Cori R. Haper
Partner
Chair, Health Care
Cori is chair of the firm’s Health Care practice. She focuses her practice on representing health care providers in business, compliance, and regulatory matters. She enjoys leveraging emerging issues and ever-evolving regulatory disciplines impacting health care businesses, allowing her to provide practical and timely advice to her clients.
Cori represents a wide spectrum of health care clients, including hospitals, clinical laboratories, hospices, home health agencies, skilled nursing facilities, pharmacies, opioid treatment centers, federally qualified health centers, and physician practices.
Cori has significant experience in structuring and conducting business transactions with both buyers and sellers in the health care business, including mergers and acquisitions, joint ventures, and non-profit affiliations, and applies a multi-disciplinary approach to handling the risks that apply to the stakeholders of every transaction. Her experience also encompasses federal and state regulatory compliance matters including the Anti-Kickback Statute and Stark Law, the False Claims Act, billing investigations and repayments, Medicare provider and supplier revocations, medical staff issues and peer review, HIPAA, EMTALA, state health care laws, licensure and change in ownership requirements, clinical integration and managed care.
As part of her commitment to Thompson Hine’s innovative service model, Cori works with clients to help them reach their goals through implementing alternative pricing structures and offering innovative approaches to her counseling services while embracing efficiency, predictability and transparency to create a customized experience for her clients.
Cori is vice chair of the firm’s Corporate Practice Group and chair of the Dayton Office’s Diversity, Equity & Inclusion Committee.
Representative Matters
Health care transactions:
- Representation of buyer of institutional pharmacies across the country
- Representation of non-profit hospice in affiliation with other non-profit hospices
- Representation of opioid treatment program in sale to private equity investor
- Representation of neonatology practice in sale to national practice
- Representation of dental practice in sale to national practice
- Representation of buyer in acquisition of inpatient rehabilitation facilities and long-term acute care hospitals
- Representation of buyer of pharmaceutical packaging business
- Representation of buyer of medical equipment business
- Representation of hospital system in spin-off of clinics to federally qualified health center
- Representation of hospital in connection with acquisition of urgent care center
- Representation of private equity company in acquisition of medical equipment business
Represented hospitals in connection with:
- Acquisition of physician practices, including primary care, cardiology, physical medicine, radiation oncology, OB/GYN, and physical medicine
- Contracting with physicians and advanced practitioners for employment
- Contracting with practices for department services, such as emergency medicine, orthopedic, and cardiology
- Physician recruitment
- Guidance on fraud and abuse laws, hospital conditions of participation, and state laws
- Use of telemedicine to expand care
- Compliance with HIPAA and data breaches
Represented clinical laboratories in connection with:
- Advising on the application of the Stark Law and Anti-Kickback Statute to common industry practices, including in-office phlebotomists, provisions of supplies to physician practices, leases with referring physicians, and non-monetary compensation
- Advising on the application of EKRA to compensation arrangements
- Joint venture arrangements with other laboratory providers
- Privacy and security of laboratory test results, including investigations by the Office for Civil Rights, and patient access to lab test results
- Licensure, accreditation, and CLIA requirements
Represented nursing facilities in connection with:
- Medicare and Medicaid conditions of participation, licensure, and certificates of need
- Contracts with suppliers under consolidated billing
- Financing transactions, including local counsel licensing opinions
- Advice on application of fraud and abuse laws to operational and ownership issues
- Use of telemedicine in nursing facilities
Represented drug treatment centers in connection with:
- Federal and state licensure and accreditation of drug treatment facilities
- SAMHSA regulations
- Practice of office based opioid treatment
- Disclosure of substance use disorder records under 42 CFR Part 2
- Use of telemedicine in drug treatment under federal and state law
- Application of EKRA to compensation of sales representatives
Represented pharmacies in connection with:
- DEA regulations and controlled substances registrations
- State licensing laws
- Acquisitions and sales of pharmacies
- “New Stark Law Rules Proposed,” Thompson Hine Health Care Law Update, November 2019
- "OIG Approves Marketing Program Offered by Technology Company to Health Care Providers," Thompson Hine Health Care Law Update, September 2019
- “Ohio Develops Standard Authorization Forms,” Thompson Hine Health Care Law Update, January 2019
- “Considerations for Practicing Telemedicine in Ohio,” Thompson Hine Health Care Law Update, October 2018
- “Federal Government Signals Continued Aggressive Health Care Fraud Enforcement,” Thompson Hine Health Care Law Update, October 2018
- “Changes to Ohio Laws Governing Advanced Practice Registered Nurses,” Thompson Hine Health Care Law Update, September 2018
- “DOJ Beefs Up Criminal Health Care Fraud Enforcement with Addition of Newark/Philadelphia Strike Force,” Thompson Hine Health Care Law Update, August 2018
- “OIG Releases List of Provider Self-Disclosure Settlements for First Half of 2018,” Thompson Hine Health Care Law Update, July 2018
- “OIG Issues Advisory Opinion on Gainsharing Arrangement Between Physician Group and Medical Center,” Thompson Hine Health Care Law Update, January 2018
- “Permissibility of Electronic Records and Signatures Under the UETA,” Thompson Hine Business Law Update, Spring 2017
- “Health Care Provider Requirements Under Final Nondiscrimination Rules,” Thompson Hine Health Care Law Update, October 2016
- “HIPAA Phase 2 Audit Program,” Thompson Hine Health Care Law Update, April 2016
- “Changes to the Stark Law: Part III,” Thompson Hine Health Care Law Update, March 2016
- “Changes to the Stark Law: Part II,” Thompson Hine Health Care Law Update, February 2016
- “Civil Monetary Penalties Upheld for Violation of the HIPAA Privacy Rule by a Home Health Company,” Thompson Hine Health Care Law Update, February 2016
- “Changes to the Stark Law: Part I,” Thompson Hine Health Care Law Update, February 2016
- “Hospitals Cannot Fire Physicians Based on Peer Review Conduct,” Thompson Hine Health Care Law Update, March 2015
- “De Facto Private Right of Action Under HIPAA: Is Ohio Next?,” Thompson Hine Health Care Law Update, December 2014
- “Hospital Subsidy of Patient Health Insurance Premiums,” Thompson Hine Health Care Law Update, August 2014
- "Ohio Health Care Employers Required to Notify Patients of Termination of Physician's Employment," Thompson Hine Advisory Bulletin, February 2013
- "Final Omnibus HIPAA Rule," Thompson Hine Advisory Bulletin, January 2013
- "Health Care Providers May Disclose Patient Information to Avert Health or Safety Threats," Thompson Hine Advisory Bulletin, January 2013
- "CMS Issues Proposed Rules on Post-Discharge Care Billing Code and DME Face-to-Face Encounters," Thompson Hine Advisory Bulletin, August 2012
- "CMS Selects New Medicare ACOs," Thompson Hine Advisory Bulletin, July 2012
- "Health Care Compliance: Current Issues," Thompson Hine Breakfast Briefing, November 2014
- "Health Care Compliance: Current Issues," Miami Valley MGMA Association, March 2014
- "Navigating the Changes to HIPAA Compliance Under the Final Omnibus Rule," Miami Valley MGMA Association, July 2013
- "Navigating the Changes to HIPAA Compliance Under the Final Omnibus Rule," Thompson Hine Breakfast Briefing, February 21, 2013
- "Health Care Compliance: Current Issues", Thompson Hine Breakfast Briefing, May, 2013
Professional Associations
- American Health Lawyers Association
- Health Care Compliance Association
- Society of Ohio Healthcare Attorneys
- Dayton Bar Association