Tom is nationally recognized for his work defending health care clients against anti-kickback, Stark Law, false claims, and whistleblower allegations. His work includes litigation, internal investigations, corporate integrity agreements, and self-disclosures. Tom also counsels clients on the legal, practical, and fraud and abuse implications of business arrangements and sales and marketing practices. Additionally, Tom has worked with several academic medical center clients in restructuring arrangements among medical school, teaching hospital, and faculty physicians. Tom gained national recognition for his work on the anti-kickback statute during his tenure at the HHS Office of Inspector General, where he prosecuted the Hanlester Network case and was the principal author of the 1991 safe harbor regulations. He is an elected Fellow of the American Health Lawyers Association.
Tom is nationally recognized for his experience with fraud and abuse. Practicing in Boston and Washington, DC, he advises national and local clients on structuring complex strategic affiliation arrangements and transactions to comply with the applicable fraud and abuse laws as well as the variety of other regulatory requirements to meet today’s health reform challenges. His work in defending clients against anti-kickback, Stark Law, false claims, and whistleblower allegations includes litigation, internal investigations, self-disclosures, and negotiating settlements and Corporate Integrity Agreements (CIAs).
He has appeared before numerous US attorneys’ offices, the FBI, and the Office of Inspector General (OIG) and Centers for Medicare & Medicaid Services (CMS) around the country and in Washington. In addition, he has served as an expert witness and consulting expert in health care fraud cases.
In addition to his fraud and abuse defense work, Tom advises clients on the legal, practical, and fraud and abuse implications of business arrangements and sales and marketing practices. This part of his practice focuses on Medicare and Medicaid fraud and abuse compliance and reimbursement issues and related laws, including the federal Physician Payments Sunshine Act, ‘meaningful use’ of EHR technology, under arrangement and provider-based rules, and OIG issues.
Tom has implemented and audited comprehensive corporate compliance programs for clients in various health care sectors.
His clients have included hospital systems and executives, medical device and pharmaceutical manufacturers, pharmacies and pharmacy benefit management companies, physicians and groups, renal dialysis providers, supply companies, home care providers as well as national and state trade groups.
He became nationally known for his work on the anti-kickback statute during his tenure at the Office of Inspector General at the Department of Health and Human Services in Washington, DC. In particular, Tom gained recognition as a prosecutor in the Hanlester Network joint venture case and as the principal author of the 1991 safe harbor regulations.
More Legal and Business Bylines From Thomas S. Crane
- A Review of the Affordable Care Act at 10 Years - (Posted On Tuesday, April 07, 2020)
- Divided Supreme Court Cuts Back Doctrine of Judicial Auer Deference to Agency Interpretations of Its Own Ambiguous Rules - (Posted On Tuesday, July 02, 2019)
- Azar v. Allina: Supreme Court Decides Important Case on When CMS Must Use Formal Rulemaking when Instructing Medicare Contractors - (Posted On Monday, June 17, 2019)
- Supreme Court Decides Important Case on When CMS Must Use Formal Rulemaking when Instructing Medicare Contractors - (Posted On Tuesday, June 04, 2019)
- Promise to Repeal the ACA Poses Threat to MACRA Implementation - (Posted On Monday, November 21, 2016)
- CMS Releases MACRA Final Rule, Easing 2017 Reporting Requirements - (Posted On Tuesday, October 18, 2016)
- Alternative Payment Models (APMs) Under MACRA Proposed Rule - (Posted On Friday, May 06, 2016)
- CMS Proposes “Advancing Care Information” Program to Replace Meaningful Use - (Posted On Thursday, May 05, 2016)
- CMS Releases Proposed Rule for MACRA Implementation – Overview and Merit-Based Incentive Payment Systems (MIPS) - (Posted On Tuesday, May 03, 2016)
- Justices Grapple with Limits of False Claims Act Liability in Implied Certification Cases - (Posted On Tuesday, April 26, 2016)