Meghan M. Cosgrove is a partner in the firm’s Health Law practice, where she focuses on compliance with healthcare fraud and abuse laws as well as issues related to the Medicare program. She represents hospitals, physicians, and other healthcare providers and suppliers on a wide range of matters, including: the Stark Law; the Anti-Kickback Statute; the Civil Monetary Penalties Law; the Emergency Medical Treatment and Labor Act; Graduate Medical Education issues; the 340B Pharmacy Program; diagnostic testing issues; the Health Insurance Portability and Accountability Act; and clinical trials. Meghan is frequently called upon to advise clients on potential compliance issues related to the structuring of affiliations, joint ventures, and other business transactions. She also works collaboratively with the litigation department in defending clients against healthcare fraud and abuse lawsuits and investigations including the review and negotiation of settlements involving the Department of Justice, the Office of Inspector General, and the Centers for Medicare and Medicaid Services.
Prior to joining the firm, Meghan served at the Centers for Medicare and Medicaid Services (CMS) in Boston and in Baltimore, Maryland as a Health Insurance Specialist in the Division of Medicare Financial Management and the Division of Technical Payment Policy, respectively. During her tenure at CMS, she worked on the Stark Law Phase III regulations, the Specialty Hospital Report to Congress, the EMTALA Technical Advisory Group Report, the Compliance Effectiveness Pilot project, as well as Medicare reimbursement and coverage issues.
Awards & Recognitions
Best Lawyers, Healthcare Law, 2019 (1)
Massachusetts Super Lawyer, 2017-2018(1)
Massachusetts Super Lawyers Rising Star 2013-2015(1)
Health Insurance Specialist, Centers for Medicare and Medicaid Services, Division of Technical Payment Policy, Baltimore, MD
Health Insurance Specialist, Centers for Medicare and Medicaid Services, Division of Medicare Financial Management, Boston, MA
Legal Intern, Partners Healthcare, Office of General Counsel, Boston, MA
Director of Project Development, Federated Ambulatory Surgery Association, Alexandria, VA
Manager of Marketing and Senior Software Support and Training Specialist, Camberley Systems, Inc., Needham, MA
Suffolk University Law School, J.D., 2005 Health and Biomedical Law Concentration with Distinction
Chief Content Editor (Founding Editor), Suffolk Journal of Health and Biomedical Law
Winner, Best LPS Brief, 2002-2003
Honorable Mention, LPS Oral Argument, 2002-2003
College of the Holy Cross, B.A., English, 1997
Court / Bar Admissions
Clinical trials and research contracting; Compliance program development and counseling; Contract negotiations; Corporate governance; Medicaid fraud; EMTALA; Fraud and abuse compliance; Government investigations; Graduate medical education compliance; Corporate formation, Joint ventures, affiliations, and other business arrangements; Medical staff governance; Medical peer review; Medicare/Medicaid reimbursement; Organ transplant issues; Payor contracting; Payor disputes; Regulatory compliance; Patient care issues; Provider network formation; Physician compensation and financial arrangements; Physician recruitment and retention; Risk management/liability; State & federal regulatory matters; Tax exempt Issues; Telemedicine/e-health; 340B compliance
Academic Medical Centers; Allied Health Professionals; Ambulatory Surgery Centers; Ancillary Providers; Clinical Laboratories; Community Health Centers; Community Hospitals; Ground/Air Emergency Transport Providers; Healthcare Technology (MRI, PET, Radiation Therapy, etc.); Home/Hospice Care; Independent & Assisted Living; Licensed Clinics; Managed Care/Behavioral Health; Pediatric Hospitals; Physicians; Professional Trade Associations; Psychiatric Providers; Rehabilitation; Skilled Nursing
Co-Editor for the Boston Bar Association Health Law Reporter
Boston Bar Association Health Law Steering Committee
American Bar Association
American Health Lawyers Association
Boston Bar Association
Holy Cross Lawyers Association
Women’s Bar Association
Health Law Basics Seminar: Health Care Fraud and Abuse (April 2013)
Home Health Care Overview (February 2013)
EMTALA in Practice (May-November 2012)
“Local Health Law Briefs: U.S. ex. rel. Christopher Drennan v. Fresenius Medical Care Holdings, Inc.,”Boston Bar Association Health Law Reporter (Spring 2012) pgs. 42-43.
“How to Read Tea Leaves: CMS’ Self-Referral Disclosure Protocol,” Boston Bar Association Health Law Reporter (Winter 2011) pgs. 9-12.
“End of Assumptions: Physician Supervision of Outpatient Hospital Services,” Boston Bar Association Health Law Reporter (Spring 2010) pgs. 4-11.
“Implementation of Accreditation Standards for Suppliers Furnishing the Technical Component of Advanced Diagnostic Imaging Services,” Boston Bar Association Health Law Reporter (Spring 2010) pg. 22.
“Local Health Law Briefs” Boston Bar Association Health Law Reporter (Fall 2009) pgs. 29-33.
“Local Health Law Briefs” Boston Bar Association Health Law Reporter (Summer 2009) pgs. 27-30.
“Rooting Out Physician Fraud: The Government’s Plan,” Mass Medical Law Report (December 2007)
Civic & charitable activities
American Ireland Fund
Suffolk University Law School Alumni Mentor
College of the Holy Cross Alumni Mentor
(1) The Super Lawyers list is issued by Thomson Reuters. A description of the selection methodology can be found at superlawyers.com/about/selection_process.html. Best Lawyers is a division of Woodward/White, Inc. A description of the selection methodology can be found here. No aspect of this advertisement has been approved by the Supreme Judicial Court of Massachusetts.
- work with a large academic medical center on compliance issues post-acquisition of a community-based cardiology practice
- develop and advise a large multi-specialty physician group practice on business models to bring ancillary revenue streams in-house.
- perform a review of physician contractual arrangements for Stark Law compliance prior to sale of a hospital
- draft template ACGME affiliation and program letters of agreement for an academic medical center including a matrix to allow the client to independently administer the agreements in the future
- negotiate a settlement on behalf of a physician group practice with DOJ, OIG, and CMS to resolve allegations of Stark Law and Anti-kickback Statute violations
- advise a multi-hospital chain on EMTALA including in-house training and assessment of policies and procedures
- collaborate with a home health provider on an ACO participation arrangement
- advise rehabilitation hospital on complex Medicare payment rule that would result in decreased reimbursement
- successfully represent a physical therapy provider against a qui tam lawsuit
- perform a compliance assessment of a proposed business model related to diagnostic testing equipment
- draft and negotiate several clinical affiliation agreements between a Boston teaching hospital and a community hospital
- develop process and guidelines for review and negotiation of clinical trial agreements for the research administration department of a hospital
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