Sarah practices in the firm's health care and higher education groups, providing strategic, transactional, and regulatory counsel to hospitals, health systems, universities, medical schools, and human services providers across a broad range of specialties.
She advises clients on complex strategic transactions, including mergers, acquisitions, affiliations, and joint ventures, guiding them through transaction structuring, governance, and the federal and state regulatory frameworks applicable to both health care and higher education institutions.
Sarah has deep knowledge of health care and higher education regulations, including institutional and programmatic accreditation standards, federal and state fraud and abuse laws, information privacy and security, value-based payment models, and integrated delivery systems. She also counsels health care providers, human services organizations, and health care investors on regulatory complexities such as the corporate practice of medicine, the Anti-Kickback Statute, the Stark Law, federal and state reimbursement requirements, and specialty state licensing.
Experience
- Health System Transactions. Advised large health system on acquiring a financially challenged hospital, structuring the transaction and navigating complex state regulatory review and approval requirements.
- Academic Medical Centers. Advised state university with multiple medical schools on affiliating with a health system, including unifying the faculty physician practice with the health system's clinical enterprise.
- School of Medicine Formation. Advised health system on forming a new medical school in collaboration with a university, structuring the institution to satisfy accreditation and regulatory requirements.
- School of Medicine Spinout. Advised health system on spinning out a medical school from a university and establishing the school as a standalone institution under a joint governance structure.
- University Acquisitions. Guided large state university through acquiring a smaller private college, including the accreditation substantive change process and two-step U.S. Department of Education change-in-ownership process.
- Investment in Higher Education. Advised private equity firm on investing in an institution of higher education, including regulatory due diligence and accreditor approval applications.
- Human Services Regulatory Advice. Advised New York human services providers on reimbursement audits and reviews, including responses to the New York State Office of the Medicaid Inspector General, self-disclosures, and corrective action plans.
- Accountable Care Organizations and Integrated Care Models. Advised primary care and behavioral health provider on affiliating with Medicare-participating ACOs and forming its own ACOs under the Medicare Shared Savings Program and CMS Innovation Center pilot programs.
- Clinical Joint Ventures. Advised health system on specialty joint ventures, including establishing microhospitals, ambulatory surgery centers, and a radiation oncology facility.
- Physician Practice Structures. Advised large multi-specialty physician practice on corporate practice of medicine compliance and restructuring to affiliate with a non-clinical services organization.
- Health Information Privacy and Security. Guided client through multiple successive HIPAA breaches, including OCR reporting, corrective action plan implementation, and ongoing monitoring and reporting.
- Pro Bono. Assisted legal services organization on health information privacy and security matters related to operating a medical-legal partnership and conducting associated return-on-investment research.