Sarah E. Swank

As a former senior in-house counsel for two national health care systems, Sarah Swank provides strategic, regulatory and operational advice to health systems, hospitals and academic medical centers, as well as large national and regional physician organizations and telehealth and other startups.

What do you focus on?

Accountable Care Organizations, Clinical Integration and Managed Care

I provide strategic advice to executive leadership at health systems, hospitals, academic medical centers, long-term care and large physician organizations. I advise clients regarding accountable care organizations (ACOs) and clinically integrated networks through all stages of development, including application into the Medicare Shared Savings Program. I assist with innovative approaches to pay-for-performance, managed care contracting, care coordination and population health. My experience includes ACOs with multiple hospital systems, physician owned, joint venture models, medical faculty entities, Federally Qualified Health Centers, children’s hospitals, health information exchanges, long-term care and hospital-owned health plans.

Digital Health, Telehealth and HIPAA

I counsel major academic medical centers, nationally recognized health systems and ACOs in launching and growing complex operational programs, such as national and international telehealth and digital health programs. I work directly with in-house counsel and senior and clinical leadership on strategic development and implementation of telehealth and e-health programs. Additionally, I assist technology startups with regulatory and corporate advice, including HIPAA compliance. I recently assisted an internationally known academic medical center with planning, implementation and advice regarding telemedicine credentialing, governance, operational, HIPAA and fraud and abuse matters. My background includes advising academic medical centers on international second opinion programs and strategic planning regarding programmatic international expansion. I have first-hand experience managing these issues as in-house counsel.

Fraud and Abuse and Compliance

My fraud and abuse background focuses on advice and guidance under Stark, the Anti-Kickback Statute, Civil Monetary Penalties and the False Claims Act related to physician transactions, compliance programs, graduate medical education, clinical research, medical director and other physician arrangements, investigations and compliance efforts after a corporate integrity agreement (CIA). I integrate operational issues with technical analysis of the fraud and abuse laws to suggest practical solutions. My experience includes acting as fraud and abuse counsel during negotiations with the DOJ on Stark and medical necessity, assisting with structuring physician arrangements and transactions, conducting internal investigations and advising regarding CIA implementation post-settlement.

Clinical Research and IRBs

My work in the area of clinical research and institutional review boards (IRBs) includes due diligence reviews during hospital mergers, FDA audits, reporting, program evaluation and compliance of IRB and research programs for academic medical centers and community hospitals. I successfully prepare and advise clients during FDA audits, assist with the integration of research activities into compliance programs and electronic health records and digital implementation, perform HIPAA compliance assessments and provide training and education to IRBs.

What do you see on the horizon?

I understand the pressures of general counsel who face increased budgetary demands and the need to adapt to changes in the health care industry. As we move toward pay-for-performance arrangements, care coordination and digital health solutions, my prior experiences provide valuable insight into where the health care industry is heading both nationally and internationally.


  • “Artificial intelligence and the legal implications, safety considerations and opportunities for utilizing AI and telehealth in the health care industry,” 2019 Telehealth Law & Policy Forum, September 5, 2019 (Panelist)
  • “The General Counsel Series Part III—Law Department Management Best Practices,” Webinar, American Health Lawyers Association, June 20, 2019 (Moderator)
  • “The General Counsel Series Part II—Contract Management,” Webinar, American Health Lawyers Association, May 16, 2019 (Moderator).


Sarah E. Swank


Washington, DC

Phone: 202-585-8500

Fax: 833-695-6391

Villanova University School of Law, J.D., cum laude

Skidmore College, B.A., cum laude

District of Columbia


New York


  • Vice Chair of Education, In-House Practice Group, American Health Lawyers Association (AHLA)
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