Sarah Blumenthal joined Ropes & Gray in 2011 as an associate in the corporate department. Sarah is part of firm’s health care group and provides regulatory, transactional and compliance advice to clients throughout the health care industry, including hospitals and health systems; universities and medical schools; and pharmaceutical, biologic and medical device companies. Sarah advises clients on a variety of matters including corporate structure and governance, university-hospital relationships, privacy and data security, government enforcement, and government and third-party payment.
- Academic Medical Centers. Counsels universities, medical schools, hospitals and faculty practice plans on matters unique to academic medical centers including university/medical school and hospital affiliations, governance and corporate matters, accreditation (including university accreditation, medical school accreditation, and graduate medical education accreditation), and faculty relationships. In particular, Sarah advised a large health system on a novel relationship with a university to operate an independent medical school.
- Health Information Privacy and Security. Advises clients throughout the health care spectrum on applicability of, and compliance with, health information privacy and security laws. In particular, Sarah counseled a large health system on health information privacy and security matters in connection with a U.S. Health & Human Services Department Office for Civil Rights compliance review, including advice on compliance with HIPAA’s breach notification obligations.
- Delivery System and Payment Reform. Sarah has assisted in the formation of and advises multiple accountable care organizations participating in the Medicare Shared Savings Program and other accountable care initiatives.
- Third-Party Payment. Advises health care provider clients in connection with Medicare audits of payment and billing practices. In particular, Sarah advised a health system in connection with a self audit and voluntary disclosure of potentially improper billing in connection with short stay inpatient hospitalizations.
- Pro Bono. Among other pro bono matters, Sarah advised a legal services organization on health information privacy and security matters related to the operation of a medical-legal partnership and certain return on investment research related to the partnership.
- Co-Author, “Inside the HHS Guidance on Ransomware,” Law360 (July 29, 2016)
- Co-Author, "Implications of the Federal Physician Payments Sunshine Act for Clinical Research," Bloomberg BNA Medical Research Law & Policy Report (November 21, 2012)