Cori R. Haper

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

• Co-author, “INSIGHT: Nursing Homes Face Heightened Criminal Enforcement During Covid-19,” Bloomberg Law, June 2020
• "From Employers to Homeschooling to Healthcare: Federal Government Provides Guidance Clarifying Data Privacy Requirements During COVID-19," Thompson Hine COVID-19 Update, April 2020
• "CMS Issues Blanket Waivers of the Stark Law During the COVID-19 Public Health Emergency," Thompson Hine COVID-19 Update, April 2020
• "Emergency Orders Increase Access to Medical Care and Reimbursement for Telehealth Services During COVID-19 Public Health Emergency," Thompson Hine Health Care Law Update, March 2020
• “OCR Allows Flexible Telehealth Technology Use During COVID-19 Emergency,” Thompson Hine COVID-19 Update, March 2020
• “Considerations for Practicing Telemedicine During the COVID-19 Pandemic,” Thompson Hine COVID-19 Update, March 2020
• "DOJ and HHS Launch a National Nursing Home Enforcement Initiative," Thompson Hine Health Care Law Update, March 2020
• "DOJ Announces First Criminal Prosecution Under EKRA," Thompson Hine Health Care Law Update, February 2020
• “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