Alexandra Busto

/My focus

HEALTHCARE TRANSACTIONS AND REGULATORY COMPLIANCE

I represent healthcare providers and related organizations in complex transactional and regulatory matters. I have extensive experience working with a broad range of healthcare organizations, spanning multi-state health systems, community hospitals, academic medical centers, ambulatory surgery centers (ASCs), specialty clinics and physician groups (including IVF, dental, and veterinary), telehealth and digital health platforms, management services organizations (MSOs), independent practice associations (IPAs), clinically integrated networks (CINs), imaging centers, and hospice agencies. 

I regularly advise clients on both buy-side and sell-side transactions to structure and negotiate arrangements that drive growth and support integration in care delivery. I serve as outside general counsel for health systems that are navigating provider-alignment strategies, including developing value-based care arrangements, shared risk models, joint ventures, and similar affiliations. This often includes the development and expansion of 1206(l) medical foundations, hospital-based clinics, and teaching clinics, including through acquisitions and complex services arrangements. 

As part of this, I advise on physician self-referral laws (Stark Law), anti-kickback statutes, licensing and certification requirements, and broader healthcare compliance issues. I routinely guide nonprofit healthcare organizations through regulatory approval processes, including securing waivers and consents from the California Attorney General, Office of Health Care Affordability (OHCA), and other regulatory agencies.

I also work with telehealth platforms and multi-state medical practices operating under the “friendly” PC-MSO model on compliance with state corporate practice of medicine laws. With the continued expansion of telehealth and digital health, I help clients address challenges related to reimbursement, multi-state licensing, data privacy and access, and fraud and abuse compliance in remote care delivery.

/Representative experience

• $200.7M hospital affiliation with USC Health System: Represented Methodist Hospital of Southern California in its $200.7 million affiliation with USC Health System. The deal preserved the hospital’s community-focused mission while expanding access to academic medicine and successfully navigating California Attorney General approval.
• Dual hospice affiliation in Northern California: Represented a large nonprofit hospice provider in its simultaneous transactions to affiliate with two additional hospice and home health agencies. Together, these affiliations created Northern California’s largest independent hospice network, ensuring seamless operational integration and governance alignment.
• Nationwide telehealth platform launch for COVID-19 testing: Co-led the launch of the first FDA-authorized at-home COVID-19 antigen test. A 50-state telehealth and diagnostics platform was built in under 60 days, expanding nationwide access to COVID-19 testing during a public health emergency.
• Physician foundation and clinic network expansion: Advised several community hospitals and integrated health systems on developing physician 1206(l) medical foundations, outpatient clinics, and community health networks. Provided strategic counsel on practice acquisitions, governance structuring, and regulatory compliance to support scalable healthcare delivery.
• Pro bono nonprofit FQHC merger: Led the legal representation of Venice Family Clinic in its merger with South Bay Family Health Care, forming one of the largest nonprofit federally qualified health centers in the US. The combined organization serves 45,000 patients across 17 locations and mobile clinics, with a robust street medicine program. 
• Care-at-home joint ventures for acute care delivery: Structured three joint ventures for a multi-state integrated health system to launch a new in-home acute care model. This approach enabled remote monitoring and telehealth-supported treatment, allowing patients to receive hospital-level care at home. 

/Looking ahead

New technologies and reshaping healthcare delivery, driving collaboration, expanding access to care, and accelerating innovation. These shifts bring evolving legal and regulatory challenges, especially around compliance, licensing, and data governance, that will require thoughtful, adaptive legal strategies. As the industry continues to evolve, the goal remains clear: delivering accessible, quality care at lower costs.

/Insights

• Speaker, “Roundtable on California Transactional Trends under California’s Office of Health Care Affordability (OHCA) and Beyond” LACBA Healthcare Law Section’s Roundtable, May 15, 2025
• Speaker, “Women's Healthcare - How to overcome investment challenges,” 12th Annual UCLA MedTech Partnering Conference, March 12, 2024
• Speaker, “IVF Clinic Market Expansion: Prioritizing Investment Over Consolidation,” Reproductive Health Innovation Summit, February 14, 2024
• Speaker, “California’s New Office of Health Care Affordability (OHCA): Key Considerations for Health Industry Transactions,” LACBA Healthcare Law Section’s Roundtable, February 7, 2024
• Speaker, “Healthcare Transactions & Regulatory Landscape in California: 2024 Outlook,” Nixon Peabody California MCLE Virtual Seminar, January 2024
• Speaker, “Insider's Views: Ensuring Telehealth Program Integrity,” ATA2023 Annual Conference & Expo, March 5, 2023
• Speaker, “2023 Healthcare Market Trends & Implications,” Nixon Peabody 2023 California MCLE Virtual Seminar, January 20, 2023
• Speaker, “Staying Competitive in the Market: Exploring Innovative Solutions to Physician Alignment Models” Zephyr Healthcare Advisors 2022 Healthcare Leadership & Executive Conference, Las Vegas, NV, September 29, 2022
• Co-Author, “Key considerations for telehealth providers following the Dobbs decision,” Association of Corporate Counsel, August 25, 2022
• Speaker, “Distribution & Market Access Innovation,” Women's Health Innovation Series Reproductive Health Innovation Summit, Boston, MA, February 16, 2022