Sarah R. Kocher

Sarah Kocher enjoys navigating the ever-evolving and complex healthcare regulatory environment. From experience as both external and in-house counsel, she has an in-depth and nuanced perspective on the challenges facing health care systems and other healthcare providers. She brings a practical approach to these challenges, and has worked closely with health system executives to operationalize strategies for compliance.

Sarah most recently served as in-house associate counsel at the University of Rochester Medical Center.

Sarah’s experience allows her to partner with hospitals, academic medical centers, pharmacies, and other clients in identifying, managing, and minimizing risks across an array of healthcare regulatory matters in a tailored and efficient manner. Key practice areas:

Regulatory and reimbursement compliance
Telehealth
Behavioral health
Fraud and abuse
State licensure
Internal and government investigations
Pandemic response and preparedness

Education

Saint Louis University School of Law (J.D., magna cum laude, 2012)
- Saint Louis University Law Journal
The Catholic University of America (B.A., summa cum laude, 2009)
- Philosophy/Pre-Law

Bar Admission

Missouri
New York

Professional Affiliations

American Health Lawyers Association – Member
American Health Lawyers Association – Vice Chair of Educational Programming for RAP – Accreditation, Certification, and Enrollment Affinity Group, 2019-2021

Recognition

Saint Louis University School of Law 1843 Scholar—full-tuition merit scholarship
First Place, 2012 National Transactional Health Law Competition, Chicago, IL

Publications

All Publications

Mandatory Provider-Based Attestations Make a Comeback

After a nearly 24-year hiatus from the mandatory provider-based attestation requirement, the Consolidated Appropriations Act of 2026 (Act, signed into law on Feb. 3, 2026), mandates (again) that hospitals file attestations of compliance with the provider-based regulations for all off-campus provider-based locations. Attestations must be filed before Jan. 1, 2028, with more specific timing to be further defined by CMS. Failure to do so by that date will result in payment reduction under the Hospital Outpatient Prospective Payment System (OPPS). Key Takeaways Hospitals must file attestations for all off-campus provider-based locations pursuant to either (a) the existing attestation regulations at 42 C.F.R. § 413.65(b)(3) or (b) new regulations that CMS must establish under the Act. All initial attestations must be filed within the

Polsinelli is pleased to share the Health Care Reimbursement Newsletter. This publication contains articles and insight into issues that affect Reimbursement. In this issue: Steps Congress May Take To Fix Reimbursement in 2025 Six Updates to Provider Enrollment in 2024 You Need to Know Utilization Management Changes to Medicare Advantage New Year, New 340B Program? Manufacturers Seek to Change the 340B Program Landscape Reimbursement Perspectives from the Host of The 10 Minute HealthBizCast The Latest in Government Audits: Three Lessons for Providers Medicaid in 2025: What Stays, What Changes and How to Prepare Continued Focus on the No Surprises Act and Hospital Price Transparency What You Need to Know About Home Health & Hospice Reimbursement in 2025 CMS Updates its Interpretation of the 60-Day Overpayment Rule IPPS Highlights Medicare Physician Fee Schedule Skilled Nursing Facility