Chris E. Rossman is a retired partner and health care lawyer with Foley & Lardner LLP. He has represented health care clients exclusively throughout his career and has experience in all areas of health care law, with a concentration of experience in the M&A, transactions, reimbursement and payment, and compliance areas. His national practice has resulted in clients in over 25 states. He lead the firm’s health care practice for the Detroit Office.
Chris M&A and transactional experience has been focused primarily on representing hospitals, health systems, and other providers. His strong background in reimbursement, payment and compliance issues, combined with his transactional experience, gave him the ability to provide strategic advice in structuring transactions.
Representative Experience
Representative Health Corporate Transactions
- Transaction counsel in the creation of large Midwest health system structured as a Joint Operating Agreement (JOA) between a Catholic and non-Catholic hospital.
- Lead transaction counsel for creation of Texas Health Resources, a $4+ billion health system in the Southwest U.S. The parties included Harris Methodist (Fort Worth), Presbyterian (Dallas), St. Paul (former Daughters of Charity Hospital), and Arlington Memorial (municipal hospital).
- JOA between two large Southwestern U.S. health systems.
- JOA between two large Catholic hospitals in the upper Midwest U.S.
- Acquisition of several Midwestern U.S. hospitals.
- In total, representation of hospitals and health care systems in over 30 mergers and acquisitions, many of which involved Catholic and other faith-based hospitals and health systems.
Related Transactional Experience
- Advice on the creation of accountable care networks (ACOs) and other forms of integrated health care networks that provide coordinated care and population management, including provider networks that contract directly with employer self-insured health plans.
- Creation of a wide variety of physician – hospital alignment structures, including clinical service line co-management agreements, other management agreements, under arrangements transactions, physician acquisitions and employment agreements, and on-call arrangements.
- Formation of a variety of forms of entities, including corporations, partnerships, limited partnerships, limited liability partnerships and limited liability companies.
Reimbursement and Payment Experience
- Representation of several Medicare group appeals and individual appeals that recovered well over $100,000,000 of Medicare reimbursement for his clients.
- Representation of a hospital that obtained the first successful federal district court decision upholding Medicare reimbursement for loss on disposition of assets notwithstanding the nonprofit structure of the corporations involved.
- Representation of hospitals in Medicaid lawsuits that successfully challenged state Medicaid policies.
- Advice to clients regarding Blue Cross Blue Shield of Michigan matters, including contract negotiations, appeals, litigation and state regulatory issues.
- Negotiation of managed care provider contracts with a variety of payors.
Awards and Recognition
Chris has been Peer Review Rated as AV® Preeminent™, the highest performance rating in Martindale-Hubbell’s peer review rating system. He has also been selected by his peers for inclusion in The Best Lawyers in America© in health care since 1991, named Outstanding Hospital Lawyer – 2004 by Nightingale’s Healthcare News, and selected for inclusion in the 2006 – 2016 Michigan Super Lawyers® lists. In addition, he was named to DBusiness magazine’s 2011 and 2012 lists of Top Lawyers in the area of health care law.
Affiliations
He is an active member of the State Bar of Michigan. He is a member of the State Bar of Michigan Health Law Section, the American Health Lawyers Association, the Health Law Section of the American Bar Association, and the Detroit Metropolitan Bar Association. Mr. Rossman is past chairman of the Reimbursement and Payment Substantive Law Committee of the American Health Lawyers Association and is a past member of the board of directors of the Southeast Michigan Chapter of the Healthcare Financial Management Association.
Presentations and Publications
Presentations
He is a frequent speaker on health legal topics. A selection of representative presentations includes:
- Regular speaker at past American Health Lawyers Association (AHLA) Institute on Medicare and Medicaid
- June 2014, Health Care Compliance Association (HCCA), 2014 West Coast Regional Area Compliance Conference, “Integrated Delivery Networks and What They Mean for Compliance”
- January 2014, AHLA Plan-Provider Managed Care Contracting Webinar Mini-Series, “A Blockbuster in the Making, The Finale: Current Compensation/Reimbursement Issues in Plan-Provider Managed Care Contracting”
- November 2012, HFMA’s 59th Annual Fall Conference, “Accountable Care Organizations – How Provider Organizations are Addressing for Success”
- March 2011, AHLA Institute on Medicare and Medicaid, “ACOs, Medical Homes and Related Integration Initiatives,” panelist with CMS representatives and other private attorney
- January 2011, Foley webinar, “Medicare Reimbursement after Health Care Reform – Navigating Significant Changes to Medicare Payment Policies,” co-presenter
- October 2010, Michigan Health and Hospital Association Health Foundation Governance Leadership Forum, “ACOs: About as Far Away From Invisible As You Can Get”
- October 2010, The Accountable Care Association 2010 National Conference, “Recent Legal Developments”
- September 2010, Michigan Health Care Financial Management Association (HFMA), “Health Care Reform Law: Changes in Law Affecting Physician/Hospital Affiliation Strategies”
- September 2010, Foley & Lardner’s Executive Briefing Series, “Health Care Reform – Are You Ready for the Major Changes to Your Group Health Plans?”
- April 2010, Foley & Lardner’s Friday Focus Web Conference Series, “Strategies for Coping With Changes to Medicare Payment Policies”
- January 2010, Wisconsin HFMA Mega Conference, “Medicare Bad Debts”
- September 2009, HFMA’s 56th Annual Fall Conference, “Physician/Hospital Alignment – Cutting Edge Strategies: Regulatory and Payment Issues”
- September 2009, Foley & Lardner’s Friday Focus Web Conference Series, “Medicare Provider Enrollment Update and Enforcement Strategies”
Publications
A selection of his publications includes:
- August 2011, American Health Lawyers Association, “Changes to LTCH Medicare payment rules”
- November 2010, Foley & Lardner LLP Legal News Alert: Health Care, “CMS Request for Information Reinforces Belief That Many Approaches to ACOs Will Be Allowed”
- August 2010, American Health Lawyers Association, “CMS Issues Final IPPS Rules; Interim Final Rule on Three-Day Payment Window”
- August 2010, American Health Lawyers Association, “Policy and Payment Rate Changes for Inpatient Stays in Acute Care and Long Term Care Hospitals (Inpatient Prospective Payment System)”
- May 2010, Foley & Lardner LLP Legal News Alert: Health Care, “Health Care Reform Legislation Makes Significant Changes to Medicare Reimbursement Methods”
- 2010, Foley & Lardner LLP White Paper, “Transforming Health Care Through Accountable Care Organizations: A Critical Assessment,” co-author
- November 2009, Foley & Lardner LLP Legal News Alert: Health Care, “CMS Relaxes Supervision Requirements for Hospital Outpatient Departments”
- September 2009, Foley & Lardner LLP Legal News Alert: Health Care, “No Summer Vacation for CMS: Multiple Significant Developments”
- January 2009, Foley & Lardner LLP Legal News Alert: Health Care, “Clinical Integration: A Guide to Working With the Federal Trade Commission to Enhance Care Through Pro-Patient, Pro-Innovation, Pro-Efficiency Provider Networks”
- January 2009, Health Lawyers Weekly, “Clinical Integration: A Guide to Working With The Federal Trade Commission to Enhance Care Through Pro-Patient, Pro-Innovation, Pro-Efficiency Provider Networks”
- January 2009, Foley & Lardner LLP Legal News Alert: Health Care, “FTC Settles Price-Fixing Charges Against Two Separate Physicians’ Groups”