Mary Buckley Tobin

Mary Buckley Tobin focuses on regulatory issues affecting health care providers, including hospitals and health systems, home health agencies, pharmacies and physician groups. She advises clients on a variety of complex regulatory and compliance issues, including licensure and enrollment, telehealth reimbursement rules and health care privacy and security. Mary uses her regulatory knowledge to structure arrangements, advise clients at all stages of transactions and assist clients in responding to and remediating a wide range of compliance issues.

Mary has experience providing covered entities with regulatory support related to the 340B drug program. Mary also has advised health care providers on a wide range of pharmacy regulatory issues, including issues related to non-resident pharmacies, shipping controlled substances and remote processing of prescriptions.

Prior to joining Polsinelli, Mary practiced law as an associate at a Chicago based law firm and worked as a health care consultant at a national consulting firm, focusing on clinical research billing compliance. While in law school, she served as a Beazley Institute Health Law Fellow, health law legal writing tutor and was an articles editor on the Loyal University Chicago Law and a member of Annals of Health Law.

Education

Loyola University Chicago School of Law (J.D., 2016)
- Certificate in Health Law & Concentration in Healthcare Compliance
University of Michigan (B.A., University Honors , 2013)
- Political Science

Bar Admission

Illinois

Professional Affiliations

Illinois Association of Healthcare Attorneys
- Membership Committee
American Health Lawyers Association

Recognition

Named one of Best Lawyers: Ones to Watch® in America in Health Care Law, 2025-2026
L. Edward Bryant, Jr. National Health Law Transactional Competition,
- Best Memorandum, 2016
- Overall Champion, 2016
Beazley Institute for Health Law and Policy Fellowship, Loyola University Chicago School of Law, 2015-2016
Dean’s List, Loyola University Chicago School of Law, 2014-2016

Publications

All Publications

Not Just a Form: Eleventh Circuit Upholds CMS-855 Conviction, Expanding Medicare Enrollment Risk

Key Takeaways: The Eleventh Circuit recently upheld a surgeon’s conviction, prison sentence and forfeiture for false ownership disclosures on a CMS-855 Medicare enrollment form, reinforcing that inaccurate enrollment information can carry criminal consequences. The court confirmed that CMS-855 accuracy is not limited to initial enrollment but extends to every submission, including routine updates and revalidations. Providers and suppliers should implement robust CMS-855 verification and oversight controls across all submissions, with a focus on accuracy, consistency and accountability. The U.S. Court of Appeals for the Eleventh Circuit recently upheld an orthopedic surgeon’s conviction, nearly three-year prison sentence and forfeiture of $125,000 for making a false statement, in violation of 18 U.S.C. § 1035, on a Medicare enrollment application.1 This case underscores how false ownership disclosures by

CMS Spring Provider Enrollment Updates

Centers for Medicare & Medicaid Services (CMS) released several pieces of Medicare provider enrollment guidance this spring, both emphasizing current policy and requirements as well as providing guidance and clarification relating to provider enrollment practices and forms. In particular, CMS reminded Medicare providers of the sanctions associated with failure to disclose their “managing employees” and updated its sub-regulatory guidance to clarify that Medicare providers’ legal business name as reported to CMS must very closely match what is listed on its IRS and NPI documentation. In its Medicare Learning Network newsletter released on April 3, 2025, CMS reiterated Medicare enrollment requirements for providers and suppliers to report managing employees or face enrollment deactivation. CMS specified that managing employees are “general managers, business