Industries & Practices



    We are well versed in Medicare hospice program requirements.

    Many of our attorneys bring firsthand regulatory and compliance experience to their understanding of the unique and complex policy, regulatory and business issues faced by hospice providers. We routinely advise clients on the Medicare Conditions of Participation and other federal and state requirements that impact hospice operations.

    We provide practical guidance on compliance practices and regulatory pitfalls.

    • Development and implementation of corporate compliance programs
    • HIPAA data privacy and security, including breach investigations and remediation
    • Hospice quality reporting requirements
    • Compliance issues related to hospice marketing, sales strategy and joint branding
    • Tax-exempt status requirements
    • Self-disclosures and adherence to the applicable protocol for notifying the appropriate governmental, oversight or accreditation agency about an issue of potential noncompliance

    We counsel clients on how to comply with federal and state regulations governing hospice providers.

    • Medicare and Medicaid certification, licensure and standards of care
    • Medicare, Medicaid and third party billing, collections and accounts receivable regulations
    • Fraud and abuse investigations
    • Federal and state anti-kickback statutes and Stark laws
    • Self-reporting overpayments and regulatory violations to government agencies

    Hospice providers of all types depend on us to help them structure transactions that are consistent with their business strategies and in alignment with state and federal regulations.

    • Mergers, acquisitions and joint ventures
    • Medical director and employed physician contracts and governance documents
    • Operational policies and procedures
    • Membership substitutions
    • Evaluation of purchases of home health agencies
    • Capital financing, including taxable and tax-exempt revenue bond and HUD loans
    • Structuring arrangements with skilled nursing facilities including allocation of staffing resources, contractual requirements and Joint Commission requirements