• vcard
  • Education
    • J.D., University of Pittsburgh School of Law, 2005, Certificate in Health Law; Tuition Scholarship; Pittsburgh Tax Review, Assistant Articles Editor; National Health Law Moot Court, Member; CALI Award – Healthcare Fraud & Abuse
    • M.P.H., Columbia University, School of Public Health, 1998
    • A.B., Dartmouth College, 1995
With more than a decade of practical experience, a solid understanding of the health care industry and a commitment to client service, Tony Choe helps clients achieve their business goals and navigate the dynamic landscape of U.S. health care laws. Tony provides strategic, pragmatic and actionable legal advice on federal and state health care issues to a variety of health care organizations, including: 
  • Integrated health delivery systems 
  • Provider-sponsored health plans
  • Health plan services vendors 
  • Practice management companies
  • Hospitals, ambulatory surgery centers, long-term care and other health facilities 
  • Pharmacies and DMEPOS suppliers
  • Laboratories and IDTFs
  • Practitioner groups, retail clinics and urgent care centers
  • Telehealth companies 
  • Private equity sponsors and their portfolio companies
  • Health care industry investors 
Clients turn to Tony on an array of complex regulatory, compliance and transactional matters, with a focus on: 
  • Compliance with Medicare Advantage, Medicare Prescription Drug Plan and state Medicaid managed care program requirements 
  • Developing, negotiating and implementing innovative payment/reimbursement arrangements with payors (e.g., value-based, risk/revenue sharing) 
  • Establishing integrated delivery systems, IPAs, ACOs, practice management arrangements 
  • Negotiating contracts with health care professionals and vendors for health care and administrative (e.g. care coordination, data analytics, RAPS/EDPS/STARS/HEDIS data collection and outreach) services 
  • Advising on structuring issues, conducting regulatory due diligence and negotiating agreements in connection with M&A and financing/investment transactions 
  • Compliance with federal and state fraud and abuse laws (e.g., federal Anti-Kickback Law, Physician Self-Referral (“Stark”) Law, the Civil Monetary Penalties Law)
  • Establishing telehealth platform businesses, compliance with telehealth laws and trends in telehealth reimbursement 
  • Compliance with state licensure and certification requirements, including corporate practice of medicine and fee-splitting restrictions
  • Developing and implementing effective corporate compliance programs 

Prior to joining Polsinelli, Anthony advised national and regional health insurers, third party administrators, pharmacy benefits managers, dental benefits carriers, care coordination companies and other managed care entities and vendors. Coupled with his non-legal experience as a Manager for the National Committee on Quality Assurance (NCQA), a leading accreditation body for managed care organizations, and as a Managed Care Project Manager for IPRO, the Medicare quality improvement organization for New York State, Tony’s breadth of experience with payors allows him to offer critical insights and perspectives to providers and other clients.  
  • Advised a managed care organization in connection with a federal investigation of its Medicare Advantage plans
  • Conducted an external assessment of a Medicaid managed care organization's corporate compliance program
  • Conducted an external compliance assessment of a Medicare Advantage Organization's processes and procedures to prepare and submit data to CMS's Risk Adjustment Processing System (RAPS)
  • Advised Medicare Advantage Organizations on regulatory compliance and program participation matters (e.g., marketing practices, vendor oversight, compliance program structure, electronic health record (EHR) incentive payments)
  • Drafted care coordination and subcontractor agreements for Dual-Eligible Special Needs Plan (D-SNP) in connection with the plan's participation in a state pilot program
  • Advised a dental services organization on various Medicare Advantage program requirements
  • Advised a Fortune 100 company on transactional and regulatory matters in connection with its national network of pharmacies and optical stores, including its transactions and arrangements with practice management companies and healthcare professionals
  • Advised the medical device division of a Fortune 100 company on its consulting and royalty arrangements with health care professionals
  • On behalf of a private-equity backed practice management company with operations in several states, conducted regulatory due diligence reviews and risk assessments of pain management clinics and related businesses, negotiating and drafting transactional documents, assisting with regulatory change of ownership (CHOW) and change of information notifications and consents, and providing healthcare regulatory compliance counseling in connection with ongoing their operations
  • On behalf of a private equity client, conducted regulatory due diligence reviews of various healthcare companies targeted for acquisition, including companies that conduct data analytics, case management, HEDIS and other services for managed care organizations, large physician practices, and a mail order pharmacy 
  • On behalf of another private equity client, conducted regulatory due diligence reviews of various health care companies targeted for acquisition, including large physician and podiatric practices and drug treatment centers
  • Conducted an internal investigation of a hospital and assisting with its CMS Stark Law Self-Disclosure Protocol submissions
  • Negotiated managed-care participation agreements for a large university hospital
  • Represented hospice and other provider entities in connection with Medicare payment appeals arising from ZPIC and other overpayment audits/reviews
  • Advised a national sleep laboratory services provider on transactional, compliance and fraud and abuse issues arising from its relationships and affiliations with hospitals and other health care entities
  • Advised a national retail pharmacy chain on regulatory matters concerning the use of kiosks, discount card arrangements, coordination of benefits, and arrangements with health plans
  • Advised a mail order pharmacy on transactional, regulatory and fraud and abuse matters in connection with proposed marketing arrangements and business transactions
  • Helped clients establish physician practice and management entities, including the formation of professional corporations and limited liability companies
eAlerts Updates
February 2020
text icon Publications & Presentations
Co-Author, AHLA
May 2018
text icon Publications & Presentations
AHLA Institute on Medicare and Medicaid Payment Issues
March 16, 2018
text icon Publications & Presentations
Presenter, Health Care Compliance Association - Kansas City Regional Conference
September 25, 2017
text icon Publications & Presentations
Co-Presenter, Health Care Compliance Association - Kansas City Regional Conference
September 25, 2017
text icon Publications & Presentations
2017 EDPMA Solutions Summit; San Diego, CA
April 28, 2017
text icon Publications & Presentations
AHLA Institute on Medicare and Medicaid Payment Issues
AHLA Institute on Medicare and Medicaid Payment Issues
March 30, 2017
Related News

Past Events