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  • Education
    • J.D., cum laude, Georgetown University Law Center, 2010, Transnational Legal Studies; Adolph Charles Hugin Endowed Scholarship; Dean's Grant
    • M.P.H., University of Illinois at Chicago, 2006, Epidemiology, Biostatistics
    • B.S., Loyola University-Chicago, 2004, Biology; Loyola National Merit Scholarship

Neal Shah applies his experience in government, private practice, and health care delivery to help identify practical legal solutions to complex regulatory and transactional problems, including: 

  • Helping clients comply with the Stark Law, Anti-Kickback Statute, and similar federal and state fraud and abuse laws
  • Establishing and operating Accountable Care Organizations and other coordinated care arrangements
  • Completing self-disclosures of over payments of fraud and abuse liability, including through the CMS Voluntary Self-Referral Disclosure Protocol (SRDP) and Medicare Administrative Contractor refund processes
  • Structuring transactions to avoid or reduce health care compliance concerns
  • Navigating delivery system reform efforts, including the Medicare Access and CHIP Reauthorization Act (MACRA)

Prior to joining Polsinelli, Neal worked for the Centers for Medicare and Medicaid Services (CMS), where he contributed to many areas of federal health care policy, including the initial implementation of the SRDP, the Medicare Shared Savings Program, initiatives under the Center for Medicare and Medicaid Innovation, and individual market financial management programs under the Affordable Care Act. Neal has also testified before state legislatures to advise on the implications of state self-referral laws for delivery system reform.

  • Represented a hospital system in the development of a joint venture with an academic medical system to operate an inpatient rehabilitation facility, including by structuring the transaction to comply with federal fraud and abuse laws, satisfying state licensure and insurance provisions, and assisting in the transfer of payor and operational contracts. 
  • Advised multiple hospital systems in their efforts to establish Clinically Integrated Networks and Accountable Care Organizations, both with and without aligning with independent community physicians and other partners. 
  • Developed and reviewed physician practice management structures in a variety of states to assure compliance with applicable corporate practice of medicine and fraud and abuse laws. 
  • Prepared and filed multiple self-disclosures under the Voluntary Self-Referral Disclosure Protocol and other refund processes, to reduce providers' federal program liability and achieve compliance with the 60-day overpayment refund obligation. 
  • Assisted national physician organizations to understand and evaluate the impact of relevant federal statutes and rules, and drafted detailed comment letters, testimony, and supporting materials for Congress and CMS on behalf of these organizations. 
  • Provided advice to state physician coalitions on the impact of state healthcare laws, particularly self-referral statutes, and assisted in all phases of efforts to modify such laws, including by negotiating legislative language, testifying before relevant committees, and assisting in preparation of witnesses. 
  • Advised physician practices on legal considerations of proposed or existing physician compensation methodologies and integration of ancillary service lines. 
  • Assisted lenders and private equity firms to perform diligence on proposed transactions involving healthcare entities to assess the risks of such transactions and recommend modifications to applicable transaction documents.
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