Bragg Hemme is a health care regulatory attorney focused on teaming up with clients in order to succeed in this complex and ever-changing federal and state regulatory environment. Bragg draws on a wealth of experience and a solid understanding of the health care industry gained during her time as both external and internal counsel in order to offer health care providers and suppliers practical legal guidance in a way that mitigates compliance risk, while also allowing clients to effectively operationalize the advice and achieve their business goals. Her experience includes advising on difficult regulatory issues such as:

  • Medicare, Medicare Advantage, Medicaid and Medicaid managed care reimbursement, including, for example:
  • Coverage, billing and payment
  • Overpayments
  • Provider-based rules
  • Space sharing
  • Medicare Secondary Payor and Coordination of Benefits rules between various payors
  • Regulatory and reimbursement compliance  
  • State licensure
  • Medicare enrollment and certification
  • Diligence support related to regulatory and reimbursement issues arising from transactions, and post-transaction support to maintain revenue
  • Payor disputes and audit support 
  • Fraud and abuse

She approaches each issue with a practical application unique to the client’s context and has a strong background working with numerous health care entities, including:

  • Hospitals, including their provider-based departments
  • Behavioral Health Organizations
  • Dialysis suppliers
  • Rural Healthcare and other safety net providers servicing underserved or health professional shortage areas, such as Critical Access Hospitals (“CAHs”), Rural Health Clinics (“RHCs”), and FQHCs/Look-Alikes
  • Physician Groups

Bragg also works with private equity firms in the health care space bringing her strong regulatory and reimbursement background in to support the success of their health care platform, whether the investment is short or long term.

Bragg co-chairs Polsinelli's Reimbursement Institute, bringing Polsinelli industry leaders together to navigate the most complex issues in the evolving reimbursement space.

Bragg also co-chairs Polsinelli's Behavioral Health practice area, bringing a unique and multi-disciplinary focus to providers in the behavioral health space.

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Education

  • University of Denver Sturm College of Law (J.D., 2002)
    • Order of St. Ives
  • University of Colorado (B.A., magna cum laude, 1996)

    Bar Admission

    • Colorado, 2002

    Professional Affiliations

    • American Health Law Association
    • American Bar Association
      • Health Law Section
    • Colorado Bar Association
      • Health Law Section
    • Denver Metro Chamber Leadership Foundation, Leadership Denver Class of 2021
    • Healthcare Financial Management Association
      • Colorado Chapter
    • Maria Droste Counseling Center, Board Member 

    Recognition

    • Selected for inclusion in Best Lawyers in America® for Health Care Law, 2022-2026
    • Named to 5280 Magazine’s “Denver’s Top Lawyers” list for Health Law, 2021
    • 14th Annual M&A Advisor Turnaround Awards, Healthcare/Life Sciences Deal of the Year ($50MM to $100MM), Restructuring of Elements Behavioral Health 
    • 11th Annual Americas M&A Atlas Awards, USA Restructuring Deal of the Year, Middle Markets, Nominee Winner: Elements Behavioral Health Restructuring and Sale of Assets 
    • Law clerk for the Honorable Rebecca Love Kourtis, Colorado Supreme Court
    Publications
    All Publications
    CMS Proposes Caps on Medicaid State Directed Payments and Fee for Service Supplemental Payments, Further Cutting Federal Funding of Medicaid
    Key Takeaways: On May 22, 2026, CMS published a proposed rule (Proposed Rule), building on (and going beyond) the requirements of H.R. 1, outlining its plan to reduce both state directed payments (SDPs) and fee-for-service supplemental payments for Medicaid providers. SDPs – a common Medicaid financing tool that requires Medicaid managed care plans to make specific payments to certain provider types in order to advance Medicaid policy objectives (access to care, quality, parity, etc.) will largely be capped at a percentage of Medicare payments limiting a common rate structure tied to average commercial reimbursement.  This change impacts nearly all SDPs, not just the historical emphasis on services tied to academic medical centers. The Proposed Rule also targets fee-for-service supplemental payments, subjecting them to the
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    2026 Health Care Reimbursement Newsletter
    2026 is shaping up to be a pivotal year for health care reimbursement. From major CMS payment rules to evolving disclosure requirements, AI scrutiny, and mounting pressure on providers across the care continuum, the 2026 Health Care Reimbursement Newsletter highlights the developments you need to understand now to stay ahead. In this issue: 2025 Wrap-Up: Key CMS Enrollment Changes and Disclosure Developments What Hospitals & ASCs Need to Know About the 2026 Outpatient Prospective Payment and ASC Final Rule Durable Medical Equipment Update 2026 Medicare Physician Fee Schedule Final Rule Highlights Forecasting Medicaid Challenges for Providers in 2026 Rural Health Providers Face a Tough Financial Road in 2026 – Will the Rural Health Transformation Program Save Them? Medicare Advantage Reimbursement Implications from the 2027 Proposed Rule Looking Ahead to 2026: CMS
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