Steven F. Banghart

Steve Banghart represents health care providers in various corporate transactions, regulatory compliance and the structuring of clinical integration programs. As a leader of the firm’s value-based contracting arrangements, he also helps providers design and develop Medicare and commercial accountable care organization programs, processes and infrastructure. He lectures frequently on value based payment models, provider-payor relationships and health care regulatory matters including clinical integration initiatives, accountable care organizations, anti-trust issues, HIPAA, fraud and abuse, and the Stark law.

What do you focus on?

Clinical Integration

Helping health care providers plan for and implement clinical integration programs is a significant focus of my practice. This includes working with the Federal Trade Commission (FTC) to help providers achieve compliance with FTC standards. I’ve completed numerous clinical integration networks that are successfully contracting on behalf of their participating providers in various value-based payor contracting arrangements.

Value-Based Contracting Programs

With growing demand for value-based contracts, I advise health care providers on the application and implementation process for Medicare shared savings programs, bundled payment initiatives, alternative payment programs and related federal, state and commercial payer contracting initiatives.

Corporate Transactions

Health care providers also turn to me for assistance with all aspects of their operations, including corporate merger and affiliation transactions, as well as the purchase and sale of health care facilities and professional medical practices and in the development of various clinical joint ventures.

Regulatory Compliance

Health care provider organizations are subject to complex regulations and regulatory scrutiny. As the industry continues to experience significant changes, I help providers maintain compliance with applicable health care regulations, including physician self-referral, fraud and abuse, HIPAA, tax and antitrust guidelines.

What do you see on the horizon?

The federal and state governments and commercial payors will continue to usher in new value-based payment programs to incentivize collaboration among health care providers. It’s important to identify and implement strategies to effectively respond to and capitalize on these value-based contracting programs as they’re implemented in Medicare, Medicaid and commercial payer initiatives.  I expect more opportunities for provider networks to form larger regional provider networks that deliver value-based services across a much broader patient population.  We are experienced in forming these “super networks” and in addressing the various regulatory, organizational and structural requirements that are inherent in their formation.

Publications & Presentations

  • ACO participants: You want to play, put some skin in the game,” Health Law Daily, Wolters Kluwer, August 10, 2018
  • “Clinically Integrated Network Governance and Structure,” Vizient Southeast Clinically Integrated Collaborative Meeting, Tampa, FL, February 7, 2018 (Keynote speaker)
  • “Accountable Care Organizations: Past, Present, and Future,” published in Health Law and Compliance Update, 2016 edition, Wolters Kluwer
  • “Moving Forward After the Affordable Care Act—Alternate Delivery Models from Industry Perspective,” Texas Health Law Conference, Austin, Texas (Co-presenter)
  • “Trends to Watch for in Health Care and Delivery System Transformation,” American Health Lawyers Association
  • “Contracting with ACOs and Other Multiprovider Arrangements,” Leading Age Annual Meeting, Rosemont, Illinois (Co-presenter)
  • “Constructing Clinically Integrated Networks,” Adventist Health System Retreat, Orlando, Florida (Keynote speaker)
  • “ACOs and Value Based Care,” Loyola Law School LLM Program, Chicago, Illinois (Visiting lecturer)

ACO participants: You want to play, put some skin in the game

Wolters Kluwer | August 09, 2018

Chicago Health Care partner Steven Banghart is quoted in this article for his analysis of a proposed overhaul of the Medicare Shared Savings Program’s approach towards accountable care organizations.


Steven F. Banghart

Senior Counsel


Phone: 312-977-4880

Fax: 844-552-3036

Thomas M. Cooley Law School, J.D., with honors

University of Michigan, M.H.S.A.

Michigan State University, B.A.


  • American Bar Association
  • American Health Lawyers Association
  • Chicago Bar Association
  • Illinois Association of Hospital Attorneys
  • Illinois State Bar Association

Steve Banghart has been appointed to the Board of Directors of Morris Hospital & Healthcare Centers (MHHC) . In addition to the main campus in Morris, Illinois, located about 50 miles southwest of downtown Chicago, MHHC serves residents of five counties through its affiliated 24 ambulatory care locations. Steve has been appointed to the board for an initial term of three years.

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