Kyle Vasquez maintains a national health care practice and provides pragmatic legal and compliance support to a wide range of health care clients. He utilizes his background in health law and his prior experience as a health care consultant to develop creative approaches to complex issues. Kyle provides 340B drug pricing program, reimbursement, licensing/certification, DEA and other regulatory support to a broad set of health care entities including academic medical centers, multi-hospital health systems, community hospitals, FQHCs, institutional and retail pharmacies, and physician practices, among others.

Kyle’s areas of focus include:

  • Providing 340B regulatory, compliance, audit, repayment, self-disclosure, litigation and contract support to Covered Entities, Contract Pharmacies, and other key stakeholders.
  • Advising on multi-state telehealth and telepharmacy matters, including assisting with state licensing, controlled substance and DEA obligations. 
  • Counseling various provider types on complex healthcare reimbursement and cost report matters, including Medicare, Medicaid, and private payor reimbursement, to ensure consistent cash flow and compliance with applicable rules.
  • Assisting multiple provider/supplier types with provider enrollment, licensing and certification matters.
  • Structuring and negotiating a variety of transactions, including provider-based conversions, physician practice acquisitions, joint ventures, joint operating agreements, mergers, and acquisitions.
  • Assisting providers with administrative appeals, reconsideration requests, and other litigation strategies regarding adverse government agency findings.
  • Assisting with self-disclosures, government audits, and appeals of audit findings.
  • Assisting providers and pharmacies with complex payor credentialing and negotiation matters, including navigating HEAT Zones credentialing issues and negotiating 340B drug pricing program, mail order, and central fill terms with the nation’s largest PBMs.
  • Assisting pharmacies with compliance and dispute matters pertaining to PBM restrictions, including mail order restrictions.
  • Advising providers and pharmacies on a variety of litigation options pertaining to health plans, PBMs and government agencies.

Education

  • Loyola University Chicago School of Law (LL.M., 2007)
    • Health Law
    • Health Law; CALI Award
  • UIC John Marshall Law School (J.D., 2006)
    • Dean's List; Moot Court Council; Dean Herzog Moot Court Competition First Place Overall
  • University of Illinois (B.A., 2003)
    • Economics

Bar Admission

  • Illinois, 2006

Court Admissions

  • U.S. District Court, Northern District of Illinois, 2007

Professional Affiliations

  • American Bar Association
    • Health Law Section
  • American Health Lawyers Association
  • Chicago Bar Association
  • Illinois Association of Healthcare Attorneys
    • Education Committee
    • Mentor

Recognition

  •  Selected for inclusion in Best Lawyers in America® for Health Care Law, 2024-2026
Publications
2026 340B Program Update – 340B Rebate Model RFI Comments Due and Manufacturers Continue Restricting 340B Pricing
Key Takeaways HRSA has extended the deadline for comments on its proposed 340B rebate model pilot program to April 20, 2026. Covered entities have a limited window to submit detailed feedback on how the model would affect operations and patient care. The proposed rebate model and new manufacturer data submission policies increase administrative burden and create risk of pricing denials and cash flow disruption. These changes could significantly expand compliance obligations and force providers into frequent disputes to recover 340B savings. Covered entities should submit detailed RFI comments and actively monitor 340B pricing access and denials. Providers should also begin tracking data, documenting losses and preparing for potential ADR filings and manufacturer engagement. The 340B program is experiencing rapid changes that could have a
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Mandatory Provider-Based Attestations Make a Comeback
After a nearly 24-year hiatus from the mandatory provider-based attestation requirement, the Consolidated Appropriations Act of 2026 (Act, signed into law on Feb. 3, 2026), mandates (again) that hospitals file attestations of compliance with the provider-based regulations for all off-campus provider-based locations. Attestations must be filed before Jan. 1, 2028, with more specific timing to be further defined by CMS. Failure to do so by that date will result in payment reduction under the Hospital Outpatient Prospective Payment System (OPPS). Key Takeaways Hospitals must file attestations for all off-campus provider-based locations pursuant to either (a) the existing attestation regulations at 42 C.F.R. § 413.65(b)(3) or (b) new regulations that CMS must establish under the Act. All initial attestations must be filed within the
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