Skip to Main Content

As the healthcare industry continues to see unprecedented regulation, we work to keep our clients out of the headlines and in compliance with today’s regulatory and statutory requirements, including the federal Physician Self-Referral Law (Stark Law), the federal Anti-Kickback Statute, state “mini” Stark and anti-kickback statutes, as well as the Federal False Claims Act, and the Emergency Medical Treatment and Labor Act (EMTALA), among others.

Healthcare providers regularly engage in business arrangements that may implicate the fraud and abuse laws. BakerHostetler has experience in the breadth of fraud and abuse matters, from analyzing a potential new business arrangement to reviewing ongoing compliance and assisting clients with handling a self-disclosure or government investigation. We understand that our clients are facing increased pressures from various enforcement agencies, and we help them navigate the expectation of self-governance in the increasingly regulated and complex healthcare environment. Our clients include hospitals and health systems, physician groups, laboratories, imaging centers and post-acute care providers, such as skilled nursing facilities, inpatient rehabilitation facilities and home health agencies.


  • Represent various healthcare entities in the development and implementation of corporate compliance plans, including plan design, risk assessments, internal reviews, self-audits, voluntary disclosures and repayments to governmental and private health programs.
  • Provide general Stark Law, anti-kickback and fraud and abuse advice to hospitals and other healthcare providers regarding structuring compliant relationships with physicians and other referral sources, including contractual relationships such as leases and employment and medical director agreements.
  • Represent providers in self-disclosures related to overpayments and Stark Law violations.
  • Assist in internal and external investigations and regulatory compliance activities related to reimbursement, including evaluation and management coding, supervision and coverage requirements related to ancillary services and midlevel providers, and Stark Law and state anti-kickback laws.
  • Provide general fraud and abuse advice to healthcare providers regarding structuring compliant relationships with beneficiaries relating to various issues, including providing discount cards and complementary local transportation, conducting health fairs, and deductible and copayment issues.
  • Represent hospitals and physicians in compliance matters related to illegal remuneration, Stark Law and Civil Monetary Penalties Law issues.
  • Provide compliance training on fraud and abuse laws, policies and procedures, and medical record documentation.

Featured Insights