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Sarah Swank has been a health attorney for over twenty years providing strategic advice to hospitals, academic medical centers, physician organizations, healthcare associations, and healthcare startups. Sarah assists with strategic development and approaches to the intersection of artificial intelligence (AI), compliance programs, value-based care, managed care contracting, virtual care, care coordination, and population health. As a former senior in-house counsel for two national healthcare systems, she provides practical solutions to clients navigating a complex and changing regulatory landscape to promote innovation and thoughtful growth. She is passionate about supporting clients through the development of compliant programs that provide equitable 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 practices, joint venture models, medical faculty entities, Federally Qualified Health Centers, children’s hospitals, health information exchanges, long-term care facilities, and hospital-owned health plans.
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, digital health, and AI programs. I work directly with in-house counsel and senior and clinical leadership on the 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 firsthand experience managing these issues as in-house counsel.
My fraud and abuse background focuses on advice and guidance under Stark, Anti-Kickback Statute, Civil Monetary Penalties, and the False Claims Act related to telehealth, 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 Department of Justice (DOJ) on Stark and medical necessity, assisting with structuring physician arrangements and transactions, conducting internal investigations, and advising regarding CIA implementation post-settlement. In addition, I support compliance programs and HIPAA advice and investigations, including cybersecurity and data breaches.
My work in the area of clinical research and institutional review boards (IRBs) includes due diligence reviews during hospital mergers, Food and Drug Administration (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.
I provide health equity thought leadership and supports healthcare providers, technology companies, and associations navigating the complex and changing legal and health policy framework around health equity. I work in cross-disciplinary teams to ensure compliance with access and safety requirements, data use and reporting, clinical research, fraud and abuse, and other federal and state requirements related to access and health equity. I helpclients in compliance and innovation around health equity as it becomes a measurable standard tied to payment reform, social determinants of health (SDOH), and population health activities. These standards are found in policies and procedures, governance activities monitoring, workforce initiatives, and other compliance and operational activities. Health equity is not done with one training program, but through ongoing commitment, advising and change. Health equity goes beyond access to healthcare and insurance to ensure that communities have the right to a healthy life and life expectancy.
Virtual care models will be integrated into care delivery with a focus on health equity and data use including AI, wearables and remote patient monitoring. As we move toward value-based care, care coordination, and digital health solutions, my historic perspective, real-world operational knowledge and practical solutions provide valuable insight into where the healthcare industry and health policy are heading and how stay nimble in a changing regulatory environment.
Sarah Swank is a national speaker, author, and thought leader in supporting organizations to navigate the rapid changes occurring in healthcare, including payment reform, ACOs, telehealth, and artificial intelligence. Sarah continues to be an innovator in the health care arena, having presented and authored on various topics, including serving as the first speaker at both HIMSS and the American Telemedicine Association on ACOs as well as the first professional to speak on telehealth issues with the American Health Lawyer Association. A selection of her standout presentations and publications over the years include the following:
This article on how the FTC’s proposed elimination of noncompete agreements could impact the DC-area healthcare industry and providers quotes Washington, DC Healthcare counsel Sarah Swank on the implications—and potential exceptions—the change could carry for consolidation deals.
Chicago Healthcare partner Valerie Montague, Rochester counsel and Cybersecurity & Privacy practice deputy leader Jenny Holmes, Washington, DC Healthcare counsel Sarah Swank, and Chicago Healthcare associate Meredith LaMaster contributed this article on how Roe’s reversal disrupts expectations regarding the privacy of women’s health information—and the role of healthcare practitioners, app developers, and cell phone providers in protecting it.
District of Columbia
Skidmore College, B.A., cum laude
Villanova University School of Law, J.D., cum laude
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