Washington, DC Paul R. DeMuro, Broad and Cassel, Fort Lauderdale, FL Alan David Bloom, Care1st Health Plan, Monterey Park, Robyn Whipple Diaz, Memphis, TN CA Thomas E. Dowdell, Norton Rose Fulbright, Washington, Philip M. Bluestein, Bluestein Law Firm PC, Boulder, CO DC Mark A. Bonanno, Law Offices of Mark Bonanno LLC, Erich Andreas Drotleff, Sutherland Healthcare Solutions, Portland, OR Pittsford, NY Annemarie Boyan, Childrens Hospital of Philadelphia, Barbara J. Duffy, Lane Powell PC, Seattle, WA Philadelphia, PA Todd M. Ebersole, OptumRx a UnitedHealth Group Bonnie S. Brier, NYU Office of General Counsel, New York, Company, Irvine, CA NY Deborah Feder, Kansas City, MO Richard J. Brockman, Burr & Forman LLP, Birmingham, AL Robert H. Feinberg, Snell & Wilmer LLP, Phoenix, AZ Ardith M. Bronson, DLA Piper LLP (US), Miami, FL Michael Felsen, Albany, GA Starr J. Brown, Starr Brown, New York, NY Andrea M. Ferrari, HealthCare Appraisers Inc, Delray Beach, FL James H.K. Bruner, Tallahassee, FL healthlawyers.org B1 Mentoring

Robin J. Fisk, Fisk Law Office, Ashland, NH Thomas R. Hoffman, American College of Radiology, Edward Michael Flanagan, The Law Offices of E. Michael Reston, VA Flannigan, Washington, DC Elizabeth E. Hogue, Elizabeth E. Hogue LLC, Washington, Thomas C. Fox, Reed Smith LLP, Washington, DC DC William M. Freedman, Dinsmore & Shohl LLP, Cincinnati, S. Craig Holden, OBER | KALER, Baltimore, MD OH Robert G. Homchick, Davis Wright Tremaine LLP, Seattle, Melesa A. Freerks, Foley & Lardner LLP, Chicago, IL WA Karen Gallinari, Bronx Lebanon, Bronx, NY Joanne P. Hopkins, Law Office of Joanne P Hopkins, Austin, TX Robert A. Gerberry, Summa Health System, Akron, OH Alvis Lee Horne, Winter Park, FL Sarah Gettings, Manatt Phelps & Phillips LLP, Los Angeles, CA William W. Horton, Jones Walker LLP, Birmingham, AL Enami Yasui Gilbert, Springfield, MO Renee M. Howard, Perkins Coie LLP, Seattle, WA Roy Francis Gilbert, Green Bay, WI Dennis Hursh, Hursh & Hursh PC, Middletown, PA Paul A. Gillan, Wilson Elser, Albany, NY Thomas K. Hyatt, Dentons US LLP, Washington, DC Alexis S. Gilroy, Jones Day, Washington, DC Jennifer Wooten Ierardi, Northwestern Memorial HealthCare, Chicago, IL Karen Glickstein, Polsinelli PC, Kansas City, MO William P. Isele, Archer & Greiner PC, Princeton, NJ Edward B. Goldman, University of Michigan, Ann Arbor, MI Michael J. Jackonis, Michael Jackonis, Gaithersburg, MD Marc D. Goldstone, Community Health Systems Professional Services Corporation, Franklin, TN Michelle D. Johnson, The Cleveland Clinic Foundation, Beachwood, OH Maria E. Gonzalez-Knavel, Foley & Lardner LLP, Milwaukee, WI Samantha Johnson, Grady Health System, Atlanta, GA Jill H. Gordon, Nixon Peabody LLP, Los Angeles, CA Jody E. Joiner, Integris Health Inc, Oklahoma City, OK Brian D. Gradle, Bon Secours Health System Inc, Emily B. Jordan, Affinity Health Plan, Bronx, NY Richmond, VA Jeffrey D. Kahn, The Children’s Hospital of Philadelphia, Emily Black Grey, Breazeale Sachse & Wilson LLP, Baton Philadelphia, PA Rouge, LA Jeffrey L. Kapp, Jones Day, Cleveland, OH J. Michael Grubbs, Barnes & Thornburg LLP, Indianapolis, Julie E. Kass, OBER | KALER, Baltimore, MD IN Francine Halushka Katz, Saint Josephs Healthcare System, Robert Guenthner, National Surgical Hospitals Inc, Paterson, NJ Chicago, IL Jamie Katz, Beth Israel Deaconess Medical Center, Boston, Claire Cowart Haltom, Baker Donelson, Nashville, TN MA Rachel Hammond, NJ Department of Health, Trenton, NJ Margaret A. Keavney, Monmouth Ocean Hospital Service David L. Haron, Foley & Mansfield, Ferndale, MI Corp, Wall Township, NJ Jacob Harper, Morgan Lewis & Bockius LLP, Washington, James M. Kessler, Health New England Inc, Springfield, MA DC Sarah Kessler, DHHS Office of the Inspector General, Lisa A. Hathaway, Blue Cross Blue Shield of Florida, Washington, DC Jacksonville, FL Geralyn A. Kidera, Regency-Pacific Management, Bellevue, Jennifer R. Henderson, Driscoll Children’s Hospital, WA Corpus Christi, TX Cavender C. Kimble, Balch & Bingham LLP, Birmingham, Gary W. Herschman, Epstein Becker & Green PC, Newark, AL NJ Spencer R. Knapp, University of Vermont Health Network, Kathryn E. Hickner, Ulmer & Berne LLP, Cleveland, OH Burlington, VT Tizgel K. S. High, LifePoint Health Inc, Brentwood, TN Martha Ann Knutson, San Diego, CA Jennifer L. Hilliard, LeadingAge, Washington, DC Chris Koepsel, Imaging Advantage LLC, Santa Monica, CA Rick L. Hindmand, McDonald Hopkins LLC, Chicago, IL Jana Kolarik Anderson, Foley & Lardner LLP, Jacksonville, FL

B2 AHLA Connections June 2015 Mentoring

Amy J. Kolczak, University of Colorado Health, Fort Andrew N. Meyercord, Gray Reed & McGraw PC, Dallas, TX Collins, CO Joline Miceli-Mullen, The Children’s Hospital of Mark S. Kopson, Plunkett Cooney PC, Bloomfield Hills, MI Philadelphia, Philadelphia, PA Richard G. Korman, Avera Health, Sioux Falls, SD Teresa Mikan, McLaren Health Plan, Flint, MI Dan Kuninsky, Bass Berry & Sims PLC, Nashville, TN John J. Miles, OBER | KALER, Washington, DC Laura F. Laemmle-Weidenfeld, Jones Day, Washington, DC Barbara L. Miltenberger, Husch Blackwell LLP, Jefferson Marilyn Lamar, Liss & Lamar PC, Oak Brook, IL City, MO Kevin Sean Lawlor, Altius Health Plans, South Jordan, UT Julie Bowman Mitchell, Mitchell Day Health Law Firm, Ridgeland, MS Simonne Lawrence, Envision Pharmaceutical Holdings LLC, Fort Lauderdale, FL Valerie B. Montague, Nixon Peabody LLP, Chicago, IL Jody Lehman, Florida International University - Herbert Nathan Mubasher, Law Offices of Nathan Mubasher, Wertheim College of Medicine, Miami, FL Corona, CA Robert F. Leibenluft, Hogan Lovells LLP, Washington, DC Erin L. Muellenberg, Arent Fox LLP, Los Angeles, CA Peter M. Leibold, Ascension Health, Washington, DC Dinetia M. Newman, Bradley Arant Boult Cummings LLP, Jackson, MS Natalie Maclean Leino, Tufts Health Plan, Watertown, MA Robert R. Niccolini, Ogletree Deakins, Washington, DC Arthur N. Lerner, Crowell & Moring LLP, Washington, DC Shelley Catherine Nordling, Healthcare Service David T. Lewis, Miller & Martin PLLC, Nashville, TN Corporation, Chicago, IL Jennifer Lundgren Lewis-David, United Healthcare, Rachel Nosowsky, University of California, Oakland, CA Columbia, MD Gerard M. Nussbaum, Kurt Salmon, Chicago, IL Travis Grainger Lloyd, Bradley Arant Boult Cummings LLP, Nashville, TN Ariana Ornelas Smyth, Allegheny Health Network, Pittsburgh, PA Christie A. Lohkamp, Mayo Clinic, Rochester, MN Stephen L. Page, RegionalCare Hospital Partners Inc, Kim Harvey Looney, Waller Lansden Dortch & Davis LLP, Brentwood, TN Nashville, TN Karen R. Palmersheim, Cigna, Pasadena, CA Karen Stephanie Lovitch, Mintz Levin Cohn Ferris Glovsky & Popeo PC, Washington, DC Lawson S. Parker, Husch Blackwell LLP, Denver, CO Charles A. Luband, New York, NY Anjana D. Patel, Epstein Becker & Green PC, Newark, NJ Grace D. Mack, Wilentz Goldman & Spitzer PA, Michael E. Paulhus, King & Spalding LLP, Atlanta, GA Woodbridge, NJ Peter A. Pavarini, Squire Patton Boggs, Columbus, OH Erin F. MacLean, Freeman & MacLean PC, Helena, MT Jarrod W. Pearson, DaVita HealthCare Partners Inc, Jay T. Manire, Siemens Healthcare, Knoxville, TN Denver, CO Ari J. Markenson, DuaneMorris LLP, New York, NY Jeffrey M. Pecore, Pecore & Doherty LLC, Columbia, MD Melissa L. Markey, Hall Render Killian Heath & Lyman PC, Jan M. Pederson, Maggio Kattar, Washington, DC Troy, MI Gerald R. Peters, Latham & Watkins LLP, San Francisco, William H. Maruca, Fox Rothschild LLP, Pittsburgh, PA CA William T. Mathias, OBER | KALER, Baltimore, MD Mark W. Peters, Waller Lansden Dortch & Davis LLP, Nashville, TN Caitlin Suzanne McCormick, Akin Gump Strauss Hauer & Feld LLP, Washington, DC Rebekah N. Plowman, Jones Day, Atlanta, GA Charlene L. McGinty, McKenna Long & Aldridge LLP, Dorthula H. Powell-Woodson, Wiley Rein LLP, Atlanta, GA Washington, DC Alanna McKiernan, Kaiser Permanente, Oakland, CA Elizabeth Anne Prokopik, Pharmakon Long Term Care Pharmacy Inc, Carmel, IN Catherine M. McKnight, Dentons US LLP, Dallas, TX Christopher C. Puri, Bradley Arant Boult Cummings LLP, Marshall P. Meringola, Strasburger & Price LLP, Austin, TX Nashville, TN Scott R. Mertie, Kraft Healthcare Consulting LLC, Greg S. Radinsky, North Shore Long Island Jewish Health Nashville, TN System, Great Neck, NY Carolyn Victoria Metnick, Akerman LLP, Chicago, IL

healthlawyers.org B3 Mentoring

Liston Eudon Radney, BayCare Health System, Clearwater, Toby G. Singer, Jones Day, Washington, DC FL Howard L. Sollins, OBER | KALER, Baltimore, MD Katea M. Ravega, Quarles & Brady LLP, Phoenix, AZ Matthew Soskins, , Escondido, CA Emilie Rayman, Community Memorial Health System, Patrick D. Souter, Gray Reed & McGraw PC, Dallas, TX Ventura, CA Gelvina Rodriguez Stevenson, The Children’s Hospital of Cynthia Y. Reisz, Bass Berry & Sims PLC, Nashville, TN Philadelphia, Philadelphia, PA Mary Holloway Richard, Phillips Murrah PC, Oklahoma Brian Richard Stimson, Alston & Bird LLP, Atlanta, GA City, OK Sarah E. Swank, Dignity Health, Pasadena, CA Ethan E. Rii, Katten Muchin Rosenman LLP, Chicago, IL Ann Marie Carr Swindler, Carilion Clinic, Roanoke, VA William J. Roberts, Shipman & Goodwin LLP, Hartford, CT Michele Hartmann Tamene, AxelaCare, Lenexa, KS Vicki L. Robinson, Office of the Inspector General, US Sanford V. Teplitzky, OBER | KALER, Baltimore, MD Department of Health & Human Services, Washington, Harvey M. Tettlebaum, Husch Blackwell LLP, Jefferson DC City, MO Taunia D. Rogers, Taunia Davis Rogers, Moscow Mills, MO Shan K. Thever, Shan Thever & Associates, Los Angeles, CA George L. Root, Procopio Cory Hargreaves & Savitch LLP, Andrea Timashenka, Department of Health and Human San Diego, CA Services, Silver Spring, MD Douglas C. Ross, Davis Wright Tremaine LLP, Seattle, WA Robert J. Tomaso, Husch Blackwell LLP, Saint Louis, MO Joseph R. Ross, Morris Manning & Martin LLP, Savannah, James L. Touse, DST Health Solutions LLC, Birmingham, GA AL Brad M. Rostolsky, Reed Smith LLP, Philadelphia, PA Joseph V. Truhe, Goodlettsville, TN Beth L. Rubin, Ambler, PA Sylvia J. Trujillo, American Medical Association, Andrew D. Ruskin, Morgan Lewis & Bockius LLP, Washington, DC Washington, DC Davis W. Turner, Capella Healthcare Inc, Franklin, TN Amita Sanghvi, Powers Pyles Sutter & Verville PC, Mathew Varughese, Yale University, New Haven, CT Washington, DC Ariadna Vazquez, University of New Mexico, Albuquerque, Janine Sarti, Palomar Health, Escondido, CA NM Paul J. Savidge, New Hope, PA John R. Voigt, Sherrard & Roe PLC, Nashville, TN Karen McKeithen Schaede, Connors Morgan PLLC, Brigitte P. Volochinsky, CarePoint Health, Jersey City, NJ Greensboro, NC Judith A. Waltz, Foley & Lardner LLP, San Francisco, CA Michael F. Schaff, Wilentz Goldman & Spitzer PA, Woodbridge, NJ J. Scott Waters, Waters Tyler Hofmann & Scott LLC, New Albany, IN Laura B. Schmidt, Amerigroup Corp, Virginia Beach, VA Diane Mary Welsh, von Briesen & Roper SC, Madison, WI Bryan A. Schneider, Chicago, IL Matthew E. Wetzel, Home, Minneapolis, MN Jack S. Schroder, Alston & Bird LLP, Big Canoe, GA Emily Wey, Polsinelli PC, Denver, CO Asha B. Scielzo, Pillsbury Winthrop Shaw Pittman LLP, Washington, DC Monica N. Wharton, Regional Medical Center at Memphis, Memphis, TN Cynthia L. Sehr, Phoenix Children’s Hospital, Phoenix, AZ Jennifer Neyan Willcox, Yale New Haven Health System, Anne P. Sharamitaro, Bryan Cave LLP, Saint Loius, MO New Haven, CT Alexander D. Sharnoff, AtlantiCare Health System, Egg Teresa A. Williams, Integris Health, Oklahoma City, OK Harbor Township, NJ Cynthia F. Wisner, Trinity Health, Livonia, MI Annie Hsu Shieh, Central Health Plan of California, Diamond Bar, CA Kevin M. Wood, Strasburger & Price LLP, Austin, TX Aileen Shinaman, University of Rochester, Rochester, NY James C. Young, Law Offices of Sheryl Story, Metairie, LA Thomas N. Shorter, Godfrey & Kahn SC, Madison, WI Heather M. Zimmerman, Walgreens Co, Deerfield, IL Martin H. Sinclair, Essentia Health, Duluth, MN

B4 AHLA Connections June 2015 Forward Thinking Healthcare Solutions It’s What We Do

HEALTHCARE LAW

Joan W. Feldman, Health Law Practice Group Chair [email protected] www.shipmangoodwin.com/health_law | @sghealthlaw

Facebook “f” Logo CMYK / .eps Facebook “f” Logo CMYK / .eps HARTFORD | STAMFORD | GREENWICH | WASHINGTON, DC Fiduciary Duties of Officers and Directors of Financially Distressed Nonprofit Hospitals

By Jay Bender, Bradley Arant Boult Cummings LLP, West Memphis, AR, North Adams Regional Hospital in North Birmingham, AL, and John B. “Jay” Hardcastle, Bradley Adams, MA, and Nicholas County Hospital in Carlisle, KY. Health care executives and industry experts alike see no Arant Boult Cummings LLP, Nashville, TN immediate relief in sight. A recent survey of hospital CEOs identified “financial challenges” as their top concern for 2015.1 Changes in the health care marketplace and uncertainties Each of the three largest ratings agencies—Fitch, Moody’s, and regarding the implementation and future of the Affordable S&P—issued negative forecasts for the not-for-profit health Care Act (ACA) have placed tremendous strain on not-for- care industry for 2015. Matters soon could get worse, espe- profit hospitals and health systems. The pressures affect both cially if interest rates increase or if the Supreme Court’s ruling sides of the ledger, as nonprofits struggle to maintain revenues, in the King v. Burwell2 case currently pending before the Court to contain costs, and to stay above water. adversely impacts the federal insurance exchanges created by Officers and directors of these financially distressed the ACA. nonprofits face a difficult role. As officers and directors, they generally owe fiduciary duties to their nonprofit organiza- The Sources of Distress tion and its charitable mission. However, if the nonprofit is Among the factors contributing to nonprofits’ problems are: or may be insolvent, uncertainty arises as to whether and to what extent those fiduciary duties may be altered. In the past, Declining patient volumes those questions were answered with references to terms such The general decline in demand for hospital services has as “zone of insolvency” and “shifting duties”—advice that depressed hospital revenues. Reduced patient volumes are provided little guidance about how to make decisions for their attributable to numerous factors, including increased compe- struggling corporations. tition from alternative models of care such as urgent care Over the past several years, the law in this area has devel- centers, stand-alone emergency departments, outpatient oped, moving away from the “zones” and “shifts” of yore and surgery centers, and home care and long term acute care towards a framework that better defines officers’ and directors’ providers. The Medicare program’s emphasis on reducing duties and defers to their reasonable business judgment, even patient readmissions, its “two-midnight rule,” and its value- when their corporations are insolvent. based compensation reforms all encourage care outside of the Nonprofits and their Current Challenges hospital environment, exerting additional downward pressures on hospital revenues. Higher deductible insurance plans are Stories of financially distressed not-for-profit hospitals causing individuals to evaluate the costs of their health care are increasingly common. In California, the Daughters of options more closely than ever before. Many nonprofits, espe- Charity Health System, which operates six hospitals in the cially rural hospitals, cannot afford the specialty services their Bay Area and Los Angeles County, and Doctors Medical community seeks, driving that demand and those revenues Center, a community-owned safety-net hospital in San Pablo, elsewhere. are engaged in ongoing, well-publicized efforts to sustain their operations through going-concern sales or increased Increased operating costs community support. In Georgia, Hutcheson Medical Center, The ACA’s electronic health record (EHR) meaningful-use a nonprofit hospital in Oglethorpe, filed for chapter 11 criteria have required many nonprofits to invest in expensive bankruptcy late last year to stave off foreclosure attempts by information systems upgrades, and the shift from cost-based one of its creditors. Hutcheson continues to operate while it reimbursement to a value-based compensation model is pursues its exit from chapter 11. Other nonprofit hospitals have imposing new tracking and reporting obligations on providers. suffered worse fates. Among those hospitals that have closed To remain competitive, nonprofits must invest in upgrades their doors this past year are Crittenden Regional Hospital in

20 AHLA Connections June 2015 to their aging equipment and facilities and in recruiting and Under the latest iteration retaining physicians, especially those in key specialties. For some nonprofits, above-market collective bargaining agree- of the Model Nonprofit ments and unfunded pension obligations may further strain Corporation Act, the duty of their coffers. care requires a director of a The move from cost-based to value-based government nonprofit to perform his or compensation Many nonprofits serve high percentages of Medicare and her duties as a director in Medicaid patients and, thus, rely on government payments good faith and in a manner for the disproportionate bulk of their revenues. In the past, hospitals were paid for services provided to these patients the director reasonably through traditional fee-for-service reimbursements. The ACA, believes to be in the best however, has shifted the basic payment structure away from interests of the nonprofit fee-for-service reimbursement to a value-based payment model that bases compensation increasingly on the quality of care a corporation. hospital provides and the outcomes its patients realize, and not on the services provided. Under programs such as Medicare’s Value-Based Purchasing (VBP) and CMS’ Hospital Readmis- ACA. Earlier this year, the Court heard arguments in King sions Reduction Program (HRRP), payments to hospitals that v. Burwell, which questions the legality of federal subsidies fail to reach specified benchmarks tied to quality of care and provided to individuals who enroll for insurance through patient outcomes are at risk. Nonprofit hospitals stand to be federally-run insurance exchanges. An adverse ruling could disproportionately affected by these changes, with at least one block federally-run insurance exchanges from providing subsi- study showing that safety-net hospitals—the majority of which dies to individuals in at least 34 states that have not adopted are nonprofits—are more likely than other hospitals to be their own state-operated exchanges. Without such subsidies, penalized under the VBP program and the HRRP.3 some experts estimate that insurance premiums sold on the Meanwhile, federal programs that provided additional federal exchanges could increase by an average of 255% and, support to many nonprofits, such as Medicaid’s Dispropor- in some states, by as much as 774%, with approximately 7.5 tionate Share Hospital (DSH) program and Medicare’s critical million individuals potentially affected.7 If premiums increase, access hospital (CAH) designation entitling certain hospitals more people will qualify for a hardship exemption from the to receive cost-based rather than standard fixed rate reim- ACA’s individual insurance mandate, relieving them from bursements, have been rolled back. The cuts in these programs their current obligation to secure health coverage. This poten- were done with the expectation the ACA would generate addi- tial increase in uninsured individuals would cause health care tional revenues that would help defray the cutbacks in these providers to lose yet another source of revenues they antici- programs. However, that expectation has not yet been realized. pated receiving when the ACA was passed.

Intended and unintended consequences of the ACA The Duties of Nonprofit Officers and Directors When the ACA was enacted, one of its central features was Fiduciary Duties with respect to Solvent Nonprofits its mandate that each state must expand Medicaid eligibility Nonprofit officers and directors owe fiduciary duties to the within their borders as a condition to the state’s receipt of nonprofit they serve. Those duties include a duty of care federal matching funds. With Medicaid expansion mandated, and a duty of loyalty. Under the latest iteration of the Model the amount of uncompensated care provided by hospitals was Nonprofit Corporation Act,8 the duty of care requires a expected to decrease markedly. That expectation has not been director of a nonprofit to perform his or her duties as a director realized, however, due to the Supreme Court’s invalidation of in good faith and in a manner the director reasonably believes 4 the ACA’s mandatory Medicaid expansion provisions in 2012. to be in the best interests of the nonprofit corporation.9 When With expansion optional for each state rather than mandatory, becoming informed in connection with a decision-making only 28 states and the District of Columbia have expanded function or devoting attention to an oversight function, a 5 their Medicaid programs since the ACA’s enactment. In those director must discharge his or her duties with the care that 22 states that have not opted to expand Medicaid, many health a person in a like position would reasonably believe appro- care providers have been particularly hard hit by both the loss priate under similar circumstances. The duty of care generally of the DSH payments they previously received and the unreal- permits a director, in discharging his or her duties, to rely ized increase in revenues that Medicaid expansion promised. on information prepared or presented by officers, employees, Evidencing that impact is the change in bad debt rates in those or volunteers of the nonprofit, legal counsel, public accoun- states that did and did not expand their Medicaid programs, tants, committees of the board, and, in the case of a nonprofit with median bad debt down by 5.6% through 2014 in those engaged in religious activity, religious authorities, provided states (including the District of Columbia) that expanded those sources are believed to be reliable and competent and Medicaid eligibility, and bad debt up by 6.8% during the same provided that the director not have knowledge that makes 6 period in those states electing not to expand. reliance unwarranted. A director’s duty of loyalty arises out of Nonprofit and for-profit providers alike are concerned the mandate that directors act in good faith and in a manner about another looming Supreme Court decision regarding the the director reasonably believes to be in the best interests of

healthlawyers.org 21 the nonprofit corporation,10 and generally requires directors to The New Line of Cases act in a manner that promotes the interests of the corporation Over the past several years, a new line of Delaware decisions— and not their own. In the nonprofit context, the duty of loyalty the most recent being the Quadrant opinion last year—has includes a duty of obedience to the corporation’s charitable broken from the old “zone of insolvency” and “shifting duties” mission, compelling them to act in a manner they reasonable cases in many material respects.15 First, these cases reject believe will further such mission.11 the notion that directors of insolvent corporations ever owe As for officers, the Model Act requires each officer with fiduciary duties directly to creditors. Rather, the fiduciary discretionary authority to discharge his or her duties: (1) in duties of officers and directors always run to their corporation. good faith, (2) with the care an ordinarily prudent person in a While the beneficiaries of those duties may shift, the duties like position would exercise under similar circumstances, and themselves do not “shift” back and forth between shareholders (3) in a manner the officer reasonably believes to be in the best and creditors depending upon their balance sheet. Second, the interests of the nonprofit.12 An officer also has a duty to inform Delaware courts now deem irrelevant whether a corporation is his or her superior officer, another appropriate person, or in the amorphous “zone of insolvency.” A corporation’s actual the directors, of material information about the affairs of the insolvency—not just the prospect of it—is relevant, as a corpo- nonprofit known to the officer with the scope of the officer’s ration’s demonstrated insolvency will provide its creditors functions, or of any actual or probable material violation of with standing to maintain derivative claims on the company’s law involving the nonprofit or material breach of a duty owed behalf against directors for breaches of fiduciary duties. by another person to the nonprofit that he or she believes has Finally, this newer line of Delaware opinions recognizes occurred or is likely to occur. Like directors, in discharging that an insolvent corporation’s officers and directors are their duties, officers may rely on information prepared or not compelled by the corporation’s insolvency to reflexively presented by certain other people affiliated with the nonprofit, pursue liquidation or to forego business opportunities that, provided those sources are believed to be reliable and compe- in the board’s properly-exercised business judgment, might tent and provided that the officer not have knowledge that enhance the enterprise’s value despite entailing some risk to makes reliance unwarranted. the company’s creditors. In Quadrant, for example, the court dismissed derivative claims brought by senior creditors of Fiduciary Duties with respect to Insolvent Nonprofits the bankrupt company against its directors. The creditors’ For decades, courts and legal scholars have wrestled with derivative claims alleged the directors breached their fiduciary whether and how the fiduciary duties of officers and directors duties by adopting a new, but riskier, investment strategy for may change when their corporation is or may be insolvent. In the insolvent company rather than pursuing liquidation. The Delaware – the state in which many corporations are formed senior creditors asserted that the directors pursued the more – and other jurisdictions, a line of case law developed holding speculative course of action solely for the benefit of the junior that, when a for-profit company became insolvent or entered debt and equity holders, with which many of the directors were the “zone of insolvency,” the fiduciary duties of the company’s affiliated. The Quadrant court found that the board’s decision directors “shifted” to include the company’s creditors such to pursue the riskier, but potentially more lucrative, business that the board members owed fiduciary duties directly to strategy was protected by the business judgment rule, and that those creditors.13 The reasoning underlying these opinions was the plaintiffs failed to rebut the business judgment rule simply that, when a for-profit corporation became insolvent or close by alleging that the directors pursued that strategy to benefit to insolvent, the company’s creditors were the stakeholders the equity owners and junior debt holders with which they who truly stood to gain or lose from the decisions made by the were related. company’s leaders since shareholders were no longer “in the No court has explicitly extended the rulings in Quadrant money.” and its predecessor cases—all of which involved for-profit Extrapolating from these cases, courts and commenta- companies—to a case involving an insolvent nonprofit corpo- tors concluded that the same result should apply with respect ration. However, the basic holding in Quadrant—that directors to officers and directors of insolvent not-for-profits that were of insolvent companies are not compelled to make decisions to in the “zone of insolvency” and that they, too, owed fiduciary pursue actions solely for the benefit of creditors and to forego duties to creditors of their insolvent or potentially insolvent opportunities that reasonably might further the corpora- company.14 These conclusions were reached without much tion’s underlying objectives (enhancing corporate value, for discussion or analysis, even though the reasoning underlying a for-profit company)—should apply equally to not-for-profit the for-profit fiduciary duty opinions—i.e., that creditors of enterprises. Nonprofits should not be compelled to pursue an insolvent for-profit are the de facto shareholders of the liquidation simply by virtue of their insolvency if the board company—was clearly not analogous to nonprofits that, by concludes, in its reasonable business judgment, that other definition, have no shareholders. Moreover, the analogy failed business opportunities should be pursued that will further the to account for a nonprofit’s obligation to maintain and pursue company’s charitable mission. its charitable mission as a condition to its tax-exempt status, Though predating Quadrant and its line of cases, an a condition which may be jeopardized if a nonprofit’s leader- opinion out of the United Healthcare System16 bankruptcy case ship was compelled to put the interests of its creditors ahead advanced such a position. In United Healthcare, the directors of furthering that mission. While the concept of “owing” of a nonprofit hospital, after a thorough marketing process of fiduciary duties to creditors was problematic in the for-profit the hospital’s assets, accepted a purchase offer that was not the context, it was simply untenable when extended to nonprofit highest one received. Instead, the board, after conferring with entities. financial advisors and state regulators, accepted as “better” a

22 AHLA Connections June 2015 bid made by a party that promised to keep the hospital in its current location and to make substantial future investments in Recent opinions show that the facility. The bankruptcy court disagreed with the board’s officers and directors of an rejection of the higher offer and vacated the sale to the lower insolvent company—including bidder. The appellate court, however, overturned the bank- ruptcy court’s decision, finding the nonprofit board’s accep- nonprofit hospitals and tance of the lower, but better, bid to be consistent with their health systems—can satisfy “fiduciary obligation to act in furtherance of the organization’s charitable mission.”17 their fiduciary duties by Like Quadrant, the United Healthcare case supports making informed, reasonable strongly the view that the reasonable and informed exercise of business judgment by a board of directors, whether of a judgments and acting for-profit or nonprofit entity, should be accorded great judicial deliberately with the interests deference even when the company is insolvent. A recent Third Circuit opinion, on the other hand, shows how severe the of the company at the core, consequences can be when nonprofit directors breach their even if those decisions and duties of care and loyalty and fail miserably to exercise reason- able business judgment. 18 actions will not necessarily That case involved The Lemington Home for the Aged assure the highest or most (the Home), a nonprofit nursing home with a long history of financial and operational problems. The Home filed for bank- certain recovery to the ruptcy in April 2005, three months after the Home’s board company’s creditors. of directors had voted to close the Home due to its financial difficulties and general eroding condition. In the intervening period, the Home’s census dropped, and it continued to incur Administrator, $750,000 against the CFO, and $350,000 indi- debt without disclosing its bankruptcy plans to creditors. In vidually against five of the director-defendants. On appeal, the the years preceding the board’s bankruptcy vote, the Home Third Circuit affirmed all of the jury verdicts, with the excep- was repeatedly cited for deficiencies at an exceptionally high tion of the punitive damages verdict against the five directors. rate, failed to maintain patient records adequately, did not The Third Circuit found there was ample evidence to find consistently maintain a general ledger, and mismanaged its that the Administrator and the CFO had each breached their billing operations, resulting in the loss of upwards of $500,000 duties of care and loyalty and that the director-defendants in Medicare payments. The Home’s Administrator and CEO had breached their duty of care. However, the court found no served for over 17 years in her position, despite the Home’s evidence that the directors had breached their duty of loyalty. dismal financial and operational history during her tenure, The absence of any evidence of self-dealing by the directors, reports from government inspectors stating that she lacked the Third Circuit ruled, weighed heavily against assessing the qualifications to serve in her position, and her collecting a punitive damages against them. full-time salary even after moving to part-time status—a move that violated state law which required the Home to maintain a Conclusion full-time administrator. In addition to neglecting the Home’s Nonprofit officers and directors may be tempted to disre- financial and billing operations, the Home’s Chief Financial gard Lemington based on the egregious set of facts it pres- Officer (CFO) failed to timely generate financial reports and ents. That would be a mistake. At its core, Lemington is an refused to meet with key creditors’ representatives while the extreme example of a rather common fact pattern seen when a Home was in bankruptcy. As for the board, it failed to properly company is financially and operationally distressed. Manage- supervise and timely remove the Administrator and CFO ment, fearful for the loss of their jobs and overwhelmed by once their mismanagement became apparent (even though the the situation, fails to communicate timely and fully to their board had sought and obtained a grant to fund the search for a supervisors and their board the full extent of the company’s new Administrator), did not meet regularly or maintain appro- problems. Directors, assuming that “no news is good news,” priate minutes of board minutes, consciously deferred filing preoccupied with their own full-time jobs or activities, and for bankruptcy and depleted the patient census, and failed to likely inexperienced with distressed situations, remain disen- establish a reasonable sale process for the Home either before gaged from the situation or, if and when engaged, do not act or after bankruptcy. swiftly or decisively to address the nonprofit’s problems. The Against this backdrop, the official committee of creditors disengagement of directors can be a particular problem with in the Home’s bankruptcy case sought, and obtained, authori- nonprofits, especially if the nonprofit or the directors them- zation from the bankruptcy court to pursue derivative claims selves have historically viewed board membership as more of on the Home’s behalf against the two officers and the Home’s an honorary position than one entailing serious oversight and directors. A jury returned a compensatory damages verdict decision-making responsibility. against 15 of the 17 defendants, jointly and severally, in the The holdings in the recent Delaware line of cases and in amount of $2.25 million for, among other things, breaching United Healthcare stand in stark contrast to Lemington. Those their fiduciary duties to the Home. The jury also awarded opinions show that officers and directors of an insolvent punitive damages in the amounts of $1 million against the company—including nonprofit hospitals and health systems—

healthlawyers.org 23 can satisfy their fiduciary duties by making informed, reason- Endnotes able judgments and acting deliberately with the interests of the 1 Healthcare Finance, Reform Top Issues Confronting Hospitals in 2014, company at the core, even if those decisions and actions will American College of Healthcare Executives, January 12, 2015, available at www.ache.org/PUBS/research/ceoissues.cfm. not necessarily assure the highest or most certain recovery 2 King v. Burwell, 759 F.3d 358 (4th Cir.), cert. granted, 135 S. Ct. 475 (2014). to the company’s creditors. To be properly informed, regular 3 Matlin Gilman, et al., California Safety-Net Hospitals Likely to be Penalized board meetings must be had and management reports by ACA Value, Readmission, and Meaningful-Use Programs, Health Affairs (Aug. 2014), at 1314. made. Outside counsel, accountants, and advisors should be 4 Nat’l Fed’n of Indep. Bus. v. Sebelius, 132 S. Ct. 2566 (2012). consulted when questions arise that cannot be adequately 5 Where the states stand on Medicaid expansion, The Advisory Board addressed in-house or to help identify options available to the Company, Feb. 11, 2015, www.advisory.com/daily-briefing/resources/ nonprofit to address its financial position, including merger primers/medicaidmap. 6 Moody’s Investors Service, Moody’s: Outlook for US Not for Profit and sale options, affiliation agreements, chapter 11 bank- Healthcare Remains Negative, Dec. 2, 2014, https://www.moodys.com/ ruptcy, or closure and liquidation. Inaction is not acceptable. research/Moodys-Outlook-for-US-Not-for-Profit-Healthcare-Remains- As the jury in Lemington aptly concluded, the incompetence, Negative--PR_314203. disengagement, and indecision of a company’s management 7 Caroline F. Pearson, Avalere Observations: Impact of King v. Burwell & Potential Fixes, March 4, 2015, http://avalere.com/expertise/managed-care/ team and board are indefensible, at any time, and especially insights/avalere-observations-impact-of-king-v.-burwell-potential-fixes/ when that company is insolvent. print. 8 Model Nonprofit Corporation Act, Third Edition (American Bar Association, About the Authors Section on Business Law, Committee on Nonprofit Corporations, 2008) (Model Act). 9 Model Act, § 8.30. Jay Hardcastle ([email protected]) 10 See Michael W. Peregrine, James R. Schwartz, James E. Burgdorfer, and serves as Co-Chair of the Healthcare Practice David C. Gordon, The Fiduciary Duties of Healthcare Directors in the “Zone of Insolvency,” J. of Health Law (Spring 2002), available at https://www. Group at Bradley Arant Boult Cummings LLP healthlawyers.org/Publications/Journal/Documents/2002/April%202002/ in Nashville, TN. He advises clients in the The%20Fiduciary%20Duties%20of%20Healthcare%20Directors%20in%20 health care industry on joint venture forma- the%20Zone%20of%20Insolvency%20[JHL,%20April%202002].pdf tion, general regulatory issues, corporate 11 Id. 12 Model Act, § 8.42. matters, and the purchase and sale of facili- 13 See Bovay v. H.M. Byllesby & Co., 38 A.2d 808 (Del. 1944); Credit-Lyonnais ties. He especially enjoys solving difficult problems in complex Bank Nederland, N.V. v. Pathe Commc’ns Corp., 17 Del. J. Corp. L. 1099, transactions and in the joint venture context. 1055 n.55, 1991 WL 277613 (Del. Ch. Dec. 30, 1991). 14 See, e.g., In re Lemington Home for the Aged, 659 F.3d 282, 290 (3rd Cir. 2011)(citing Citicorp Venture Capital, Ltd. v. Comm. of Creditors Holding Jay Bender ([email protected]) serves as Unsecured Claims, 160 F.3d 982, 987-88 (3rd Cir. 1998) (in case involving Co-Chair of Bradley Arant Boult Cummings a nonprofit, the court cited a case involving a for-profit corporation case as LLP Bankruptcy, Restructuring, and authority for finding that officers and directors of insolvent nonprofit owed fiduciary duties to creditors). Distressed Investing Practice Group in 15 Quadrant Structured Prods. Co., Ltd. v. Vertin, 102 A.3d 155 (Del. Ch. Birmingham, AL. He represents debtors, 2014); North Am. Catholic Educ. Programming Fdtn., Inc. v. Gheewalla, 930 lenders, indenture trustees, and other A.2d 92 (De. 2007); Trenwick Am. Litig. Trust v. Ernst & Young, L.L.P., 906 creditors in bankruptcy cases and receivership A.2d 168 (Del. Ch. 2006). 16 In re United Healthcare System, Inc., 1997 WL 176574 (D. N.J. 1997). proceedings and in out-of-court negotiated workouts, loan 17 Id. at *5. restructurings, and orderly liquidations involving privately 18 Official Committee of Unsecured Creditors v. Baldwin (In re Lemington and publicly owned borrowers. Mr. Bender has developed Home for the Aged), 2015 WL 3055505 (3rd Cir. 2015) (applying special expertise representing creditors, debtors, investors, and Pennsylvania law). buyers of financially troubled health care providers. He has represented clients in distressed health care cases involving hospitals, surgical centers, continuing care retirement commu- Thanks go to the leaders of the Hospitals and nities (CCRCs), skilled nursing facilities, assisted living Health Systems Practice Group (HHS PG) for facilities, rehabilitation therapy providers, physician groups, sponsoring this Feature. imaging centers, and hospices. For more information about the HHS PG, visit www.healthlawyers.org/pgs or follow them on Twitter @AHLA_HHS.

24 AHLA Connections June 2015 A national healthcare consulting practice with an emphasis in: • Physician engagement and alignment strategies • Medical Staff redesign • Physician performance management strategies • Negligent credentialing/privileging/peer review Jon Burroughs, MD, MBA, FACHE, FACPE • Fair/Judicial Hearings President and CEO, The Burroughs Healthcare Consulting Network, Inc. • Medical Staff Bylaws, Policies/Procedures, Rules and Regulations Mobile: 603-733-8156 “We appreciate Dr. Burroughs’ hard work and flexibility. [email protected] He did a terrific job for the defense.” —Peter Eidenberg, Esq. / Keating, Jones & Hughes, PC / Portland, Oregon www.burroughshealthcare.com

As trusted counsel to clients throughout the health care industry, Crowell & Moring affords timely and keen insight into emerging AHLA’s office legal and business issues, and provides effective solutions and will be closed results that allow its clients to achieve their business objectives.

Friday, July 3, 2015, For more information about our health care practice, contact in observance of John Brennan at [email protected] Independence Day Arthur Lerner at [email protected] www.crowell.com/healthcare

healthlawyers.org 25 Public Interest

Public Interest in Action: AHLA Staff and Members Volunteer in New Orleans

If you have ever visited our website www.healthlawyers.org, chances are you have probably read part of AHLA’s Public Inter- est mission as you searched for one of our guidebooks or webinar resources. But this statement truly gets to the heart of Public Interest:

“AHLA is dedicated to bettering the communities in which we work and live. Our ongoing communication and efforts inform both the lay and health care communities so we can better understand complex Christopher Martin, Barb Miltenberger, so much. I also got to know and network health law issues and prepare for dif- and Chris Puri. The group spent the day with many AHLA members I would not ficult health care-related situations, beautifying the Royal Castle property have met otherwise.” ultimately leading to better care and by staining decks and benches, paint- David Cade, CEO and Executive planning for patients and their com- ing fences, planting flowers, assembling Vice President of AHLA, is hopeful munities. AHLA fulfills this Public storage units, and of course helping to that AHLA will be able to coordinate Interest commitment—giving back to clean up after the improvement efforts. more volunteer opportunities like this the health care communities—main- “It was an honor to give back to the one. That would make Ms. Milten- ly through the following activities.” community,” said Sylvie Ha. “I admire berger—and surely the staff of Royal [Emphasis added.] my peers who dedicated their time and Castle—very happy. Says Ms. Milten- talents to help make a safe and beautiful berger, “Keep up the good work and AHLA Public Interest is all about place for children to go and learn and let me know when another activity is improving our communities, bettering have fun.” scheduled!” health care, and giving back. Those sentiments were echoed by To keep up-to-date with the lat- One might assume that AHLA’s Barb Miltenberger, who was grateful to est Public Interest efforts, visit www. Public Interest mission is fulfilled solely AHLA for coordinating the project. “It healthlawyers.org/PublicInterest. You through the publication of guidebooks was a wonderful and fun experience. The can also donate to AHLA’s Public Inter- or factsheets related to public health child care center does great work and it est mission by visiting www.healthlaw- topics or through information pre- is gratifying to give back when we have yers.org/donate. sented during a webinar. But sometimes fulfilling the mission of improving the communities in which we work and live About Royal Castle and HandsOn New Orleans requires a more hands-on approach. On February 22, 2015 several AHLA Royal Castle opened its doors in 1996 to provide low-income residents with quality members and staff took a break from the child care at affordable rates. Unfortunately, the Center was closed from 2005 to 2007 after Hurricane Katrina inundated the Center with six feet of water. Long Term Care and the Law in-person Royal Castle is a cornerstone to the New Orleans community: to date, the program to volunteer at the Royal Castle Center has provided care for more than 2,000 infants and toddlers ages six weeks Child Development Center in New to five years old. By focusing on a holistic approach to education and care that en- Orleans, LA. AHLA volunteers were courages parental involvement and educates the entire family, Royal Castle helps joined by volunteers from another local children and families achieve long-term success. non-profit, HandsOn New Orleans. In AHLA’s Public Interest Committee was able to plan this community service total, eight program attendees, three project through HandsOn New Orleans, a local nonprofit whose mission is “to AHLA staff members, and two Hand- engage, empower, and transform our community through volunteer service…” sOn New Orleans staff members volun- HandsOn New Orleans was established after the Gulf Coast hurricanes ravaged teered that day, including Lois Cornell, communities in Louisiana in 2005. John Gochnour, Sylvie Ha, Karin Irwin,

26 AHLA Connections June 2015 Public Interest

Congratulations to AHLA’s 2014 Pro Bono Champions!

Since 2011, AHLA has been ers (NWNY) incorporate, obtain Finally, Ms. Bienstock has helped recognizing members who have tax-exempt status, and launch its first many new nonprofit organizations devoted a significant amount of campaign efforts. NWNY is a non-profit with formation and governance issues, their pro bono hours to cases in- organization dedicated to empowering including helping these organizations volving health law-related issues. young women immigrants from under­ to obtain tax-exempt status, preparing Some of our members devote hundreds served communities in New York City, governance documents, and provid- of hours each year to providing pro bono especially first-generation high school ing advice on best practices for board legal services in general. Given client and college students; recent, undocu­ members, including conflicts of inter- emergencies, complex litigation, and mented, low-income young women im­ est and financial controls. For example, rapidly emerging industry-wide issues, migrants; and single mothers. NWNY’s she provided guidance to Rethink the this is not an easy task. In addition, key goal is to provide young women Conversation on an array of forma- many Pro Bono Champions juggle the immigrants with the knowledge, skills, tion and governance issues. Rethink demands of operating a law firm, an and support they need to recognize and the Conversation is a new not-for-profit in-house legal department or – in the achieve their potential, pursue better corporation that seeks to address the case of some of AHLA’s past Pro Bono educational and professional oppor­ stigma around and indifference towards Champions – teaching full-time at law tunities, and become agents of change mental illness and suicide. By increasing schools. in and for their communities. While public awareness of suicide and men- NWNY is a young organization, it has a tal illness through the gathering and AHLA is extremely proud to strong message and Ms. Bienstock looks dissemination of accurate information, honor 30 Pro Bono Champions for forward to working with the organiza­ Rethink the Conversation destigmatizes the pro bono services they have tion further. these important issues and makes a real provided in the health law field In addition, Ms. Bienstock has difference in the lives of those who may during calendar year 2014. Con- provided ongoing support to GMHC contemplate suicide and survivors of gratulations to the following members (formerly Gay Men’s Health Crisis), a New suicide loss. whose commitment to providing pro York City-based non-profit community- bono legal services has impacted indi- based health and social services organiza- viduals and communities in significant tion. GMHC is a leading provider of HIV/ and meaningful ways. AIDS prevention, care and advocacy. Ms. Bienstock began assisting GMHC shortly Ross Burris after the organization announced that it Polsinelli PC would be expanding its comprehensive Atlanta, GA service delivery model to include new Julia Bienstock and innovative services by Mr. Burris worked with the Health Law Proskauer Rose LLP opening a state-of-the-art mental health Partnership (HeLP), a community col- New York, NY center. Ms. Bienstock continues assisting laboration among Children’s Healthcare GMHC in drafting and negotiating man- of Atlanta, Atlanta Legal Aid Society, Since September 2014, Ms. Bienstock aged care contracts for the new mental Inc., and Georgia State University Col- has helped New Women New York- health clinic. lege of Law that assists needy children

healthlawyers.org B1 Public Interest

Court of Appeals for the Fourth Circuit health information privacy advice for and U.S. Supreme Court and Halbig v. nonprofit health care providers, patient Burwell in the U.S. Court of Appeals for organizations, youth organizations and the District of Columbia Circuit. These veteran’s organizations, including Vet- two matters involved the issue of whether eran’s Village of San Diego (VVSV), an IRS-authorized tax credits to low-income organization dedicated to helping home- individuals for the purchase of health in- less and at-risk veterans to get off the surance under the ACA were permissible streets and fight addiction. DLA Piper and their families on legal matters that in all states or only in those states that LLP (US) works with VVSD as part of affect their health. HeLP’s primary established their own health insurance our national signature project, Serving premise is that attorneys can intervene exchanges under the ACA. Because a Those Who Serve Our Country. We have to improve the physical, social, and large majority of states (36) chose to rely helped them with lease and contract economic environments in which many on a federally-facilitated health insurance revisions, compliance with the ADA and low-income children live, resulting in exchange rather than establishing their health care regulatory requirements, their improved health and quality of own, and because the vast majority of low and various other legal matters for the life. HeLP’s goals are to address health- income individuals purchasing insurance nearly a decade. We also work closely harming legal problems in order to coverage on the exchanges have taken with VVSD in their role as lead sponsor improve health outcomes for low-income advantage of tax credits to make cover- of San Diego Stand Down, a three-day families through the establishment of age affordable, disallowing tax credits in event for homeless veterans. on-site public health legal services offices the states using the federally-facilitated at Children’s three hospital campuses; exchange would—according to most ob- to foster knowledge, understanding, and servers—eviscerate the goal of the ACA a cooperative spirit between the health to achieve near-universal health insur- care and legal professions to promote ance coverage. Jeremy Earl children’s health through interdisciplin- In both Halbig and King, Mr. Collier McDermott Will & Emery ary educational programs, including and McDermott represented a group Washington, DC in-service education for healthcare of 34 deans, chairs, and faculty mem- professionals at Children’s and student bers from public health schools across Mr. Earl maintains an active pro bono education for law students and graduate the country, arguing that disallowing practice dedicated to assisting individu- professional students; to improve low-in- premium subsidies (i.e., tax credits) in als with mental and physical disabili- come children’s access to healthcare and the 36 federally-facilitated exchange ties secure disability benefits from the the conditions that affect their health states would have devastating public Social Security Administration or the through a program of legal and policy health consequences for the low income Veterans’ Administration. In 2014, Mr. systemic advocacy, including advocacy residents who likely would lose insur- Earl continued his representation of a at the legislative, policy-making, and ance coverage. When the Supreme Court Vietnam War veteran in his claim for government agency levels; and to serve agreed to hear King, the public health service-connected disability benefits, as a model demonstration program for amici swelled to 102 deans, chairs, and related to the veteran’s post-traumatic interdisciplinary community collabora- faculty members and were joined by the stress disorder and tonsil cancer. Mr. tions that seek to promote the public’s American Public Health Association. Earl began his representation at the U.S. health. As proud as Mr. Burris is to The case, which received broad media Court of Appeals for Veterans’ Claims receive this selection, he is more proud attention, was argued on March 4, 2015 after the Veterans Consortium Pro Bono of the great work being done by HeLP. and a decision is expected in June. Program referred the case to him. Prior to Mr. Earl’s representation, the veteran had pursued his claim unsuccessfully for years and the Board of Veterans’ Appeals had rejected both the PTSD and tonsil H. Guy Collier Lara Compton cancer claims. McDermott Will & Emery DLA Piper With respect to the PTSD claim, the Washington, DC San Francisco, CA veteran sought an increase from a 30% to a 50% disability rating on the grounds During 2014, Mr. Collier served as lead Ms. Compton worked on multiple pro that his symptoms were sufficiently counsel on amicus briefs in two critical bono projects in 2014 related to health severe to support the higher rating. The cases interpreting the Affordable Care care regulatory advice. Ms. Compton’s veteran argued that his tonsil cancer was Act (ACA): King v. Burwell in the U.S. work included significant HIPAA and caused by his exposure to Agent Orange

B2 AHLA Connections June 2015 Public Interest

while in Vietnam. Mr. Earl worked and advocate for creative solutions that with a medical expert who reviewed the preserve the government’s responsibility veteran’s medical records and was able as the provider of last resort. to provide medical support linking the In 2014, Ms. Hance and other at- veteran’s Agent Orange exposure to his torneys at McDermott assisted NHeLP tonsil cancer. by providing legal research and analysis Following extensive briefing and the on issues relating to coverage mandates presentation of medical evidence, the under the Public Health Service Act. For Court of Appeals recently issued a fully- example, Ms. Hance and McDermott Ms. Helak represented NHeLP in its favorable decision on the veteran’s tonsil addressed the scope of the first-dollar assessment of potential legal avenues cancer claim. The Court of Appeals also coverage requirement for preventive ser- for seeking Medicaid expansion in the remanded the PTSD claim for further vices, including contraceptive items and states that declined to take advantage review on the grounds that the Board of services, adopted under the ACA. They of expanded federal funding available Veterans’ Appeals failed to sufficiently also assisted NHeLP in understanding under the ACA. This involved a state-by- consider certain evidence that was favor- the statutory and regulatory framework state assessment of state constitutions, able to the veteran. Mr. Earl is continuing for compliance with, and enforcement statutes, and regulations. This analysis to represent the veteran in his remanded under, the Public Health Service Act. supported NHeLP’s mission of protect- case for increased PTSD benefits. ing and advancing the health rights of low income and underserved individuals throughout the United States.

Dawn Helak Anne Hance McDermott Will & Emery McDermott Will & Emery Washington, DC Washington, DC Sean Higdon Ms. Helak, an associate in McDermott’s McDermott Will & Emery Ms. Hance, a partner in McDermott’s Washington office, focuses her practice Los Angeles, CA Washington office, actively provides pro on health care transactional and regula- bono service in addition to her robust tory matters. She also maintains an Mr. Higdon maintains a strong commit- practice advising health insurers, health active pro bono practice, leveraging her ment to pro bono practice, leveraging maintenance organizations, pharmacy health law expertise. Most recently, Ms. his knowledge of state and federal health benefit managers, and other industry Helak advised the National Health Law care programs to advise nonprofits stakeholders on federal and state regula- Program (NHeLP), a nonprofit organiza- working with underserved communities tory matters as well as providing counsel tion dedicated to protecting and advanc- on regulatory and tax-exempt matters. on issues relating to the Affordable Care ing the health rights of low-income and For example, Mr. Higdon advised a non- Act (ACA) and state insurance require- underserved individuals and families, profit provider of diagnostic and screen- ment. Ms. Hance most recently provided as they assessed issues arising under the ing mammography services based in the support to the National Health Law Affordable Care Act (ACA). Mid-Atlantic concerning reimbursement Program (NHeLP) on The ACA made billions of dollars in and billing issues. Mr. Higdon coun- and related projects. federal funding available to states that seled the provider, which exclusively NHeLP is a non-profit organization expanded their Medicaid programs to serves under and uninsured women who that addresses the health rights of low- cover non-elderly individuals in families otherwise have few options for care, income and underserved individuals and with incomes below 133 percent of on whether a provider may bill certain families. Established in 1969, NHeLP the Federal Poverty Level. The federal Medicaid and other state health care advocates, educates, and litigates at the government estimates approximately programs for mammography services if federal and state levels. Health care re- 8.6 million people have gained access to some of the equipment used to perform form offers the opportunity to substan- Medicaid or Children’s Health Insurance the service is obtained at no cost or tially reduce the number of uninsured Program coverage since 2014 as a result below-cost. Mr. Higdon further advised and improve access to care, including of this expansion in federal funding. the provider concerning implications for through the law’s expansion of the Med- However, almost half of the states have reimbursement due to recent proposed icaid program. NHeLP fights to give at- opted not to expand Medicaid and take changes to U.S. Preventive Services risk populations a voice in federal policy advantage of these federal funds, includ- Task Force guidelines concerning breast making, promote the rights of consum- ing some states whose citizens would cancer screening. ers in emerging managed-care systems, have benefited most. Mr. Higdon also helped a nonprofit

healthlawyers.org B3 Public Interest

provider’s everyday practice and will be granting his VA benefits, and that there useful to the many health care providers was actually enough medical evidence to who are unaware of their legal rights and show service connection to his disabili- duties when treating a patient who is a ties. The VA agreed to remand its deci- victim of bullying. The guide includes sion on all of the client’s claims. The VA information about “Matt’s Safe School rarely remands its decisions at this stage Law,” which requires all Michigan public and, if it does, will rarely remand on all school districts to implement policies claims without some caveats. This is the company that offers entertainment and and procedures to prohibit bullying (in- best decision that the client, or any other gifts to patients at a California chil- cluding cyberbullying) and to respond to veteran at this stage, could ask for. dren’s hospital secure tax-exempt status. incidents of bullying. Specifically, the company operates The publication also discusses the The VCPBP was created in 1992, with holiday-themed events for patients and mandatory reporting requirements ap- a dual mission to provide assistance to their families who would otherwise be plicable to health care providers under unrepresented veterans or their fam- unable to afford such activities on their Michigan law, including a discussion of ily members who have filed appeals at own. Mr. Higdon informed the company physician-patient privilege issues. The the U.S. Court of Appeals for Veterans about particular application criteria guide even includes an “Alleged Violent Claims, and to recruit and train at- given the type of services the company Injury Report” template that health care torneys in the then-fledgling field of provided and discussed differences in providers may use in their practice to veterans’ law. For volunteer attorneys, state and federal requirements for tax- report injuries resulting from bullying. the VCPBP teaches a one-day class in exempt status. Most importantly, Mr. Iwrey’s dedica- veterans’ law, and every attorney who tion to this cause will undoubtedly receives training accepts a case. benefit victims of bullying in Michigan. This is a matter that is a special cause for The health care providers who read the Mr. Jackson as before law school and fol- guide will be better equipped to identify lowing his graduation from West Point, Robert Iwrey symptoms of bullying and the resources Mr. Jackson served as a Medical Services The Health Law Partners PC available to help their patients. Corps Officer in the United States Army. Southfield, MI

In 2014, Mr. Iwrey continued his dedica- tion to pro bono services and turned his attention to the anti-bullying effort. Mr. Marshall E. Jackson Jr. Lisa Kaderabek Iwrey partnered with Marlene Seltzer, Epstein Becker & Green PC McDermott Will & Emery M.D., Director of the Beaumont Children’s Washington, DC Chicago, IL Hospital NoBLE Anti-Bullying Program, and the Oakland County Medical Society In 2014, through the Veterans Consor- Ms. Kaderabek, a partner in McDer- to develop informational materials to assist tium Pro Bono Program (VCPBP), Mr. mott’s Chicago office who focuses her health care providers in recognizing the Jackson successfully represented his practice on health care transactions, has signs of bullying, clarifying their obliga- client in his appeal before the U.S. Court maintained a strong pro bono commit- tions under applicable laws, and identify- of Appeals for Veterans Claims. The cli- ment year after year. She is particularly ing the resources available to their patients ent sought representation to appeal the dedicated to The Women’s Treatment who are victims of bullying. Mr. Iwrey decision by the Board of Veterans’ Ap- Center of Chicago (TWTC), a substance devoted a considerable amount of time peals (Board), an administrative tribunal abuse treatment center for women with to researching the laws and policies that within the U.S. Department of Veterans both in-patient and outpatient beds and impose duties on health care providers and Affairs (VA), to deny his VA benefits for programs. TWTC is unique in the area public school districts in Michigan to re- service connected disabilities of asbes- because it also provides services to chil- port and respond to incidents of bullying. tosis, asthma, and chronic obstructive dren, including nursery, pre-school, and The product of Mr. Iwrey’s efforts is pulmonary disease. Mr. Jackson was able pediatric care. “A Healthcare Provider’s Guide to Bul- to successfully argue that the Board did Ms. Kaderabek has provided general lying,” which was published in the Oak- not provide a proper basis for denying legal counsel services to TWTC, which land County Medical Society’s March/ his client’s benefits, that the Board failed has complex legal needs, since 1993. April 2015 Bulletin. This practical guide in its obligation to assist his client in In 2014, her pro bono work for TWTC can be incorporated into a health care recovering medical evidence to support included contract review, investment

B4 AHLA Connections June 2015 Public Interest

management and investment policy work, a member substitution, and em- ployment assistance. Ms. Kaderabek also Mark Kadzielski advised another tax-exempt entity on Pepper Hamilton LLP post-dissolution matters. Los Angeles, CA

Jee-Young Kim CCALAC’s members serve as the medical Mary Emma Karam Pepper Hamilton LLP home for over one million patients per Jackson Walker LLP Los Angeles, CA year. “LA’s health centers are deeply com- Dallas, Texas mitted to this program, their ongoing partnership with LA County, and most Ms. Karam serves as counsel to the importantly, the patients they serve,” Board of St. Joseph’s Residence, a non- Dayna Nicholson CCALAC President and CEO Louise profit assisted living facility for the indi- Pepper Hamilton LLP McCarthy said. “Our joint efforts to build gent and underserved. In this volunteer Los Angeles, CA and implement My Health LA will create capacity since 2008, she worked with the a strong foundation for the continued Board in 2014 to handle legal matters Pepper attorneys Mark Kadzielski, development of a world-class system of enabling it to expand its license and Jee-Young Kim, and Dayna Nicholson care for all residents of LA County.” double the size of the facility to increase were at the forefront of the efforts in The Pepper pro bono team provided the availability of its services, includ- Los Angeles to establish My Health LA CCALAC significant assistance in ne- ing taking in a number of persons from (MHLA), a partnership program that gotiating the MHLA master agreement homeless facilities. Her legal work at no will strengthen primary care access, and all of its attendant exhibits—total- charge for this facility included revision promote coordination, and improve ing over 150 pages. The MHLA pro- of its bylaws and assisted living policies, health outcomes for approximately gram is just the latest project that the compliance with state regulations, re- 150,000 of LA County’s remaining Pepper team has handled for CCALAC. sponding to resident inquiries, and legal uninsured. At a recent 25-year Anniversary Cel- compliance with health care issues. The MHLA program evolved from ebration, Mr. Kadzielski, Ms. Nichol- Additionally, Ms. Karam provides a decades-long partnership between son, and Ms. Kim were recognized for pro bono legal services to Catholic Char- the Los Angeles County Department their outstanding efforts in support of ities of Dallas, which provides programs of Health Services (LADHS) and local LA’s community clinics. According to that serve the poorest and most vulner- community clinics and health centers. Ms. McCarthy, the Pepper team has able people throughout North Texas. In The program kicked off on October 1, “had a profound impact on the health the past year, Ms. Karam has worked 2014 with more than 10,000 LA residents care landscape of LA County. Without extensively to help the organization with already enrolled. Under the newly-mint- their support, hundreds of thousands its broker and insurance company in ad- ed MHLA, these safety-net providers of underserved patients would not have dressing legal issues related to its health will receive funding of up to $61 million access to high quality, cost effective care plan and compliance with regula- annually to provide a range of services services.” tions under the Affordable Care Act and including primary care, dental care, Mr. Kadzielski was also instrumen- other health care benefit issues. chronic disease management, and pre- tal in his contributions to AHLA’s latest Ms. Karam has also spent many pro scription medications to the uninsured Public Interest publication, Legal and bono hours advising this non-profit patients enrolled in the program. Operational Guide for Free Medical organization and its church employer The Community Clinic Association Clinics (coming in July 2015), which benefit plan on various issues under of Los Angeles County (CCALAC), a will provide valuable guidance to health care regulations and laws in the long-time pro bono client of Mr. Kadziel- health care providers, community lead- area of compliance. ski, Ms. Kim, and Ms. Nicholson, led key ers, and pro bono counsel who want to negotiations with LADHS on behalf of its build and operate a free medical clinic member community clinics. Founded in in underserved communities. 1994, CCALAC represents the inter- ests of fifty-five community clinics and health centers that operate over 200 primary care sites throughout the county.

healthlawyers.org B5 Public Interest

for the school district initiated a formal under the ACA. This involved a state-by- administrative hearing seeking a judi- state assessment of state constitutions, cially enforceable order that would have statutes, and regulations. This analysis placed the boy in the inappropriate self- supported NHeLP’s mission of protect- contained special education classroom. ing and advancing the health rights of Mr. Leone continued his representation low income and underserved individuals of the boy and his family in contesting throughout the United States.. the appeal, which the school was subse- quently forced to withdraw. Mr. Leone then advised the family on the options Peter Leone available for continuing education in a McDermott Will & Emery classroom better suited for their son’s Karen Nelson Boston, MA educational needs. DLA Piper Austin, TX Peter Leone continues to devote sub- stantial pro bono hours to representing Cornerstone Recovery, Inc. is a chari- young children (generally under eight table organization with a mission to years old) and their families in seek- Kate McDonald promote wellness and address the health ing appropriate individualized special McDermott Will & Emery care needs of at-risk adolescents. Over education services from public school Washington, DC half of its clients receive some form districts. These pro bono special educa- of financial assistance. Cornerstone tion cases may involve children with Kate McDonald, an associate in Mc- Recovery, Inc. developed an innovative diagnoses such as autism spectrum Dermott’s Washington office, focuses model for outpatient adolescent chemi- disorder, attention deficit hyperactivity her practice on federal and state health cal dependency treatment services that disorder (ADHD), and physical disabili- care government programs. She also combined traditional treatment methods ties. Often, the cases can entail disciplin- maintains a robust pro bono practice. with adventure activities and family sup- ary matters and require added resources In 2014, Ms. McDonald advised the port. The average one-year sobriety rate to ensure the child’s effective educational National Health Law Program (NHeLP), has historically been 89%, which is well development and growth. a non-profit organization protecting in excess of the 38% industry standard. In 2014, Mr. Leone worked on such and advancing the health rights of low- The majority of its clients move on to cases identified and screened by the income and underserved individuals and attend college or become productively Children’s Law Center of Massachusetts families, as they assessed issues arising employed. DLA Piper LLP (US) original- and by the Medical-Legal Partnership/ under the Affordable Care Act (ACA). ly accepted Cornerstone as a pro bono Boston. In one case, a seven-year-old The ACA made billions of dollars in client to assist with correcting certain second grade student was eligible to federal funding available to states that documentation matters identified during receive special education in a regular expanded their Medicaid programs to a routine inspection. Karen Nelson has classroom under an individualized cover non-elderly individuals in families continued to work with Cornerstone in education program that was to provide with incomes below 133 percent of the developing best practices for documen- him with behavioral supports to address Federal Poverty Level. The federal gov- tation and, ultimately, restructuring to neurological and emotional disabilities, ernment estimates that approximately mitigate potential legal risks. DLA Piper developed from birth, which could make 8.6 million people have gained access to has collaborated with the client and the it difficult for him to access the regular Medicaid or Children’s Health Insurance state licensing agency throughout the classroom curriculum. However, the Program coverage since 2014 as a result restructuring efforts to ensure that the behavior plan that the school devised of this expansion in federal funding. Al- new business model satisfies regulatory was not tailored with rewards that most half of the states have opted not to guidelines while continuing to support would be effective with the boy. With expand Medicaid and take advantage of the types of professional services that the school unwilling to expend funds these federal funds, however, including have proven to be so effective. for the needed in-classroom support, the some of the states whose citizens would school district sought an administrative have benefited the most. order placing the boy in a self-contained Ms. McDonald represented NHeLP in special education classroom that was not its assessment of potential legal avenues appropriate for his educational program. for seeking Medicaid expansion in the When the school proved unwilling to states that refused to take advantage of modify the boy’s program, the attorney the expanded federal funding available

B6 AHLA Connections June 2015 Public Interest

In light of McDermott’s submissions that were supported by the health profession- Monica Neuman als’ evaluations, the child’s current school McDermott Will & Emery acknowledged that it could not adequately Boston, MA provide the range of appropriate special education services required by law in this Ms. Neuman has actively engaged Mc- instance, and it agreed to fund an out-of- Dermott’s lawyers and summer associ- district placement at a specialized school. ates in the Boston office in undertaking The family was extremely pleased with this in the routine denial of jobs, housing, a broad range of pro bono matters. She result and Ms. Neuman and Mr. Leone’s rep- and educational opportunities. also has an active pro bono practice resentation continues, with a shift in focus Mr. Ortman was also an integral focused on representing mentally and to ensuring that the placement chosen and member of a team that worked with the physically disabled children and their funded is an available and appropriate one. Legal Aid Society of Metropolitan Fam- families in seeking special education ily Services’ anti-trafficking initiative to services to ensure their educational investigate the possibility of expanding development and growth. the civil remedies available to formerly Ms. Neuman has worked closely with sex-trafficked individuals under the McDermott attorney Peter Leone on Randall Ortman Illinois Predator Accountability Act special education cases referred by the McDermott Will & Emery (IPAA) to individuals who were formerly Children’s Law Center of Massachusetts. Chicago, IL labor trafficked. Sex and labor traffick- In 2014, Ms. Neuman and Mr. Leone ing victims are subjected to deplorable represented the family of a four-year-old Mr. Ortman has devoted significant conditions, impacting their mental and boy in need of special education services. pro bono time to advocating for LGBT physical health. Mr. Ortman and his The boy’s public school district devised an rights. He leads, organizes, and regularly colleagues liaised in a working group Individualized Education Plan (IEP) that, volunteers for McDermott’s legal clinic comprised of various legal, advocacy, while placing the boy in a self-contained advising LGBT individuals at the Center and community groups with an inter- special education classroom, fell short of on Halsted, one of the nation’s largest est in human trafficking to secure and meeting the legal standard for services LGBT community centers. Through the expand civil remedies for victims. required in light of the boy’s diagnosis legal clinic, Mr. Ortman has assisted Mr. Ortman also serves as chair- of autism spectrum disorder and global LGBT individuals with navigating insur- person of the LGBT Committee of the developmental delay. More specifically, ance coverage restrictions and under- Chicago Bar Association (CBA). In that the school district’s services in the special standing the impact of the Affordable role, Mr. Ortman organizes and hosts education classroom fell far short of what Care Act (ACA). He also works with the weekly presentations addressing various was specified in the specialized and exten- Broadway Youth Center of the Howard topics, including the impact of the ACA sive pediatric medical and developmental Brown Health Center, advising at-risk for the LGBT community and health is- evaluations and recommendations that the LGBT youth on obtaining birth records sues unique to transgender individuals. family obtained from a specialized teach- necessary to address employment, hous- ing hospital. ing, and health-related issues. Ms. Neuman, working with Mr. In 2014, Mr. Ortman participated Leone, has advocated for over a year in the Second Chance Clinic, organized on behalf of the boy and his family. As by the Association of Pro Bono Counsel Anna Park detailed in multiple advocacy submis- (ABPCo) IMPACT program. Mr. Ort- McDermott Will & Emery sions and school meetings, the boy’s man assisted individuals with criminal Los Angeles, CA family and professionals all believed records obtain Illinois Health Care that an out-of-district placement into a Waivers, which allows eligible individu- Ms. Park, who focuses her practice on small, highly specialized school program als with criminal records to demonstrate transactional and regulatory matters qualified in working with children with to employers and others that they are affecting a wide range of clients in the autism spectrum disorder and co- “rehabilitated,” and health care employ- health care industry, continues to main­ occurring global developmental delays ers are relieved from certain criminal tain a robust pro bono practice. During was the optimal result for the child, and and civil liabilities if they hire such 2014, Ms. Park represented four separate such a placement was consistent with individuals. Such criminal records often organizations on health care-related the special education program recom- stem from isolated, long-past incidents, issues. She assisted Bet Tzedek Legal Ser­ mendations contained in the most recent but because adult felony convictions can- vices in preparing an Advanced Health hospital evaluations. not be expunged in Illinois, they result Directives seminar for senior residents

healthlawyers.org B7 Public Interest

Brian Roark Chelsea Rutherford Bass Berry & Sims PLC McDermott Will & Emery Nashville, TN Washington, DC

For five years, Bass, Berry & Sims de- Ms. Rutherford maintains an active pro voted more than 4,400 pro bono hours bono practice dedicated to assisting served by the organization; advised across 30 team members to the defense health-based nonprofit organizations, as Claris Health with respect to its sexual of a local ambulatory service company well as mentally and physically disabled health education program; advised a facing charges of Medicare and Medic­ children and their families seeking non­profit provider of diagnostic and aid fraud in the case of USA v. Medlock. special education services to ensure their screen­ing mammography services As leader of the firm’s Healthcare Fraud educational development and growth. based in the Mid-Atlantic concerning Task Force, Mr. Roark served as the In a matter referred by Children’s Law reimbursement and billing issues; and firm’s lead counsel for the case alongside Center, Ms. Rutherford and her col- assisted KHEIR – Imaging Center in a the appointed counsel Barry Tidwell of leagues represent an aunt and her matter relating to its 340B program. Bullock Fly Hornsby & Evans. six-year-old niece in securing special In January 2010, Woody Medlock, education services from the District owner of Murfreesboro Ambulance Ser- of Columbia Public Schools (DCPS). vice, was indicted on charges of Medi- Ms. Rutherford compiled and reviewed care and Medicaid fraud. The indictment records and prior evaluations of her cli- Rene Quashie was a result of a joint federal and state ent’s niece, and successfully petitioned Epstein Becker & Green PC investiga­tion into fraudulent billing DCPS to obtain independent education- Washington, DC practices by the company to Medicare al, speech-language, and occupational and Medicaid for transportation of di- evaluations. She has also worked with In February 2014, the District of alysis patients who were not qualified to the student’s Individualized Education Columbia’s La Clinica del Pueblo receive ambulance transportation. In the Program (IEP) team at the elementary won a $425,000 grant from CareFirst initial trial, held in U.S. District Court, school to secure appropriate services, BlueCross BlueShield to implement a Middle District of Tennessee, Medlock and continues to advocate on her client’s telemedicine behavioral health initia- was found guilty and sentenced in Janu- behalf to ensure the student obtains a tive that will expand remote access to ary 2014 to a 75-month prison sentence. quality education informed by her spe- its bilingual counselors and health care The Bass, Berry & Sims team donated cific learning needs. providers through telemedicine to ap- 442 hours of billable time during 2014 In 2014, Ms. Rutherford also con- proximately 650 patients in the DC area. preparing for the appeal. On May 13, tributed significant pro bono hours to Mr. Quashie led a team of attorneys at 2015, the Sixth Circuit Court of Ap- counseling the Solve ME/CFS Initiative Epstein Becker Green who aided La Cli- peals overturned the aggravated identity (SMCI), the nation’s leading charitable nica del Pueblo with its grant application theft conviction of Woody Medlock. The organization dedicated to conquering and Mr. Quashie continues to provide Sixth Circuit held that the Medlock did chronic fatigue and immune dysfunc- pro bono legal services as La Clinica not “use” the identifying information tion syndrome. Ms. Rutherford specifi- implements the program. of the Medicare beneficiaries within the cally assisted SMCI in the preparation In a February 20, 2014, article, meaning of the aggravated identity theft and negotiation of research agreements CareFirst said it will offer $1.3 million in statute merely by lying about how the that navigated complex regulatory grants to four initiatives meant to help beneficiaries had been transported. requirements related to human subjects medical providers develop telemedicine- Mr. Roark devoted nearly 600 hours research and data privacy. based ways to increase access to behav- throughout the trial and 2014 appeal ioral health services. CareFirst is plan- and was instrumental in preparing and ning to grant money over three years to delivering an extensive oral argument seed projects that use video conferencing before the court. Since the beginning or other technologies to allow doctors of this case in 2010, Brian has provided and others to diagnose and treat patients extensive guidance and counsel to the remotely. The grants were meant to ex- client and other team members. pand access to behavioral health care for patients in both urban and rural areas of the District of Columbia and Maryland.

B8 AHLA Connections June 2015 Public Interest

A recent case involved a 19-year-old Sheniece Smith patient who was diagnosed with several Children’s Hospital of conditions including cerebral palsy, Orange County global developmental delay, epilepsy, Orange, CA and cognitive impairment. These condi- tions left the patient wheel-chair bound, Ms. Smith spent approximately two without the ability to speak, and in need years developing the structure for a of his family’s close care to assist daily medical-legal partnership between necessities. garten, first, and second grade students Children’s Hospital of Orange County Ms. Smith represented the parents who are academically at-risk in Miami- (CHOC) and the Public Law Center, a in obtaining a conservatorship for their Dade County Public Schools. All- pro bono law firm, to provide free legal son so that they would continue to have Aboard recruits, trains, places, moni- services to CHOC patients who cannot the legal authority to make decisions for tors, and supports volunteers to tutor afford to pay for legal services on their his care and well-being, even though one-on-one during the regular school own. The clinic, Family Legal Assis- he is now legally an adult. After five day and at after school care programs. tance at CHOC Children’s, launched in months of work submitting paperwork, January 2014 and focuses specifically meeting conservatorship requirements, on guardianships and conservatorships. and a court appearance, the court is- Many families are in need of this service sued Letters of Conservatorship to the yet lack the proper information or finan- parents granting them the legal ability Jerome Tichner cial resources to obtain the service. The to continue to make decisions for their McDermott Will & Emery hospital sees many children who do not adult son. Ms. Smith also filed the neces- Boston, MA have parents or legal guardians involved sary paperwork to prevent the family in their lives or their care, as well as from having to re-appear for the 90 day Mr. Tichner is a Partner in McDermott pediatric patients who are developmen- review hearing. Will & Emery’s Health Industry Advi- tally disabled and will continue to need sory Practice Group, where his practice care from another adult throughout has involved the merger, acquisition, and their lives. In 2014, the clinic served over affiliation of over 20 U.S. hospitals in the 90 families, with more than 90% of the past 5 years. Continuing his year-to-year cases ending in an approved guardian- James Saling commitment to pro bono work in 2014, ship or conservatorship. McDermott Will & Emery Mr. Tichner devoted over 80 pro bono The clinic also offers a service for Miami, FL hours to two entities in the health care guardians or conservators to have a will field: Families for Depression Aware- drafted to designate care of the patients Mr. Saling, who focuses his practice on ness (FFDA) and American Healthcare if they pass away or become unable to health care mergers and acquisitions Professionals and Friends for Medicine continue care. Ms. Smith and the Public and regulatory matters, maintains an in Israel (APF). Law Center successfully found two active pro bono practice. In 2014, Mr. FFDA is a nonprofit charity dedi- sponsors to provide volunteers for the Saling advised the National Health Law cated to helping families recognize project: the Hyundai Motor America Program (NHelp), a non-profit organi- and cope with depression and bipolar in-house legal department and the Shep- zation working to protect and advance disorder. Working with other McDer- pard, Mullin, Richter & Hampton LLP the health rights of low-income and mott attorneys, Mr. Tichner helped Orange County, California office. Ms. underserved individuals. Mr. Saling and FFDA launch a Care Consultation Smith was instrumental in putting to- a McDermott team analyzed a state’s pilot program dedicated to provid- gether presentations to train the volun- ability to collect Medicaid debt against ing free Care Consultation services to teer attorneys and continues to have an individuals under Medicaid expansion low income families in Massachusetts. active role in the monthly clinics. With laws. The team’s research and analysis Services include conducting screenings Ms. Smith’s efforts, CHOC was named was used by NHelp in its advocacy ef- and in-person meetings to assess family Community Partner of the Year by the forts to correct the inequities present in needs, developing family action plans, Public Law Center at their 2014 annual the health care system and pursue legal and helping to connect families with award dinner. strategies to improve health care access. available mental health resources in and Additionally, Ms. Smith has taken Mr. Saling also works with Miami’s around Massachusetts. several pro bono cases on direct Institute for Child & Family Health on Mr. Tichner’s pro bono work for representation from the Family Legal the All-Aboard Tutoring/Mentoring FFDA included providing advice with Assistance at CHOC Children’s clinic. Program, which targets pre-k, kinder- respect to the development of engage-

healthlawyers.org B9 Public Interest

Scott Weinstein Anna Whites McDermott Will & Emery Anna Whites Law Office Washington, DC Frankfort, KY

Mr. Weinstein is an associate in Mc- As a long-term pro bono advocate in the Dermott’s Washington office, where he area of autism, Ms. Whites has dedicated ment letters, consent and privacy forms, maintains a strong commitment to pro over 50 hours a year on legal advocacy policies and procedures and other relat- bono work. During 2014, Mr. Weinstein for persons with autism, their families, ed materials. Mr. Tichner also provided assisted two clients with appeals of their caregivers, and schools or employers. FFDA with governance-related support social security disability determinations. This includes outreach to courts and and, in addition to his pro bono work He performed legal research for both cas- public advocates to aid them with an for FFDA, served as a Board member for es, gathered medical evidence, performed understanding of autism spectrum is- a 6th consecutive year and as Chair of client interviews, prepared a letter brief, sues, as well as education for families FFDA’s Governance Committee. and represented one of the clients at an and persons with autism so that they can APF is a nonprofit charitable administrative hearing. Both clients were understand their legal rights and the ser- organization helping North Ameri- seeking listings relating to mental health vices and supports available to them as a can health care professionals receive disabilities, and had been incarcerated matter of law. advanced training in disaster manage- during parts of their application process. In 2014, the Office of Autism was es- ment through Disaster and Emergency Mr. Weinstein navigated the complexi- tablished to address Kentucky’s lack of a Preparedness Courses offered in Israel. ties surrounding these cases in forming coordinated system of service provision APF is the only organization designated arguments for these clients’ appeals. and to link public, private, and edu- by the State of Israel to maintain a Mr. Weinstein also assisted two cational institution services related to Registry of Emergency Medical Volun- non-profit entities with health regula- autism spectrum disorders. Ms. Whites teers. In the event of a declared national tory compliance questions. The first, assisted in the creation, implementa- crisis in Israel, APF volunteers would be Cape Moments, Inc. d/b/a My Moments tion, and overall support for the Office of called upon to provide medical care and (in partnership with the Dana-Farber Autism which will facilitate the coordi- assistance in Israeli civilian hospitals. In Cancer Institute), sought to offer art nation between the Kentucky Cabinet 2014, Mr. Tichner provided general cor- therapy classes for patients in psychiat- for Health and Family Services, the porate pro bono support to APF through ric hospitals. Mr. Weinstein helped the Kentucky Department for Community work with APF’s Executive Director. Mr. client determine its compliance needs Based Services, the Kentucky Commis- Tichner also served on APF’s Board of under the Health Insurance Portability sion for Children with Special Health Directors. and Accountability Act, and developed Needs, the Governor’s Committee for privacy and security policies and proce- Autism Spectrum Disorders, private dures for their services. Mr. Weinstein and public autism support groups, the additionally drafted Business Associate University of Kentucky, and the Univer- Agreements for the client. sity of Louisville. Ms. Whites advocated Adam Walters The second non-profit sought to to ensure that the Office of Autism has Sanders Law Firm PC establish a position on requesting medi- office space at no charge and drafted Savannah, GA cal record evidence from hospitals and Memorandum of Agreements, sample medical providers for social security legislation, contributed to the Execu- Mr. Walters provided representation of disability cases in which law firms were tive Order to implement the program, the parent of an adult with a cognitive providing pro bono representation. Mr. and engaged with affected entities in the disability seeking guardianship and rep- Weinstein assisted the non-profit in mutual effort to create and support the resentation of the aunt of a minor seek- determining what steps it would need to Office of Autism. ing guardianship for medical decisions. take in order to request medical records on behalf of a social security disability client and his/her pro bono attorney. He researched the requirements for patient authorization under federal and state law and proposed potential options for the client to provide this service.

B10 AHLA Connections June 2015 Distance Learning Redefined

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healthlawyers.org 27 Compensation-Focused Compliance: Is Your Physician Compensation Governance Process Ready for Shifts in Stark Law Enforcement?

By Joseph N. Wolfe, Hall Render Killian Heath & Lyman, physicians and medical groups.2 Milwaukee, WI, and Alex T. Krouse, Krieg DeVault LLP, Given the substantial awards and settlements in recent Stark Law enforcement actions, compensation-focused Mishawaka, IN compliance has become more than just a compliance issue: it is an enterprise risk management issue. As medical groups, Compliance issues related to physician compensation have been hospitals, and health systems pursue integration strategies a key area of discussion in health care for a number of years. and transition to more innovative compensation plans, these This area continues to grow in importance as the demands of organizations must manage their compliance and enterprise health care reform and value-based payments accelerate the risk by ensuring their compensation arrangements are defen- need for health care organizations to have an aligned physician sible under the Stark Law.3 These health care organizations, workforce. As such, adoption of a compliant and innovative independent, hospital and system-affiliated groups in partic- physician compensation plan that incentivizes quality of care ular, should evaluate their compensation-focused governance and cost effectiveness, while encouraging optimal physician structures to ensure existing processes and internal controls productivity, is a necessity for health care organizations. support compliance with Stark’s technical requirements and In response to these changing market dynamics, medical key tenets of defensibility (e.g., fair market value, commercial groups, hospitals, and health systems are focusing on devel- reasonableness, and not taking into account designated health oping integrated health care delivery systems structured service referrals, etc.) in case their physician compensation around acquiring, employing, and directly compensating their arrangements are ever challenged. aligned physicians. From multiple perspectives, employment (as This article focuses on the Stark Law’s underlying technical opposed to other alignment strategies) is generally the preferred requirements, related tenets of defensibility, and potential shifts integration model because employed physicians are more in Stark Law enforcement. It also seeks to provide guidance for tightly aligned and provide these organizations with wider medical groups, hospitals, and health systems as they assess latitude to develop, implement, and incentivize behavior that their compensation governance structures to ensure existing advances the organization’s integration strategies and business processes and internal controls support compensation-focused objectives. Health care organizations are allocating substantial compliance in today’s shifting enforcement climate. time and resources toward integrating their employed physi- cians and overhauling their existing compensation models to Compensation-Focused Compliance position themselves for success in a new value-based world. Stark Overview Simultaneously, as evidenced by a wave of recent cases and The Stark Law prohibits a physician from making referrals of provider settlements, the federal government continues to certain designated health services (DHS) to any entity with focus on pursuing health care fraud and abuse. A combination which the physician has a financial relationship, unless the of aggressive enforcement efforts and a hyper-technical regula- arrangement qualifies for one of Stark’s specified exceptions. tory framework make today’s environment particularly chal- No entity furnishing DHS may submit a claim to Medicare for lenging for health care organizations. Enforcement continues services performed pursuant to a physician’s prohibited DHS to focus on the federal physician self-referral law and its imple- referral.4 This prohibition applies regardless of the reasons for 1 menting regulations (collectively, the Stark Law or Stark). the financial relationship and the DHS referral. Unlike fraud Specifically, government enforcement efforts concentrate on and abuse laws such as the Anti-Kickback Statute, no finding alleged violations related to compensation-focused compli- of unlawful intent is required under the Stark Law.5 ance (e.g., fair market value, commercial reasonableness, the While it has the features of a fraud and abuse law, the Stark prohibition on taking into account designated health service Law is fundamentally a billing and payment rule. In cases referrals, etc.). Historically, enforcement efforts centered where an entity bills and collects for DHS referred in violation almost solely on hospitals, even though physicians and medical of the Stark Law, the entity must refund the inappropriately groups have been intimately involved in the compensation collected amount in a timely manner. The government may arrangements. The dynamic has shifted somewhat, however, impose a civil penalty of up to $15,000 for each claim related to and it appears that whistleblowers and the government are the DHS billed by a person or entity who knew, or should have now expanding their focus to enforcement actions against known, that the DHS was referred in violation of the Stark Law.

28 AHLA Connections June 2015 The violation also may cause the person or entity to be excluded the regulations and agency commentary on the three tenets of from federal health care programs and may result in imposi- defensibility provides additional context. tion of a civil penalty of up to $100,000 against any parties that ❯❯ The first tenet, fair market value, is defined in both the Stark enter into a scheme to circumvent the Stark Law’s prohibition.6 statute and its implementing regulations.19 CMS has provid- Similar to the Anti-Kickback Statute, a Stark Law violation may ed some general explanatory guidance on this topic, but has also serve as the basis for liability under the False Claims Act.7 declined to set forth a specific methodology for determining From a compliance and process perspective, health care whether the fair market value standard has been satisfied, organizations should ensure that all compensation arrange- noting that no single method could apply universally to the ments with referring physicians meet Stark’s technical require- wide variety of arrangements, services, and markets covered ments and fit squarely within an applicable exception.8 In by Stark.20 Significantly, CMS has endorsed referencing particular, for organizations adopting direct physician employ- multiple, objective, and independently published surveys as ment models, arrangements are likely to be structured to meet a prudent practice for evaluating fair market value and has either the exception for bona fide employment relationships9 recognized the use of independent valuation consultants as or the in-office ancillary services exception (IOAS).10 The one means of supporting fair market value.21 Although an employment exception is generally considered the broadest independent valuation is not required by the Stark Law, it and most commonly used compensation exception available has become a routine practice for health care organizations under Stark.11 The exception does not protect, however, physi- to engage valuation consultants to issue a written valuation cian members of a group practice who also function as owners. opinion confirming that the compensation paid under an Financial relationships involving physician ownership generally arrangement is consistent with fair market value. must meet the IOAS, which is applicable to both compensation ❯❯ The second tenet, commercial reasonableness, is not defined and ownership financial arrangements.12 under either the Stark statute or its implementing regulations. The IOAS provides additional compensation flexibility for Therefore, there are inherent challenges to meeting this stan- independent, hospital or system-affiliated physician practice dard. For compliance and documentation purposes, organiza- entities, provided they are separately organized and operated tions and valuation consultants generally look to published primarily for the purpose of being a physician “group practice.”13 CMS commentary that describes the standard as being met by As a threshold matter, the physician practice entity must meet all certain subjective and objective qualitative factors.22 Health nine structural and operational requirements for being a “group care organizations evaluating commercial reasonableness practice.”14 Stark group practices can pay productivity bonuses should consider whether the financial arrangement ap- for DHS that are “incident to” a physician’s personally performed pears to be a sensible, prudent business agreement from the services and also can distribute overall profits derived from DHS perspective of the parties, even in the absence of any potential to the group or to subcomponents of the group, provided the DHS referrals. Many valuation consultants have developed distribution methodology does not directly take into account expertise in assessing and confirming compliance with the DHS referrals.15 This favored treatment and additional latitude commercial reasonableness standard. These consultants are with respect to physician compensation is statutory.16 Ensuring often willing to incorporate their commercial reasonable- and documenting compliance with the hyper-technical require- ness analysis and conclusions into a more comprehensive and ments of the group practice definition and IOAS exception is robust written valuation opinion. a prudent practice that will enhance defensibility in the event ❯❯ Finally, the third tenet, sometimes referred to as the volume a group practice’s compensation arrangements are ever chal- or value standard, prohibits paying compensation that is lenged. The Centers for Medicare & Medicaid Services (CMS) has determined in a manner that takes into account, directly or specifically noted in agency commentary that group practices indirectly, the volume or value of DHS referrals by the refer- that choose to take advantage of the IOAS should at all times be ring physician. This tenet has inherent challenges as well, in prepared to demonstrate compliance with the relevant statutory part because of the potential for a broad reading of the phrase and regulatory standards.17 “takes into account” and also because of court interpretations Health care organizations pursuing alternative alignment indicating that compensation based on anticipated DHS refer- models that do not fit within the bona fide employment exception rals can implicate the standard.23 For compliance purposes, or the IOAS should ensure their structures are defensible under one as a threshold matter, health care organizations should ensure of the many other exceptions available under the Stark Law.18 their compensation formulas do not calculate compensation in any manner that is based on a physician’s DHS referral Key Tenets of Defensibility activity.24 Further, to the extent possible, governance processes Though each Stark exception carries its own technical require- should emphasize and document the proper non-referral pur- ments, three key tenets of defensibility are common to most of poses supporting all compensation arrangements and should them: (1) the compensation must be consistent with fair market avoid any actions or communications that may be miscon- value; (2) the compensation must be paid under an arrange- strued as being in violation of this standard. ment that is commercially reasonable; and (3) the compensation cannot be determined in a manner that takes into account the In several of the recent enforcement cases, the government has volume or value of the physician’s referrals of DHS. Because expressly alleged Stark Law violations based on these three tenets these tenets of defensibility are common to most exceptions, of defensibility. Thus, in addition to ensuring strict technical governance processes and procedures should support and compliance with an exception, organizations looking to manage document compliance with these tenets regardless of the excep- their Stark Law risk should focus their attention on confirming tion that is ultimately relied upon. Notably, the guidance in and documenting their compliance with these tenets.

healthlawyers.org 29 Ongoing Stark Law Enforcement arrangements with two Ohio hospitals that allegedly vio- Due to favorable judgments and settlements, and positive returns lated the Stark Law.32 on its investment in enforcement, it is likely the government ❯❯ Infirmary Health System Inc. (Infirmary) agreed to pay will continue to aggressively pursue potential fraud. Recently, $24.5 million to resolve alleged Stark Law violations related the Department of Health and Human Services (HHS) and to bonus payments to physicians that allegedly took into Department of Justice (DOJ) noted in their Annual Report of the account the volume or value of DHS referrals.33 A central Departments of Health and Human Services: Health Care Fraud issue in the case was whether the Infirmary practice enti- and Abuse Control Program (Report) that the return on invest- ties could meet the definition of a Stark group practice for ment from their joint health care fraud enforcement efforts was purposes of the IOAS. $7.70 returned for every $1.00 spent over the last three years.25 The ❯❯ New York Heart Center (New York Heart), an independent Report also noted that Office of General Counsel will continue cardiology physician practice, agreed to pay $1.33 million to to assist the DOJ with assessments of complex issues in enforce- resolve alleged Stark Law violations relating to an internal ment actions involving the Stark Law. The Report highlights the compensation formula that allegedly directly took into ac- ongoing and joint focus of HHS and DOJ with respect to health count the volume or value of each physician’s DHS referrals, care fraud. primarily their referrals for nuclear scans and CT scans.34 As has been the case for a number of years, Stark Law actions ❯❯ Two cardiologists and their physician practice agreed to pay are largely initiated by private whistleblowers under the False $380,000 to resolve alleged Stark Law violations relating to Claims Act’s qui tam provisions.26 The following cases and management agreements that allegedly were not commer- settlements from 2014 and 2015 suggest a continued focus on cially reasonable.35 alleged Stark Law violations related to the key tenets of defen- sibility (i.e., fair market value, commercial reasonableness, and Although these recent cases are important because they repre- the volume or value standard). sent a departure from actions solely against hospitals, these ❯❯ Halifax Hospital agreed to pay $85 million to resolve alleged cases still focus predominately on the key tenets of defensibility. Stark Law violations relating to oncology bonus arrange- Additionally, Infirmary and New York Heart are particularly ments that allegedly took into account the volume or value interesting because they may be indicative of an increased of DHS referrals and neurosurgery compensation arrange- regulatory focus on internal group practice dynamics and ments that allegedly exceeded fair market value.27 compliance with the IOAS and group practice requirements. ❯❯ All Children’s Health System, Inc. agreed to pay $7 million What continues to be most important, however, is that from to resolve alleged Stark Law violations relating to physician the onset of any arrangement, whether internal group compen- compensation arrangements that allegedly exceeded fair sation or hospital-physician compensation arrangements, market value.28 organizations should ensure governance processes support ❯❯ Citizens Medical Center agreed to pay $21.75 million to defensibility under the Stark Law. resolve alleged Stark Law violations relating to cardiology and emergency department physician salaries that allegedly Compensation-Focused Compliance took into account DHS referrals, were not commercially As discussed throughout this article, health care organizations reasonable and exceeded fair market value.29 should adopt governance processes that support compliance ❯❯ Westchester Medical Center agreed to pay $18.8 million to with Stark’s technical requirements and key tenets of defensi- resolve alleged Stark Law violations relating to consulting bility. There is no-one-size-fits-all strategy to achieve compensa- and fellowship arrangements with referring cardiologists tion focused compliance. Health care organizations will utilize that allegedly took into account DHS referrals, were not different approaches to demonstrate compliance due to their commercially reasonable and exceeded fair market value.30 different market dynamics, existing governance framework, tax- ❯❯ King’s Daughters Medical Center agreed to pay $40.9 mil- exempt status, organizational size and complexity, risk tolerance, lion to resolve alleged Stark Law violations relating to cardi- and other factors unique to their particular circumstances. ology salaries that allegedly exceeded fair market value.31 Regardless of the organization’s ultimate approach, however, a recommended starting point for all health care organizations These cases and settlements demonstrate the government’s is a careful examination of the Stark regulations and applicable continued focus on Stark enforcement and underscore the guidance from CMS, the HHS Office of Inspector General (OIG), importance of developing processes that support and appropri- and as applicable, the Internal Revenue Service (IRS) to ensure ately document compliance with the key tenets of defensibility. compensation governance structures support compliance. The Though the government’s focus is, in one sense, somewhat OIG has developed a series of voluntary compliance program predictable, the following cases display how Stark Law enforce- guidance documents intended to encourage development and 36 ment is constantly evolving. use of internal controls to monitor regulatory compliance. The OIG’s 2000 Compliance Program for Individual and Small Potential Shifts in Enforcement Group Physician Practices (Practice Guidance) and 2005 Supple- Historically, enforcement efforts generally focused on hospital mental Program Guidance for Hospitals (Hospital Guidance) 37 activity. The following cases from 2014 suggest that the dynamic are particularly informative. Although these documents were has shifted in some areas, and that more actions against physi- initially directed at slightly different segments of the health care cians and medical groups may be coming down the pipeline. industry, when examined together they provide a comprehensive ❯❯ A cardiologist and his physician practice agreed to pay framework that is applicable to integrated health care delivery $1 million to resolve an enforcement action related to systems. In particular, the Practice Guidance and Hospital Guid-

30 AHLA Connections June 2015 ance documents identify seven basic components of an effective Given the substantial awards compliance program that serve as a solid basis for evaluating ongoing compensation-focused compliance efforts.38 and settlements in recent Stark The considerations below, while neither exhaustive nor Law enforcement actions, comprehensive, are intended to provide health care organiza- tions with issues to identify as they begin to evaluate their compensation- compensation-focused governance processes. focused compliance Compensation Governance Process Considerations has become 1. Initial Governance Considerations. more than just a a. Integration with Compliance Program. Compensation- compliance issue: it focused compliance is potentially an enterprise risk management issue. Thus, health care organizations should is an enterprise risk align their compensation governance processes with their management issue. existing compliance program structures. For example, an organization’s compliance officer could participate actively in the compensation committee meetings and governance process or compliance department liaisons could be integrated into the underlying processes, such as reviewing compensation models for compliance purposes, d. Focus on Plan Implementation. Once the terms of a developing compensation-focused compliance policies, compensation arrangement are established, health care and performing monitoring or audit functions. organizations should take care to ensure that they are b. Engagement of Legal Counsel. Legal counsel’s role often properly implemented and consistently followed. Recent focuses on advising management and the board or com- enforcement actions highlight the dangers of establish- pensation committee on the legal and regulatory risks of ing, but then failing to follow the terms of a compensa- the organization’s physician compensation arrangements. tion plan and/or compensation policies. Additional duties may include providing compliance training, governance and oversight counseling, manage- 2. Compliance Training and Education. Compensation- ment of the valuation process (e.g., facilitating selection of focused training and education programs help ensure that a valuation firm, assessment of valuation opinions for de- physicians, employees, and members of the board and fensibility, etc.), assistance with compensation model and compensation committee are fully capable of executing plan development, and legal assessments of the compensa- their roles in accordance with rules, regulations, and other tion arrangements under applicable laws. Legal counsel standards applicable to physician compensation. The Hos- may be tasked with monitoring regulatory changes, the pital Guidance and Practice Guidance identify a number of industry’s enforcement climate, and areas of identified common factors that health care organizations can consider risk. Due to the unique regulatory framework, it is critical as they evaluate their training and education programs.39 for counsel to be experienced with the Stark Law, physi- cian compensation, and health care valuation issues. 3. Processes for Compensation Oversight. Health care organi- c. Engagement of a Qualified Third-Party Valuation Consul- zations should consider establishing a standing compensation tant. The valuation consultant’s role may include perfor- committee of the governing board with delegated responsibili- mance of financial projections, compensation planning ty for oversight, modifications, adjustments, and/or exceptions and design (e.g., examination of national trends, concep- to the organization’s physician compensation arrangements. tual modeling, etc.), development of compensation struc- The role of the management team in physician compensa- tures and compliance parameters, providing expertise, tion matters (e.g., reporting requirements, recommendation and issuance of an objective third-party opinion validat- authority, etc.) should also be defined. The compensation ing fair market value and commercial reasonableness. committee should receive regular reports from the functional Consideration should be given to engagement directly by areas discussed above regarding compensation governance legal counsel to ensure that the communications related to and the organization’s efforts to mitigate risk. the valuation and any written reports obtained under the engagement are protected under the attorney-client privi- 4. Parameters for Compensation Review. Health care organiza- lege. Consistent with the terms of the privilege, the valu- tions should work with their valuation consultant to develop ator should work at the direction and under the control compensation parameters/thresholds that trigger additional of legal counsel. Health care organizations should engage governance processes. Once thresholds are triggered, the valuation consultants that have the requisite expertise to organization could perform additional internal or external opine on compliance with the Stark Law’s definitions of analyses to confirm and document that the facts and circum- fair market value and commercial reasonableness. Further, stances support compliance with the fair market value and valuation consultants should not “take into account” the commercial reasonableness standards. Appropriate support volume or value of past, present, or future DHS referrals may include survey data supporting the arrangement, docu- and should state the same in their written valuation opin- mentation of the underlying business rationale, and/or a writ- ions and work papers. ten valuation opinion from a third-party valuation consultant.

healthlawyers.org 31 5. Governance Documents. The following governance docu- 8. Approaches for Documenting Compliance. ments, in addition to others, may be necessary: a. Legal Analysis. Health care organizations should define a. Compensation Committee Charter. The compensation legal counsel’s role in documenting compliance. They charter should define the compensation committee’s also should consider requesting formal written as- purpose, member composition, responsibilities, and sessments of the compensation arrangement or plan’s processes by which it will carry out those responsibilities. compliance with the underling technical requirements b. Compensation Plan. The compensation plan could ad- of the applicable laws (e.g., Anti-Kickback Statute, Stark dress some or all of the following: (i) identification of the Law, Intermediate Sanctions Law, etc.). These assess- guiding principles and objectives that form the basis of the ments could be performed and updated periodically to organization’s compensation philosophy; (ii) governance address changes in the regulations and shifts in Stark roles and responsibilities; (iii) physician compensation for- Law enforcement. mulas and parameters; and (iv) a processes for monitoring b. Valuation Analysis. Health care organizations should also and documenting compliance with the fair market value define the valuation consultant’s role in documenting and commercial reasonableness regulatory standards. compliance.41 They should also consider obtaining a for- c. Contractual Support for Compensation Review. The mal written valuation opinion documenting compliance contract terms in a health care organization’s physician with the key tenets of fair market value and commercial employment agreements and compensation plan should reasonableness. allow for periodic evaluation of projected and actual c. The Volume or Value Standard. Governance process should compensation and should facilitate the withholding and emphasize and document the proper non-referral busi- modification of such compensation when necessary to ness rationale supporting all compensation arrangements. maintain regulatory compliance. Health care organizations should also avoid any actions or d. Physician Compensation Policies. A health care organiza- communications that may be misconstrued as violating the tion’s policies should establish compensation-focused prohibition on taking into account DHS referrals. compliance standards and processes for: (i) requesting d. Documentation Supporting Group Practice Require- contracts; (ii) developing compliant terms; (iii) review- ments. Independent, hospital or system-affiliated physi- ing the arrangement for technical Stark compliance; (iv) cian practice entities that rely on the group practice supporting the key tenets of defensibility with analysis definition and the IOAS should develop processes for and documentation; and (v) approving of compensation evaluating and documenting compliance with the arrangements by management and/or the compensation hyper-technical underlying requirements. committee depending on the identified approval authority. 9. Internal Monitoring and Auditing. Health care organiza- 6. The Rebuttable Presumption. Tax-exempt organizations tions should consistently monitor and periodically audit their should consider whether the compensation approval process compensation-focused compliance protocols to confirm they supports the establishment of a rebuttable presumption under are being followed and to ensure they can support the techni- the Internal Revenue Code of 1986.40 For this presumption to cal requirements and key tenets of defensibility of the Stark exist, the Code generally requires the following factors: (i) the Law if their arrangements are ever challenged. The Practice compensation arrangement must be approved in advance by Guidance and Hospital Guidance collectively identify a num- an authorized body of disinterested individuals; (ii) the autho- ber of factors that health care organizations can consider as rized body must rely upon “appropriate data as to comparabil- they evaluate their monitoring and audit programs.42 ity” in making its determination; and (iii) the authorized body must adequately document the basis for its determination The resulting goal of the critical analysis performed by a health concurrently with that determination. care organization is to anticipate the continued changing market conditions and shifting Stark Law enforcement trends. Although 7. Quality Based Compensation. Health care organizations it can be difficult to anticipate shifting enforcement trends and that are transitioning to models that incentivize quality and how Stark may be construed under specific fact patterns, health cost savings should develop processes for evaluating compli- care organizations can nonetheless still strive to be consistent ance with Section 1128A(b)(1)-(2) of the Social Security Act with historical understandings of government enforcement. (the “CMP”). The CMP establishes a civil monetary penalty of up to $2,000 per covered patient against any hospital that Governance Process as a Solution knowingly makes a payment directly or indirectly to a physi- Health care organizations face significant potential liability in cian (and any physician who received such payment) as an the current regulatory environment. Given these risks under the inducement to reduce or limit services provided with respect Stark Law, it is of the utmost importance that health care organi- to Medicare or Medicaid beneficiaries under such physician’s zations continue to enhance their compensation-focused gover- direct care. Appropriate governance processes may include nance processes. Specifically, health organizations should focus documentation of the evidence and clinical outcomes sup- on the key tenets of defensibility and organizational planning. porting the quality and cost savings measures and develop- Health care organizations can be assured that Stark Law enforce- ment of sufficient safeguards to protect against inappropriate ment will continue; however, by planning and enhancing the reductions in care. key tenets of defensibility and ensuring compensation-focused compliance, risks of enforcement can be significantly reduced.

32 AHLA Connections June 2015 About the Authors 21 Id. 22 See 63 Fed. Reg. 1700 (Jan. 9, 1998) and 69 Fed. Reg. 16093 (Mar. 26, 2004). 23 The federal district court in United States ex rel. Singh v. Bradford Reg’l Med. Joseph Wolfe ([email protected]) is a Ctr., 752 F. Supp. 2d 602 (W.D. Pa. 2010) interpreted that the term “referral” health care lawyer in the Milwaukee, WI, office encompasses both actual and anticipated referrals. 24 42 C.F.R. § 411.352. The Stark Law permits payment of bonuses and profit of Hall Render Killian Heath & Lyman PC. Mr. shares that include DHS revenues, provided the distribution methodology Wolfe provides advice and counsel to some of meets certain conditions. the nation’s largest health systems, hospitals, and 25 Department of Health and Human Services and the Department of Justice, Health Care Fraud and Abuse Control Program Annual Report for Fiscal Year individual medical practices on a variety of 2014 (Mar. 19, 2015), available at https://oig.hhs.gov/publications/docs/hcfac/ health care issues. He regularly counsels clients on a national FY2014-hcfac.pdf. basis regarding compliance-focused physician compensation 26 Press Release, Department of Justice (DOJ), Justice Department Recovers Nearly $6 Billion from False Claims Act Cases in Fiscal Year 2014 (Nov. 20, and alignment strategies, the physician self-referral statute, 2014), available at www.justice.gov/opa/pr/justice-department-recovers- hospital-physician transactions, physician compensation nearly-6-billion-false-claims-act-cases-fiscal-year-2014. governance, and health care valuation issues. 27 Press Release, DOJ, Florida Hospital System Agrees to Pay the Government $85 Million to Settle Allegations of Improper Financial Relationships with Alex T. Krouse ([email protected]) is an Referring Physicians (Mar. 11, 2014), available at www.justice.gov/opa/pr/ florida-hospital-system-agrees-pay-government-85-million-settle-allegations- attorney in the health care practice group at improper. Krieg DeVault LLP in Mishawaka, IN. He 28 United States ex rel. Schubert v. All Children’s Health Sys., Case No.: focuses on transactional, regulatory, and 8:11-cv-01687-T-27EAJ, 2013 U.S. Dist. LEXIS 163075, at *2-5 (M.D. Fla. Nov. compliance work for various health care 15, 2013). 29 Press Release, DOJ, Texas-Based Citizens Medical Center Agrees to Pay providers including health systems, hospitals, United States $21.75 Million to Settle Alleged False Claims Act Violations (Apr. health care providers, and other business entities. He concen- 21, 2015), available at www.justice.gov/opa/pr/texas-based-citizens-medical- trates his practice on regulatory issues affecting a wide range of center-agrees-pay-united-states-2175-million-settle-alleged. 30 Press Release, DOJ, Manhattan U.S. Attorney Settles Civil Fraud Claims business and health care clients, including regularly advising Against Westchester Medical Center Arising From Its Violations Of The organizations on Stark Law and Anti-Kickback Statute Anti-Kickback Statute And The Stark Law (May 14, 2015), available at compliance. Mr. Krouse regularly provides legal advice to www.justice.gov/usao-sdny/pr/manhattan-us-attorney-settles-civil-fraud- claims-against-westchester-medical-center. health systems regarding the compliant and effective use of 31 Press Release, DOJ, King’s Daughters Medical Center to Pay Nearly $41 practitioners in their organizations. Million to Resolve Allegations of False Billing for Unnecessary Cardiac Procedures and Kickbacks (May 28, 2014), available at www.justice.gov/opa/ Endnotes pr/king-s-daughters-medical-center-pay-nearly-41-million-resolve-allegations- false-billing. 1 42 U.S.C. § 1395nn. 32 Press Release, DOJ, Health Care Providers to Pay $1 million for False 2 See generally Danielle M. Sloane, Lauren M. Gaffney & Amy Sanders, Fallen Claims, Improper Referrals (Apr. 17, 2014), available at www.justice.gov/ Halos, Excessive Salaries, and Turning Yourself In: A Look Back at 2014 Stark usao-ndwv/pr/health-care-providers-pay-1-million-false-claims-improper- Law Enforcement, AHLA Connections, Feb. 2015, at 36. referrals. 3 See 42 U.S.C. § 1395nn. Because of the significant exposure for health care orga- 33 United States ex rel. Heesch v. Diagnostic Physicians Grp., No. nizations, the Stark Law is viewed as a threshold compliance statute. That being 1:11-cv-00364-KD-B (S.D. Ala. Sept. 4, 2014). said, compliance with the Stark Law will not ensure compliance under the federal 34 Press Release, DOJ, New York Heart Center To Pay More Than $1.33 Million Anti-Kickback Statute or the Internal Revenue Code of 1986. To Settle Allegations Of False Claims Act And Stark Law Violations (Aug. 14, 4 42 C.F.R. § 411.353(b). 2014), available at www.justice.gov/usao-ndny/pr/new-york-heart-center-pay- 5 See 42 U.S.C. § 1320a-7b(b). The relevant inquiry in an action brought under more-133-million-settle-allegations-false-claims-act-and. the Anti-Kickback Statute focuses on the subjective intent of the parties to 35 Press Release, DOJ, Kentucky Cardiologists Agree to Pay $380,000 to exchange remuneration for referrals. Settle False Claims Act Allegations Based on Illegal Referrals (Oct. 21, 2014), 6 Social Security Act § 1877(g); 42 U.S.C. § 1395nn(g); 42 C.F.R. §§ 411.351(b)-(d). available at www.justice.gov/opa/pr/kentucky-cardiologists-agree-pay- 7 42 U.S.C. 1320a-7b. 380000-settle-falseclaims-act-allegations-based-illegal. 8 See OIG Supplemental Compliance Program Guidance for Hospitals, 70 Fed. 36 OIG Compliance Guidance, available at http://oig.hhs.gov/compliance/compli- Reg. 4858 (Jan. 31, 2005). ance-guidance/index.asp. 9 See 42 C.F.R. § 411.357(c) (2015). 37 See Supplemental Compliance Program Guidance for Hospitals, 70 Fed. Reg. 10 42 C.F.R. § 411.355(b). 4858 (Jan. 31, 2005); see also Compliance Program for Individual and Small 11 See 42 C.F.R. § 411.357(c). Further, the employment exception lacks many of Group Physician Practices, 65 Fed. Reg. 59434 (Oct. 5, 2000). the requirements that trigger technical Stark issues under other exceptions 38 Id. The OIG identifies seven factors that are often observed in effective compliance (e.g., that compensation must be “set-in-advance,” that the arrangement be programs: (1) designation of a compliance officer and compliance committee; evidenced by a signed written agreement, that the arrangement have a term of (2) development of compliance policies and procedures, including standards of at least a year, etc.). conduct; (3) developing open lines of communication; (4) appropriate training and 12 42 C.F.R. § 411.355. education; (5) internal monitoring and auditing; (6) response to detected efficien- 13 Id. cies; and (7) enforcement of disciplinary standards. 14 42 C.F.R. § 411.352; see also 69 Fed. Reg. at 16077 (Mar. 26, 2004). 39 Id. 15 42 C.F.R. § 411.352; see also 66 Fed. Reg. at 909 (Jan. 4, 2001). CMS has 40 Treas. Regs. § 53.4958-6(a). identified safe harbored methodologies for distributing productivity bonuses 41 See Supplemental Compliance Program Guidance for Hospitals, 70 Fed. Reg. and profit shares that it deems to be indirect. Group practices may use other 4858 (Jan. 31, 2005); see also Compliance Program for Individual and Small methodologies provided they are reasonable, objectively verifiable, and are Group Physician Practices, 65 Fed. Reg. 59434 (Oct. 5, 2000). only indirectly related to DHS referrals. 42 Id. 16 42 U.S.C. § 1395nn; see also 69 Fed. Reg. at 16077 (Mar. 26, 2004). 17 66 Fed. Reg. at 909 (Jan. 4, 2001). 18 See 42 C.F.R. § 411.357. 19 42 U.S.C. § 1395nn(h)(3); 42 C.F.R. § 411.351. Thanks go to the leaders of the Physician 20 See 69 Fed. Reg. 16107 (Mar. 26, 2004); see also 72 Fed. Reg. at 51015-16 Organizations Practice Group (PO PG) for (Sep. 5, 2007). In 2004 CMS created a “safe harbor” provision in the definition sponsoring this Feature. of “fair market value” under Stark for hourly payments made to physicians for their personal services. Due in part to concerns regarding the availability of For more information about the PO PG, the surveys identified in the safe harbor, the fair market value safe harbor was eliminated by CMS in 2007. visit www.healthlawyers.org/pgs or follow them on Twitter @AHLA_PhysOrgs. healthlawyers.org 33 Women’s Network

AHLA Women’s Network - Looking Back at our “Freshman” Year

Dear Diary – and don’ts in the legal setting, and attendees participated in sharing their lists as well. Attendees left with tools to simplify What an amazing inaugural year the AHLA Women’s Lead- the technology demands and scheduling issues that frequently ership Council has had! We have been working and brain- arise at work. February ushered in “A Few Good Men: Perspec- storming to create interesting, informative, and relevant tives from Men about Women in Law” at the Physicians and programming at in-person meetings, articles for AHLA Hospitals Law Institute in Las Vegas. Presenters included past Connections, and terrific conversations on the new online president Rick Shackelford, Michael Schaff, and Rob Niccolini. Women’s Network community. They provided their perspectives on advice they would give their daughters, work/life balance from a man’s perspective, In case you have picked up my diary and are reading it, you and patterns for success. may not have been aware of the Women’s Leadership Council because you have not: (a) attended an AHLA in-person At the Long Term Care and the Law program in New Orleans, meeting where the Council presented; (b) been reading your panelists Joanne Lax, Amy Brantley, and Julia McMillen ever-growing stack of health care publications (including discussed their experiences and offered advice on executive AHLA Connections) or (c) crawled out from underneath your presence during their panel “Tips and Tools for Building Your desk after reading Tuomey. Please let me take a moment to Executive Presence.” The Institute on Medicare and Medicaid show you what we have done this past year and what we intend Payment Issues featured a panel on “Effective Communica- to accomplish in the coming year. tion with the Government.” Panelists Jana Kolarik Anderson and Lisa Ohrin Wilson talked about communicating between First, we have an awesome Council of AHLA women volun- the government and private sector, and discussed challenges teers from around the country representing government, specific to women. in-house counsel, consultants, and law firms. Thank you to my amazing team: Radha Bachman, Carol Carden, This year, we hosted the inaugural Women’s Leadership Tracy Ivers, Amy Joseph, Laurie Levin, Helen Quick, Institute (WLI) in Nashville. The day-long program included Michele Hartmann Tamene, Claire Turcotte, Laura sessions on critical conversations, mentoring, negotiation Laemmle-Weidenfeld, Vicki Robinson. Also Anna skills, bridging the gap between generational and gender Bhat, Beth Christian, Jody Joiner, and Lisa Gora. These differences, and more. We’re excited to keep the momentum women contributed their time, creativity, and expertise to alive for next year’s WLI. design programs and articles over the last year. I also want to thank our amazing staff dedicated to our Council, which During the Annual Meeting on Wednesday, July 1, we will includes Kerry Hoggard, Anne Hoover, Allison Beard, and host a breakfast panel presentation entitled “It’s Raining Men Tory Johnson. They did all the heavy lifting. Women: Building Networks and Relationships that Produce Results.” Come join us, listen, share your perspective and So–how did we start? We sent a survey to all AHLA women wisdom, network with fellow AHLA members, and help members asking them what they wanted the Council to focus advance the dialogue and success of our members. on. At the end of compiling the anonymous surveys, the topics And so diary, I close off a fabulous end of the AHLA were sorted into several areas: networking, client develop- “school” year. I look forward to the Council’s activi- ment, leadership, effective mentoring, work/life balance, and ties in our next fiscal year. Everyone have a great professionalism. Thus, we planned our programming around summer–beaches, burgers, and Bieber . . . oh my. your requests. At the Fraud and Compliance program in the fall, Kathleen McDermott and Asha Scielzo presented on Anthea “From Proposal to Presentation: Useful Tips for Developing a Successful Speaking Event.” Attendees were treated to an Anthea R. Daniels, chair of the Women’s hour-long session on how to organize and execute a successful Leadership Council, is on the pep squad, presentation. National Honor Society, and show choir. In her spare time she’s a Shareholder at Baker At the Academic Medical Centers program, the Council Donelson. presented a breakfast session on “New Year’s Resolutions: What I’m Going to Do and What I’m Not Going to Do at Work in 2015.” Presenters were Kristen Rosati and Claire Cowart Haltom. This presentation provided helpful hints on the do’s

34 AHLA Connections June 2015 Women’s Network

Breakfast Panel Recap: “Tips and Tools for Building Executive Presence”

Tracy Ivers Joanne Lax Amy Brantley Julia McMillen

AHLA’s Women’s Leadership Council (WLC) sponsored a How does this definition change based on the situ- networking breakfast panel at the Long Term Care and the ation, environment, and the type of people that you Law program on Tuesday, February 24, on “Tips and Tools for are interacting with? Building Executive Presence.” Moderated by WLC member Tracy C. Ivers, Attorney and Legal and Compliance Amy Brantley: The definition of executive presence Analyst at Masonicare, the panel included Amy Brantley, doesn’t change. Your “executive presence” remains an Chief Compliance Officer at Golden Living; Joanne R. Lax, integral part of you as you adapt to your situation and/or Member at Dykema Gossett PLLC and Chair of AHLA’s Post- audience. Your executive presence actually gives you the Acute and Long Term Care Services Practice Group; and Julia ability to successfully interact with different situations, McMillen, General Counsel at Post Acute Partners. Read a environments, and people. recap of the questions and the panelists’ responses below. Are there any tips on personal appearance/dressing Is “executive presence” a term of art? What does that should be considered when trying to convey “executive presence” mean to you? How do you executive presence? command a room with authority and/or how important is executive presence? Julia McMillen: Appearance matters. We may want judgments about us to be solely merit-based, but there are Joanne Lax: In my opinion, the main attributes of all sorts of intangibles – how we look, how we sound, how executive presence are subject matter competence, appro- we appear to others – that factor into people’s judgments priate demeanor and decorum for the situation, respect about us. On the one hand, how we appear to others may and empathy for others involved in the conversation matter more in the “first impression” sense than in the (both for their opinions and for them personally), and an long-term “executive presence” sense. But appearance appropriate level of humble self-confidence. Be sure that matters in the longer-term “executive presence” sense you are well prepared and thorough in your analysis of as well. I’ve been asked in both corporate and law firm an issue, but be flexible enough to allow your thinking settings to talk to women colleagues about their appear- to evolve if other participants raise valid points that you ance in connection with advancing their careers. There is have not previously considered. Neither agree for the sole something to be said about looking or acting the part – purpose of placating, nor disagree for the sole purpose men do it, too. of dominating. Be true to your own personality and style and always be a person of integrity.

healthlawyers.org D1 Women’s Network

How can you demonstrate that you belong “at the What advice do you have for young attorneys who table” without overstepping/posturing? are just starting to encounter situations where they are in the spotlight? What are some behaviors that Joanne Lax: You do not need to be the loudest or most promote executive presence? vivacious person in the room in order to command respect from others as a trusted advisor. You do need to Amy Brantley: I would suggest remembering that speak from a strong knowledge base that has been fine “listening” is a very important skill. Thoughtful, reflective tuned to recognize the needs of your client. People quickly responses when you truly do have something to contribute see through shallow glad-handing and instead react is also important. Do not speak up just to be heard; have positively to the person who reliably delivers quality and something worth saying. value. Julia McMillen: I agree with Joanne and Amy – coming How do you handle it when things go awry/ prepared, listening to others, and staying true to your own mishap? personality. In high-pressure situations, if you’re prepared, you will have foundation to rely upon; if you’ve listened, Amy Brantley: As we know, there are varying degrees you’ll anticipate other’s expectations and reactions; and if of “blunders.” As part of “executive presence,” I believe you’re true to yourself, you’ll be credible. you must be accountable and as transparent as possible in those situations when unexpected things arise. If you We would like to thank the audience for attending the break- have achieved the level of maturity that supports execu- fast panel presentation, the panel faculty for coordinating and tive presence, you are able to address the mishaps and still delivering the presentation, and AHLA’s Women’s Leadership maintain the respect of your peers. How do you main- Council for sponsoring the event. tain composure in an unexpected/unplanned situation? Humility is the first line of defense with a little amount of humor. I quickly accept the situation and find a way to correct it.

Do you think women have to work harder at earning and maintaining executive presence? Build your case with Julia McMillen: I do think women – and anyone who is not in the majority – have to work harder at executive living, working expertise. presence. Women executives and lawyers operate in a man’s world with limited role models, whereas men are accustomed to operating in a world where everyone is just like them. So if a women walks into a meeting, sits down quietly and buries herself in her notes – in contrast to the man who walks in and announces through words and body language that “he’s arrived” – the message the men in the room may be receiving from the woman is that this is person is not good, smart, articulate (fill in the blank), Nationwide and across the health care continuum, like me. more than 2,500 health care organizations rely on us for timely, practical, technical expertise on their most vital business challenges.

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healthlawyers.org 37 Member News

Kathleen M. Jerard Jensen has William H. Boozang has been been named General Thompson, chairman named Dean of the Counsel for the Marsh- of Hall Render Killian Seton Hall Univer- field Clinic Health Heath & Lyman PC sity School of Law in System in Marshfield, in Indianapolis, IN, Newark, NJ. WI. has received the 2015 Distinguished Alumni Award from the Emily T. Brack- Dana G. Jones, Indiana University Richard M. Fair- stone has been named owner/partner of Dana banks School of Public Health. a shareholder at Baker G. Jones & Associates Donelson in Memphis, with offices in Chicago, J. Everett Wilson, a TN. IL and Raleigh/Durham, shareholder at Akerman NC, was recently named LLP in Miami, FL, has Director of Contracting and Health Care been added to the Board Daniel B. Brown has Legal Compliance with the North Caro- of Directors for the joined Taylor English lina Department of the Treasurer - State Health Foundation of Duma LLP in the firm’s Health Plan. South Florida. Atlanta, GA, office. Scott Leuning has joined the Goosmann Law Firm in Sioux Falls, Sarah K. Browning SD. has joined the firm of Taylor English Duma LLP in Atlanta, GA. Catherine A. Martin Several attorneys have joined Roetzel & has been named co-chair Andress LPA’s health care law practice of Ober|Kaler’s Health as partners in Chicago, IL: Ericka L. Lois Dehls Cornell, Law Group in Baltimore, Adler, Michael B. Brohman, and Chief Administrative MD. David J. Hochman. Officer and General Counsel of Tufts Health Plan in Watertown, MA, and AHLA’s President Elect, has been honored by the YWCA Boston in their Academy of Women Achievers.

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healthlawyers.org 39 Fraud and Compliance Forum Sponsored by Heal Care Appraisers, Inc.

Join us in Baltimore, where we will address emerging regulatory trends, recent case law and legislative developments, and how they affect legal and compliance practices in health care. This program covers Stark, False Claims Act, Anti-Kickback Statute, and the enforcement efforts in these areas. Joyce Branda, Deputy Assistant Attorney General, US Department of Justice, will be our keynote speaker, followed by Elizabeth Carder-Thompson who will cover the Year in Review.

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40 AHLA Connections June 2015 Securing Protected Health Information is Our Main Focus

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800.737.2585 United States regulatory compliance; medical providing corporate, litigation, Multiple Locations, US: Health staff and accreditation; clinical tax, contract, and other legal Washington, DC: Compliance Care Attorneys, Dinsmore & affiliation agreements; managed advice and review, research, Manager, The HSC Health Shohl LLP. Dinsmore & Shohl care contracting; real estate analysis and recommenda- Care System. The HSC Health LLP, a prominent law firm with and construction; and health tions on wide variety of internal Care System is seeking a approximately 575 attorneys care reform and reimburse- matters. Under the direction of Compliance Manager who is in eighteen offices, is looking ment. Minimum Required the General Counsel, manage passionate about advancing for lateral health care attor- Qualifications: JD; Membership industry legal and compli- our organization in a respon- neys to add to our growing in the Arkansas Bar, or eligibility ance policy development and sible and compliant way for the team. The firm has continued for immediate admission; five execution on domestic and benefit of children and young to grow substantially over the (5) or more years experience global legal and compliance people with special needs past several years, driven in as a practicing attorney with at policy matters affecting the in the District of Columbia. part by our lead role in cases least three (3) years of health medical device industry. Works Experience: Bachelor’s degree of national prominence. The care experience. Please apply with staff to develop, imple- and minimum of five (5) years firm has offices in Colorado, at mercy.net/careers. EEO/AA/ ment, and monitor certain relevant experience. To apply, Illinois, Kentucky, Ohio, Minorities/Females/Disabled/ Association corporate policies email credentials to Barbara L. Pennsylvania, Washington, DC, Veterans and procedures for compliance Sheppard, PHR at­ Bsheppard@ and West Virginia. Our health with relevant laws and regula- hospsc.org. California tions. Required: Bachelor’s care attorneys leverage varied Los Angeles, CA: Chief Florida backgrounds with detailed degree and Juris Doctorate Compliance and Privacy from an accredited law school; Gainesville, FL: Deputy General knowledge of the health care Officer, Children’s Hospital Los Counsel, UF Health Shands. industry and serve both institu- membership in a State Bar; Angeles. The Chief Compliance eight or more (8+) years’ experi- UF Health Shands, located tional and individual health care and Privacy Officer is respon- in Gainesville, FL, and affili- providers located throughout ence involving corporate legal sible for supporting a culture work. For more information or ated with the University of the nation on a variety of consistent with the organiza- Florida, is one of the premier constantly evolving issues our to apply, email credentials to tion’s mission, values, and [email protected]. academic health systems in clients face. All candidates code of conduct by planning, the Southeast. The successful should have a strong academic designing, implementing and candidate will possess the Washington, DC: Chief background and possess maintaining compliance and following qualifications: JD excellent communication skills. Compliance Office, GW Medical privacy programs, policies, and Faculty Associates. This posi- from an accredited law school; Please send cover letter and procedures for the purpose Licensed to practice law in resume to Jennifer Stark, tion is responsible for ensuring of ensuring organizational all areas of the organization are the state of Florida, or eligible Director of Recruiting and Legal reporting integrity and compli- for admission under Florida Personnel, Dinsmore & Shohl in compliance with applicable ance effectiveness. The Chief laws and regulations, and Authorized House Counsel rule; LLP, 255 East Fifth Street, Suite Compliance and Privacy Minimum of 10+ years of health 1900, Cincinnati, OH 45202, is responsible for planning, Officer helps ensure adequate designing, implementing, care law, and extensive transac- or to dinsmore.legalrecruiting@ internal controls are maintained tional experience required, with dinsmore.com. maintaining, and assessing the through reviews of existing and MFA’s Compliance Program and major law firm or major health Arkansas proposed processes and that associated policies and proce- care corporation preferred; Fort Smith, AR: Associate staff and physicians perform dures, in order to promote and Experience negotiating and Counsel, Mercy Hospital. Refer in compliance with applicable reinforce a culture of integrity drafting documents for complex to listing under Rogers, AR, for laws, regulatory, and privacy imbued with ethical business health care transactions; Strong full description. requirements. Qualifications: principles and practices at command of regulations relating 10+ years of experience of MFA and its affiliated entities. to Medicare and Medicaid reim- Rogers, AR: Associate Counsel, direct compliance respon- The Chief Compliance Officer bursement, fraud and abuse, Mercy Hospital. Mercy is sibilities with an academic shall determine, prioritize, the federal Anti­-Kickback looking for a qualified and and research medical center. and address the MFA’s chief Statute, HIPAA and Stark; Prior talented Associate Counsel for An undergraduate degree in compliance risk areas, such experience in managing and its Rogers and Fort Smith, AR, accounting or a master’s degree as Medicare/Medicaid fraud mentoring junior attorneys. For communities. This Associate in business or health care and abuse issues, improper confidential consideration, apply Counsel will provide direct legal administration. Juris Doctorate or inadequate documentation directly to requisition #33070 at counsel and subject matter degree is preferred. To apply, and billing, HIPAA Privacy and jobs.ufhealth.org. Competitive expertise to multiple routine contact Meisha Parker by email Security standards, Foreign salary and benefits package functional areas and one or at [email protected] or Corrupt Practices Act, and offered, including relocation more complex functional areas. by phone at (323) 361- 7140. other rules and regulations assistance. Functional areas include a and ethical standards. Primary District of Columbia Rockledge, FL: Corporate broad range of legal areas Washington, DC: Vice President Contact: Peace Okoya, GW affecting Mercy’s services and Medical Faculty Associates, Director of Claims, Health and Assistant General Counsel, First. Engages all members operations such as antitrust, Advanced Medical Technology 2150 Pennsylvania Ave NW, tax, employment law, and Washington, DC 20037. in legal department and Risk Association. Under the direc- Management team. Works physician practice acquisitions; tion of the General Counsel, [email protected]. Phone: hospital operational support; (202) ­741­-3360; Fax: (202) closely/effectively with Risk serve as in-­house legal health care risk manage- counsel to the Association, ­741-­2276. ment; clinical ­related issues; (continued on page 44)

Additional Listings: May be found in our National Job Bank. Go to: www.healthlawyers.org/jobbank. Deadlines: Space reservations, copy, and payment are due on the 5th of the month prior to publishing. Copy for classifieds and contact information should be emailed in basic text format to hlclassifieds@ networkmediapartners.com. Payment information should also be included in the email. For a copy of our media kit or for information about Display, Classified, and Online advertising, contact: Evan Zippert, Network Media Partners, Phone: (410) 584-1992, Fax: (410) 584-1998, Email: healthlawyers@ networkmediapartners.com.

42 AHLA Connections June 2015

(continued from page 42) of these qualifications, please Requirements: Juris Doctorate representing health care submit your resume and tran- degree, current State of Illinois clients in transactional and/or Management, Corporate and script to Rochelle.weiner@dbr. licensure, and a minimum of regulatory matters to join our Defense Counsel, Department com. EOE. The submission of eight years of corporate legal health care practice in Topeka, Managers and Directors, Senior an unsolicited resume or other experience, which includes four Kansas. Candidates should Leadership and Executive candidate information by a third years of health care experience. have a deep understanding of Team, and is available to all party in response to this posting Visit our website to apply online fraud and abuse laws, reim- associates, patients, visitors, shall not constitute our consent via our careers page at http:// bursement issues (including Medical and Allied Health Staff or approval to such submission. emhccareers.org/job­search/ Medicare and Medicaid), as well for consultation on litigation search. as the Stark Law, and HIPAA/ and potential litigation issues/ Maywood, IL: Paralegal, Loyola HITECH. Candidates must concerns. Reports directly University Health System. Indiana also have excellent academic to the Senior VP Corporate Loyola University Health System Indianapolis, IN: Health Care credentials and strong writing Counsel. Develop familiarity with (LUHS) in Maywood, IL, is a Compliance Specialist/ and communication skills. This professional and general liability Magnet designated academic Attorney, Hall Render. Hall position is a partnership track insurance markets through medical center and member Render Killian Heath & Lyman position, and the candidate will frequent market contact and of Trinity Health. We are one is the nation’s largest law be expected to demonstrate attendance at meetings and of the nation’s premier medical firm focused exclusively the work ethic, client develop- marketing symposiums. Support centers focused on patient on health care organizations. ment skills, and entrepreneurial professional and general liability care, research, and education. We provide extensive counsel thinking of a partner. Candidates insurance coverage and risk Right now we have a daytime regarding health care compli- will be required to become financing. Manage professional opportunity for a Paralegal ance and payment practices. licensed in Kansas. To apply and general liability claims to report to the Senior Vice We are seeking a health care for this position, please visit the against all entities. Manage President and General Counsel. compliance professional with AHLA Career Center at www. subrogation claims on behalf Minimum requirements include experience as a Compliance healthlawyers.org. On the top of HFHP. Interface with legal an Associate’s degree and one Officer or in a similar support navigation bar, click on “Find a defense counsel. Works with or more years of relevant experi- role. Candidate must have Resource,” then select “Career state/national organizations, ence, preferably in a health care experience with developing Center.” legislative committees, inter- setting. A paralegal certificate is and maintaining compliance acting with legislatures to control also preferred. LUHS provides policies and procedures, Massachusetts development of adverse statu- competitive compensation providing education, responding Boston, MA: Research and tory requirements or inappro- with a comprehensive benefits to alleged violations and initi- Technology Attorney, Partners priate rule making. Manage day package and a number of ating investigations, performing Healthcare. The Office of the to day litigation related matters, amenities to ensure a quality audits, identifying areas of General Counsel is seeking including discovery, technology working experience. Please risks, and preparing correc- an attorney with six to eight services, facilitate preserva- apply via the following link, tive action plans. Knowledge (6-8) years of experience for tion, collection and retention of and please note that we can of Federal payment systems a position in its Research electronic and/or paper informa- respond only to those candi- and reimbursement is benefi- and Technology Section. The tion as it pertains to litigation. dates most closely meeting cial. Candidates should have primary areas of responsibility Support Risk Management. To our qualifications: http://bit. two to five (2-5) years’ experi- are human subject research; apply for this position, please ly/1xwoJzP. EOE. ence in health care compliance, privacy and issues relating to visit the AHLA Career Center at with a J.D. and CIA and/or CHC research data, and the sharing certification preferred. Preferred of such data for research www.healthlawyers.org. On the Naperville, IL: Associate top navigation bar, click on “Find General Counsel, Edward- office location is Indianapolis, IN. collaboration, benchmarking, a Resource,” then select “Career Elmhurst Healthcare System Travel is required. Please submit quality improvement and other Center.” (EEH). Edward­-Elmhurst resume and letter of interest purposes; regulatory oversight Healthcare, one of the larger to: https://home.eease.adp. of human subject research, Illinois com/recruit/?id=13276541. Hall including OHRP, FDA and HIPAA Chicago, IL: Health Care health systems servicing the west and southwest suburbs Render Killian Heath & Lyman is regulations. Experience in some Associate, Drinker Biddle & an equal opportunity employer. or all of the foregoing areas is Reath LLP. The Health Care of Chicagoland, is seeking an Associate General Counsel. No phone calls please. a prerequisite; experience in Group seeks to hire a third- to other related areas, including fifth-year associate to work in Responsible for preparing and Iowa reviewing contracts and legal scientific research in academic the Chicago office. A substan- Des Moines, IA: Medicare settings, technology transfer, tive background in the legal documents on a wide variety Compliance Implementation of matters; Represents EEH and intellectual property, or in issues pertaining to provider Manager, Physicians Plus the health care department of health care organizations, such before legal forums, including Insurance Corporation. Refer to governmental and regulatory a law office representing large as the Stark Law, Medicare and listing under Madison, WI, for full organizations, is preferred. Medicaid reimbursement, and agencies, courts and arbitration description. bodies, under limited direction; The office is a full service law health care regulatory compli- Kansas department providing legal ance, and significant trans- Serves as key legal advisor on major business transactions; Topeka, KS: Healthcare Associate services to Partners Healthcare actional experience involving – Partnership Track Position, and its affiliates, including health care organizations, is Negotiates business agree- ments and provides legal advice Foulston Siefkin LLP. Foulston Brigham and Women’s Hospital required. Drinker Biddle’s Health Siefkin’s health care team and Massachusetts General Law Practice has represented to EEH Boards of Directors and to Senior Staff; Manages EEH’s represents a diverse group of Hospital. Applicants should the health care industry for health care clients, both in the send a resume and cover letter more than 90 years, and outside legal assistance and assists EEH in the development State of Kansas and across the to PHSOGCRecruitment@ currently maintains one of the United States. We are looking partners.org. largest national practices in the of its business and policy initia- tives; Ensures EEH conducts its for an entrepreneurial, hard­ representation of health care working attorney with six to organizations. If you meet all business in compliance with all applicable laws and regulations. ten (6­-10) years of experience

44 AHLA Connections June 2015 Watertown, MA: Senior Corporate to assist the Executive Vice abuse. Bachelor’s degree in and specialty areas of behavioral Counsel, athenahealth. This President and General Counsel health care administration, busi- health, developmental disabili- is a great opportunity to join a in overseeing the Office of ness administration or a related ties and other long term services busy legal team in a dynamic Legal Affairs and providing legal field; MBA or JD preferred; five and supports areas. To apply, and fast‐growing health advice to senior management (5) years Medicaid experience email your resume to employ- care information technology and various departments. To required; 10+ years of progres- [email protected]. company. The Senior Corporate apply, email credentials to Adam sive management experience. Counsel will report to the Stern at info@executivehealth- Email resume to Laura Stanley, Pennsylvania company’s Assistant General search.com. HR Consultant, laura.stanley@ Harrisburg, PA: Government Counsel (Commercial) at its dhhs.nc.gov. Programs Compliance headquarters in Watertown, MA. North Carolina Officer, Capital BlueCross. Senior Staff The Government Programs Responsibilities may include, but Chapel Hill, NC: Raleigh, NC: Chief Compliance are not limited to: Drafting and Attorney, UNC Health Care. This & Privacy Officer, WakeMed Compliance Officer is respon- negotiating sales, vendor and staff attorney position reports Health & Hospitals. The Chief sible for general oversight of all other commercial agreements; to the Senior Vice President Compliance & Privacy Officer activities related to the govern- Playing an integral role in the and General Counsel for the is responsible for supporting ment programs (i.e., PPACA, company’s vendor management UNC Health Care System a culture consistent with Medicaid Expansion, CHIP, program; Working closely with (UNCHCS). In this in-house WakeMed’s mission, values, and FEP etc.) lines of business at management and business part- counsel role, the attorney will be code of conduct by planning, Capital BlueCross, excluding ners on a variety of agreements; responsible for providing legal designing, implementing and Medicare. The Government Issues impacting a rapidly advice and services in support maintaining compliance and Programs Compliance Officer growing health care IT company; of the operations of UNCHCS privacy programs, policies, and is responsible for developing, Other general legal matters to and its affiliated hospitals and procedures for the purpose of implementing, and monitoring be assigned as company needs entities. This attorney will be ensuring organizational reporting the Government Compliance warrant. Please visit www.athe- working primarily in support of integrity and compliance effec- Program at the Company to nahealth.com/careers to apply. UNCHCS’ affiliate High Point tiveness. The Chief Compliance ensure compliance with all Regional Health located in High & Privacy Officer helps ensure applicable rules and regula- Michigan Point, NC, and generally will be adequate internal controls are tions relating to the Company’s Beverly Hills, MI: Director of Legal expected to spend time each maintained through reviews government programs opera- & Compliance, Confidential. week in both High Point (at High of existing and proposed tions. JD required, five to Develops, initiates, main- Point Regional) and Chapel Hill processes and that WakeMed seven (5­-7) year’s health plan tains, and revises policies and (at the UNCHCS legal office at staff and physicians perform or state or federal government procedures for the general the Medical Center). Learn more in compliance with applicable experience required, including operation of the Compliance & apply at unchealthcare.org/ laws, regulatory, and privacy management experience Apply Program and its related jobs. requirements. Reports to the at www.CapBlueCross.com. activities to prevent illegal, Board of Directors with a dotted unethical, or improper conduct. High Point, NC: Senior Staff line relationship to the CEO. Mechanicsburg, PA: Health Care Manages day-­to-­day opera- Attorney, UNC Health Care. MBA or relevant Master’s degree Operations Attorney, Select tion of the Program. Develops Refer to listing under Chapel Hill, required. Certified in Health Care Medical. Select Medical is and periodically reviews and NC, for full description. Compliance (CHC) or Certified in seeking a health care opera- updates Standards of Conduct Health Care Privacy Compliance tions ATTORNEY to join the to ensure continuing currency Raleigh, NC: Director of (CHPC) required. JD strongly legal team at Select’s corporate and relevance in providing Compliance, North Carolina preferred. At least 10 years of office in Mechanicsburg, PA. guidance to management Department of Health and compliance, legal, financial and/ The health care operations and employees. Collaborates Human Services - Division of or audit leadership experience in ATTORNEY will provide general with other departments Medical Assistance. NC DHHS a health care setting, as well as legal advice, guidance and (e.g., Medical Management, provides essential human demonstrated understanding of representation to the company’s Corporate Services, Information services to North Carolinians. effective Corporate Compliance affiliated health care operations Technology, etc.) to direct The Division of Medical & Privacy programs. To apply, on a variety of complex legal compliance issues to appro- Assistance arranges and reim- visit www.wakemed.org/landing. and operational issues. Ideal priate existing channels for burses for health care services cfm?id=563. candidate will have a strong investigation and resolution. for the most vulnerable North academic background, good Consults with the counsel as Carolina residents. The Director Ohio interpersonal skills, excellent needed to resolve difficult legal of Compliance is an Executive Columbus, OH: Senior Advisor – oral and written communica- compliance issues. Responds to position responsible for the Health Care Policy, Vorys Health tion skills, a minimum of 3 years alleged violations of rules, regu- administration of an effective Care Advisors LLC. Vorys Health professional legal experience in lations, policies, procedures, compliance program for DMA, Care Advisors is searching for a private legal practice, and the and Standards of Conduct by including detection of fraud, a Senior Advisor ­Health Care ability to collaborate and inter- evaluating or recommending the waste, and abuse. The Director Policy, who will advise clients face in a complex, fast paced, initiation of investigative proce- of Compliance is responsible for regarding health care policy high growth environment. Health dures. Develops and oversees a providing direction and overall issues, with a solution oriented care law experience is preferred. system for uniform handling of management for the compli- perspective. Common client Some travel is required. such violations. To apply, email ance team that is comprised of priorities include a wide variety Interested candidates should [email protected]. HIPAA and Program Integrity. of state, federal health care send resume to: Anne Franklin The compliance group has a and Medicaid policy, including at [email protected]. New York team of over 60 employees and benefit package design, home Brooklyn, NY: Associate General other supplemental staff. The and community based services Southeastern, PA: In-House/ Counsel, Confidential. Hospital compliance group is respon- waivers, provider requirements, Health care, Confidential. Large, in Brooklyn, NY, is seeking an sible for HIPAA oversight and reimbursement methodologies, public specialty health care Associate General Counsel identifying fraud, waste, and including hospital, physician, company seeks a health care

healthlawyers.org 45 lawyer with five or more (5+) practices; Receive compliance in procurement transactions Legal department team. This years’ experience gained at complaints regarding EHS poli- (materials and services acquisi- individual will play a critical role either a law firm or in-house. cies and notices, and oversee tion) and other transactional in executing Evolent Health’s This candidate must have a patient and workforce compli- matters. Experience inter- mission by leading initiatives to significant amount of experi- ance; Assist EHS SVP /CCO acting and communicating support effective and compliant ence in one of the following with investigations and assess- with a wide range of corporate health plan operations on behalf two areas: 1) providing legal ments, and provide reports on roles, including executives. of clients. This role reports to support on a broad range of related incidents to the ECC, Experience in health care goods General Counsel. This position regulatory health care matters, leadership, and EHS Attorney(s). and services acquisitions, is located in the Washington, such as licensure, survey and To apply for this position, please and familiarity with nonprofit DC, Metro area. To apply for certification, Medicare/Medicaid visit the AHLA Career Center corporation and health care this position, please visit the regulations, fraud and abuse, at www.healthlawyers.org. On laws and regulations preferred. AHLA Career Center at www. physician credentialing and the top navigation bar, click on CERTIFICATES, LICENSES AND healthlawyers.org. On the top guardianship matters; or 2) “Find a Resource,” then select REGISTRATIONS REQUIRED: navigation bar, click on “Find a representing a client or organi- “Career Center.” Member of Texas Bar in good Resource,” then select “Career zation in relations with state and standing; current licensure in Center.” federal bureaus, departments or Nashville, TN: Operations Texas required. To apply for agencies. In addition to working Counsel, Ardent Health this position, please visit the Lynchburg, VA: PCHP Corporate in these two areas, the lawyer Services. We are seeking AHLA Career Center at www. Counsel, Centra Health PCHP. will handle contracts, regulatory an Operations Counsel to healthlawyers.org. On the top Required Qualifications: due diligence and approvals, prepare and review a variety of navigation bar, click on “Find a Admitted to practice law as training, and management of complex contracts and provide Resource,” then select “Career Corporate Counsel in the outside counsel. The lawyer to legal counsel, guidance and Center.” Commonwealth of Virginia; whom this position reports is representation to the company Strong knowledge of health care a terrific mentor, and the law and its affiliated health care Vermont laws and regulations, including department has an open door, operations on complex legal Burlington, VT: Associate General the Affordable Care Act and approachable, friendly culture and operational issues. Also Counsel, The University of its implementing regulations, that is regarded highly by the supervise litigation, investiga- Vermont Medical Center. The HIPAA, Virginia laws and regula- business clients. Relocation tions and outside counsel. University of Vermont Medical tions, Medicare, Medicaid, the assistance provided. To apply Education: Must be an attorney Center in Burlington, VT, has Stark law, the False Claims Act, for this position, please visit the with a Juris Doctor (JD) degree an opening for an Associate and the Federal Anti­-Kickback AHLA Career Center at www. from an accredited law school, General Counsel. We are a Level Statute; Excellent organizational healthlawyers.org. On the top and current license to practice I Adult and Pediatric Trauma and analytical skills, and strong navigation bar, click on “Find a law. Experience: Must have a Center serving a population of legal project management skills; Resource,” then select “Career minimum of seven (7) years’ one million throughout Vermont Strong interpersonal skills, Center.” experience in health care law and Northern New York. With sound judgment, excellent including, but not limited to, more than 7,000 employees, we oral and written communica- Tennessee EMTALA, HIPAA, Stark, ACA, are the largest private employer tion skills, and an adaptable, Chattanooga, TN: Director, fraud and abuse, health care in the state of Vermont. Position cooperative approach to Corporate Compliance; regulatory compliance, and Summary: The Associate problems. Demonstrated ability Erlanger Health System (EHS). hospital operations. Previous General Counsel provides to work both independently and Requirements: Baccalaureate law firm experience a plus. legal advice and counsel to collaboratively, provide leader- Degree in Business, health-­ Contact: Stephen Wilder, (615) the University of Vermont ship, influence organizational related field, or legal training. ­296­-3213; stephen.wilder@ Medical Center and its affiliated behavior, and create alignment Certification in Compliance; ardenthealth.com; www.arden- hospitals under the direction across disparate groups. Ability Minimum five to ten (5-10) thealth.com. of the Director of Legal Affairs. to provide practical and sound years of experience in hospital For More Information: To apply, advice to internal clients on or health care setting. The Texas please use our online applica- legal issues related to busi- Corporate Compliance Director Houston, TX: Director, Legal tion system at www.uvmhealth. ness objectives and an active will perform the following Services, Contracts; Houston org/medcenter/Pages/Health- role in driving projects to final tasks: Work to support the Methodist Hospital. To provide careers, posting #26409. We result. Strong work ethic and EHS SVP/ Chief Compliance legal counsel and guidance to offer a comprehensive benefits the ability to manage multiple Office (CCO) and leadership Houston Methodist and its affili- package, including relocation. tasks at once in a fast­-paced, team in their efforts to imple- ates (collectively “Methodist”) We proudly offer a nonsmoking performance­-driven culture. To ment the EHS Corporate Wide in the routine and special work environment. The UVM apply for this position, please Compliance Program (Program) activities of Methodist entities, Medical Center is an Equal visit the AHLA Career Center elements; develop, opera- including transactional and Opportunity/Affirmative Action at www.healthlawyers.org. On tionalize and administer the vendor relationship matters, Employer. All qualified applicants the top navigation bar, click on Program; gather information, in order to ensure protection will receive consideration for “Find a Resource,” then select maintain documentation and of legal rights, to operate in employment without regard to “Career Center.” provide educational programs; accordance with the law, and race, color, religion, sex, national perform policy management/ to support the fulfillment of the origin, disability, or protective Wisconsin enforcement, investigations/ Methodist’s Mission, Values and veteran status. Madison, WI: Medicare reviews, and provide Program Belief Statements. EDUCATION Compliance Implementation leadership; monitor Program REQUIREMENTS: Juris Virginia Manager, Physicians Plus Managing Director, activities and performance, and Doctorate (JD) degree required. Arlington, VA: Insurance Corporation. Compliance; Evolent Health. report outcomes to the ECC EXPERIENCE REQUIREMENTS: Physicians Plus Insurance Evolent Health is looking leadership; oversee and ensure Long-­term, substantial legal Corporation, a nationally for a Managing Director of EHS progress in implementing experience in­-house, or in a accredited managed care Compliance to be a key and complying with system­- law firm setting, with signifi- organization, has a Medicare member of the Compliance and -wide compliance policies and cant transactional experience Compliance Implementation

46 AHLA Connections June 2015 Manager position available in Medicare Part C and Part D experience in health insurance, applicable to MA­PD programs. Madison, WI, or Des Moines, lines of business (MA­PD). The or managed care compliance or For more information, visit: IA. The Manager is respon- qualified applicant will have a regulatory affairs; three or more www.pplusic.com/careers. sible for the development and Bachelor’s Degree (graduate (3+) years of supervisory experi- EEO/AA Employer: Minorities/ implementation of the Medicare degree in law, health adminis- ence; experience working with Females/Veterans/Disabled. Advantage (MA) Compliance tration, accounting, or related regulatory agencies; knowledge Program. The MA Compliance field is preferred), and five or of Medicare and federal health Program encompasses the more (5+) years of progressive care laws and CMS policies Advertising Index Burroughs Health Care Consulting Network 25 Moss Adams 35 Coding Compliance Solutions 37 Ntracts 39 Crowell and Moring 25 Polsinelli PC 9 Greeley Company 7 Principle Valuation Back Cover Hall Render Killian Heath & Lyman PC Inside Back Cover PYA 43 HealthPort 41 SAI Global Inside Front Cover Husch Blackwell 37 Sheppard Mullin 27 K & L Gates 3 Shipman and Goodwin LLP 19 LW Consulting Inc 39 Squire Patton Boggs 5

AHLA would like to thank our members from the following law firms for their generous sponsorship of the Monday, June 29 evening reception at the National Air and Space Museum: ❯❯ Akin Gump Strauss Hauer & Feld LLP ❯❯ Kelly Law Firm PC ❯❯ Baird Holm ❯❯ King & Spalding LLP ❯❯ Baker & Hostetler LLP ❯❯ Krieg DeVault LLP ❯❯ Baker Donelson Bearman Caldwell & Berkowitz PC ❯❯ Lane Powell PC ❯❯ Bass Berry & Sims PLC ❯❯ LeClairRyan ❯❯ Benesch Friedlander Coplan & Aronoff LLP ❯❯ Liss & Lamar PC ❯❯ The Bittinger Law Firm ❯❯ Locke Lord LLP ❯❯ Blanchard Manning LLP ❯❯ Manatt Phelps & Phillips LLP ❯❯ Broad and Cassel ❯❯ McDermott Will & Emery LLP ❯❯ Bradley Arant Boult Cummings LLP ❯❯ Mintz Levin Cohn Ferris Glovsky and Popeo PC ❯❯ Bricker & Eckler LLP ❯❯ Morgan Lewis & Bockius LLP ❯❯ Buchanan Ingersoll & Rooney PC ❯❯ Nixon Peabody LLP ❯❯ Cadwalader Wickersham & Taft LLP ❯❯ OBER | KALER ❯❯ Clark Hill PLC ❯❯ Ogletree Deakins Nash Smoak & Stewart PC ❯❯ Conner & Winters LLP ❯❯ O’Melveny & Myers LLP ❯❯ Coppersmith Brockelman PLC ❯❯ Pillsbury Winthrop Shaw Pittman LLP ❯❯ Crowell & Moring LLP ❯❯ Polsinelli PC ❯❯ Davis Wright Tremaine LLP ❯❯ Post & Schell PC ❯❯ Dentons US LLP ❯❯ Proskauer ❯❯ Drinker Biddle & Reath LLP ❯❯ Reed Smith LLP ❯❯ Epstein Becker & Green PC ❯❯ Ropes & Gray LLP ❯❯ Godfrey & Kahn SC ❯❯ Shipman & Goodwin LLP ❯❯ Greenberg Traurig LLP ❯❯ Skadden Arps Slate Meagher & Flom LLP ❯❯ Hall Render Killian Heath & Lyman PC ❯❯ Smith Moore Leatherwood LLP ❯❯ Hooper Lundy & Bookman Inc. ❯❯ Squire Patton Boggs (US) LLP ❯❯ Husch Blackwell LLP ❯❯ Waller Lansden Dortch & Davis LLP ❯❯ Jones Day ❯❯ Wilentz Goldman & Spitzer PA ❯❯ K&L Gates LLP ❯❯ Wiley Rein LLP ❯❯ Katten Muchin Rosenman LLP

Annual Membership Meeting of the American Health Lawyers Association Monday, June 29, 2015 | Washington Marriott Marquis (Marquis Ballroom) | Washington, DC Time: 8-8:15 am (prior to the General Session of AHLA’s Annual Meeting)

healthlawyers.org 47 (continued from page 1) AHLA leaders are not immune to this Be a life-long criticism. With so many members asking 10 learner. Identify problems early and how they can get involved in the work of As the JFK quote at the beginning of 7 have a plan to solve them. AHLA, anyone who leads this organiza- this column states, leadership and Just as there are no perfect people; tion should strive to define what needs to learning are inextricably interwoven. there are no perfect associations. I can be done and who should do it. Other- One characteristic that I have found in argue that AHLA is as effective and as wise, some of our best ideas will wither all great leaders is a fascination with respected a legal organization as one and die. subjects outside their field of expertise. can join, but I also acknowledge that They engage in daily learning through we live in changeable, uncertain times. You never go wrong books, audio, online forums, coaching, How businesses function, how people 9 doing the right thing. mentoring, and most importantly asking communicate, and how legal services are America’s pluralistic society makes it many questions. They listen more than delivered will continue to evolve faster hard to express opinions that presup- they speak, but when they speak, they do than any professional society’s ability to pose a universal set of values or prin- so as much from the heart as the head. adapt. That’s why the AHLA board has ciples. Under the watchful eyes of social Anyone who wishes to lead a commu- traditionally engaged in periodic stra- media and 24-hour news cycles, any nity of smart, energetic people like the tegic planning and even now is consid- decision a person makes will inevitably AHLA should prepare for leadership by ering shortening the planning cycle from be subjected to second-guessing and continually experiencing the excitement five to three years. We hope to put the sometimes ridicule. However, an AHLA of learning new things. finishing touches on a new strategic plan leader should never shrink from doing at the Annual Meeting in Washington at the right thing. Hot topics in health law Let no one reading this, my final First the end of June. come and go, but people long remember Reflections, conclude that its author has whether they were treated respectfully, fully learned these lessons. I am only Make follow-up spoken to honestly, and given a fair grateful for having had a brief oppor- 8 actionable. chance. Doing the right thing requires tunity to serve as your president and Lawyers and health professionals are both courage and compassion. Those experience first-hand the dedication and extremely good at making lists (yes, this traits tend to be missing in people who resourcefulness of AHLA’s members, column is just another one of those). seek leadership roles for the wrong leaders, and staff. Thank you for giving On the other hand, what happens after reasons. me that chance. a business meeting often lacks clear action steps and a table of responsibility?

PETER A. PAVARINI President, FY 2015 [email protected]

48 AHLA Connections June 2015

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