Ronke Fabayo is an attorney and health care policy professional concentrating in Medicare and Medicaid regulatory and compliance issues. She provides comprehensive counsel to a variety of health care providers including hospitals, laboratories, pharmacies, and specialty providers. Ronke supports these providers with private and federal reimbursement issues and disputes.

Prior to joining Polsinelli, Ronke served as the Division Director for the Division of Medicare Enrollment and Eligibility Policy of Centers for Medicare and Medicaid Services (CMS), where she concentrated on regulatory issues related to traditional Medicare and Medicare Advantage enrollment.  During her tenure at CMS, she worked on Stark law matters, was part of the team that developed the CMS Voluntary Self-Referral Disclosure Protocol and provided technical assistance on fraud and abuse investigations and litigation.  She contributed to other areas of federal health policy including, settlement of provider payment disputes, provider debt resolution and Medicare plan marketing requirements.

Education

  • University of Maryland Francis King Carey School of Law (J.D., 2006)
    • Brown University (B.A., 2000)
      • Community Health

    Bar Admission

    • Georgia
    • District of Columbia
    Publications
    New OIG FAQ Warns Fair Market Value Alone Does Not Shield AKS Liability
    Key Takeaways OIG’s new FAQ #17 reiterates that fair market value alone does not eliminate risk under the Federal Anti-Kickback Statute and emphasizes that AKS compliance depends on the full facts and circumstances, including intent. The FAQ reinforces that health care organizations cannot rely solely on FMV analyses or commercial reasonableness opinions when structuring arrangements involving referral sources. OIG stated that safe harbor protection requires compliance with all applicable conditions, not just FMV requirements. The U.S. Department of Health and Human Services Office of Inspector General (OIG) updated its General Questions Regarding Certain Fraud and Abuse Authorities FAQ page on April 23, reinforcing a point that OIG has articulated in prior rulemaking, advisory opinions, compliance guidance and enforcement actions: compliance with fair market
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    Election Year Politics and Policy at CMMI: What Stakeholders Can Expect
    Key Takeaways CMS’ Innovation Center is accelerating new payment and care delivery models as the Trump administration uses CMMI to advance health policy priorities. Current models target areas such as chronic care, behavioral health, drug pricing and value-based care. CMMI remains a powerful policy vehicle, but its recent pace has drawn renewed scrutiny over cost savings, scale and taxpayer value. That debate could shape oversight, legislation and expectations for how future models are designed and evaluated. Health care stakeholders should continue tracking CMMI closely as participation opportunities expand and mandatory models create new operational demands. Organizations should assess where engagement, compliance planning or advocacy may be needed as models evolve. The Centers for Medicare & Medicaid Services (CMS) is currently pursuing approximately 35 models
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