Cori R. Haper
Partner
Chair, Health Care
Dayton Co-Chair, Diversity, Equity & Inclusion Initiative
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. Her strong corporate and contract experience, together with a deep understanding of health care laws, enables Cori to represent health care clients in significant matters as well as day-to-day business needs.
Cori represents a wide spectrum of traditional health care clients, including hospitals, clinical laboratories, hospices, home health agencies, nursing facilities, pharmacies, opioid treatment centers, federally qualified health centers, and physician practices.
She also represents private equity companies, emerging health technology vendors, and health care providers in the telehealth industry and assists them with navigating the federal and state laws that can apply to their business models, including licensure, fraud and abuse laws, corporate practice of medicine doctrines, telemedicine, fee-splitting and privacy laws, and prescribing of medications.
Cori has significant experience in conducting business transactions with buyers and sellers in the health care industry, including structuring transactions to comply with federal and state regulatory compliance laws.
She partners with the firm’s white collar defense lawyers as a subject matter expert in connection with government investigations of health care providers.
Cori is vice chair of the firm’s Corporate Practice Group and chair of the Dayton office’s Diversity, Equity & Inclusion Committee.
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 and physician practice
- 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, Anti-Kickback Statute, and EKRA to common industry practices, including in-office phlebotomists, provisions of supplies to physician practices, leases with referring physicians, and non-monetary compensation
- 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 manager of pain management clinics in connection with:
- Application of state pain management clinic laws to management service model
- Drafting of management service agreement
- Commenting on proposed rules of state board of pharmacy
Represented nursing facilities in connection with:
- Contracts with suppliers
- 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
Represented medical device and pharmaceutical companies in connection with:
- Compliance policies and procedures
- Clinical research agreements
- Physician Payments Sunshine Act reporting obligations
- Contracting matters
- Analysis of proposed business arrangements for compliance with laws
Represented emerging telehealth companies in connection with:
- Developing a women's health treatment and pharmacy services platform
- Developing a behavioral and mental health therapy platform
- Developing a web-based health coaching telehealth business
- Developing a web-based physical therapy business
- "Ohio Corporate Practice of Medicine Doctrine," Thompson Hine Health Care Law Update, December 2021
- "OIG Rejects Joint Venture Between Long-Term Care Facilities Owner and Therapy Provider," Thompson Hine Health Care Law Update, December 2021
- “Consolidated Appropriations Act, 2021: Implications for Business,” Thompson Hine COVID-19 Update, December 30, 2020
- 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
Professional Associations
- American Health Lawyers Association
- Society of Ohio Healthcare Attorneys
Community Activities
- Miami Valley Hospital Foundation, trustee
INSIGHT: Nursing Homes Face Heightened Criminal Enforcement During Covid-19Bloomberg Law
June 15, 2020