Nixon Peabody LLP
Harsh works with managed care organizations, hospital systems, and other providers on a wide range of regulatory, reimbursement, and transactional matters. His practice encompasses federal and California fraud and abuse compliance, licenses and permits, Medicare and Medicaid (Medi-Cal) participation and reimbursement, False Claims Act internal and government investigations, and enforcement actions. Harsh also advises clients on health information technology, bioethics, privacy, security compliance, digital health, and telemedicine matters.
What do you focus on?
Health Care Transactions
I assist clients in complex transactions involving sales and acquisitions of clinics, pharmacies, and hospitals. With deep experience handling regulatory issues implicated in health care transactions, I often serve as the regulatory counsel on a range of transactions involving state and federal agencies, including the Center for Medicare and Medicaid (CMS), California Department of Health Care Services (DHCS), California Department of Public Health (CDPH), the Medical Board of California (MBC), and the California State Board of Pharmacy. Additionally, I provide critical analysis and health care compliance advice on a variety of business arrangements with health plans, physicians, mental health providers, hospitals, and drug and device manufacturers.
I regularly advise clients on compliance with federal and California health care laws, with an emphasis on assessing False Claims Act risk and resolving self-disclosure obligations under the Stark Law and Anti-Kickback Statute. I have successfully defended clients seeking resolution of government health care program overpayment issues through negotiated settlements. For example, I recently coordinated a major health system’s internal investigation of its billing practices and its voluntary self-disclosure to the Department of Health and Human Services, Office of the Inspector General. I’ve also led multiple compliance investigations and provider self-disclosures to federal and state agencies of unlicensed staff, cost report errors, EMTALA violations, and HIPAA security breaches.
Managed Care Reimbursement
I’ve worked on numerous Medicare and Medicaid reimbursement/audit matters, including representing clients in administrative hearings.