Mary Canavan is an associate in the Health Care Operations practice. She is committed to delivering clients with strategic solutions tailored to their specific needs. She utilizes her background in health law and her prior experience as a health care consultant to assist with transactional, operational and regulatory counsel on many complex matters that impact the health care industry. Mary provides reimbursement, provider-based status, 340B drug pricing program, licensing/certification, DEA, billing and coding 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, among others. Mary’s practice includes:

  • Providing 340B regulatory, compliance, audit, repayment, self-disclosure, litigation and contract support to Covered Entities, Contract Pharmacies and other key stakeholders.
  • Assisting with licensing and enrollment matters with Medicare, Medicaid, and various state agencies.
  • Preparing CARES Provider Relief Fund and FEMA applications and reporting related to the COVID-19 Public Health Emergency.
  • Structuring and negotiating a variety of transactions, including provider-based conversions, physician practice acquisitions, mergers, and acquisitions.
  • Counseling various provider types on complex health care reimbursement and cost report matters, including Medicare, Medicaid and private payor reimbursement, to ensure consistent cash flow and compliance with applicable rules.

Prior to joining Polsinelli, Mary was a consultant at a nationwide health care consulting firm specializing in provider enrollment services, 340B auditing and compliance, certificate of need, micro hospital consulting, IDTF and LTACH consulting.

Education

  • Loyola University Chicago School of Law (J.D., 2019)
    • Certificates in Health Law and Compliance Studies, Beazley Institute for Health Law and Policy Fellow
  • University of Michigan (B.A., 2016)
    • Political Science

Bar Admission

  • Illinois, 2019

Professional Affiliations

  • Chicago Bar Association
  • Illinois Association of Healthcare Attorneys
  • Women’s Bar Association of Illinois

Recognition

  • Named one of Best Lawyers: Ones to Watch® in America in:
    • Administrative / Regulatory Law, 2024-2026
    • Commercial Litigation, 2026
    • Health Care Law, 2023-2026
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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NYBOP May 2026 Deadline Is Fast Approaching: Do Your Pharmacy and Pharmacists Have the Right Licenses?
Key Takeaways: The New York State Board of Pharmacy (NYBOP) issued guidance in December 2025 requiring licensure both for pharmacies and for each individual pharmacist participating in shared pharmacy services arrangements when servicing New York patients. Nonresident pharmacy registration alone is no longer sufficient to satisfy shared services compliance. While this requirement becomes effective May 22, 2026, organizations should not delay taking action now. A proactive assessment and timely remediation of any licensure gaps will be critical to ensuring compliance moving forward. What Organizations Should Be Doing Now Evaluate your shared services model to identify where operations may be impacted; Confirm that all pharmacists supporting or involved in New York operations, including remote personnel, hold appropriate licensure and identify any gaps; Implement proactive compliance measures for any
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