Tessa Lancaster is an investigations lawyer with extensive knowledge in health care, financial services, environmental, and tax government enforcement actions and litigation. Tessa advises on matters involving fraud and abuse enforcement, including in investigations and litigation predicated on the False Claims Act (“FCA”), federal and state Anti-Kickback and Stark laws and Medicare and Medicaid reimbursement and coverage criteria. Tessa provides comprehensive representation and strategic counsel for regulatory considerations to a variety of health care providers, including hospitals and health systems, physician groups, individual health care professionals, home health agencies and long-term care providers. Tessa helps clients with a variety of matters including Medicare and Medicaid compliance, state licensure requirements, and compliance with federal and state fraud and abuse laws.

Tessa’s government investigation practice includes representing professional firms and investors in civil and criminal tax investigations involving syndicated conservation easements. She works closely with Polsinelli tax, environmental litigation, and business insurance attorneys utilizing her investigation skills and experience working with the government with substantive legal knowledge to comprehensively address the increased IRS, Department of Justice and Congressional scrutiny of these deals in recent years. Working with boards of directors and corporate management, Tessa also helps clients address internal compliance matters through developing compliance programs, conducting internal investigations and determining appropriate corrective action.

Prior to joining Polsinelli, Tessa worked at a law firm representing hospitals, health care facilities, physician practices and other health care providers in regulatory, transactional and reimbursement matters. During law school, she interned at the American Medical Association, City of Chicago Law Department, Carle Foundation Hospital and Department of Health and Human Services Office of Counsel to the Inspector General with a Pathways fraud and abuse fellowship.

Education

  • University of Illinois College of Law (J.D., cum laude, 2020)
    • Internet & Symposium Editor, Illinois Law Review
  • University of Michigan (B.A., 2015)
    • History and International Studies

Bar Admission

  • Illinois

Court Admissions

  • U.S. District Court, District of Nebraska

Recognition

  • Named one of Best Lawyers: Ones to Watch® in America in Health Care Law, 2025-2026
Publications
Clock Beats Commissioner: IRS Concedes $48M Easement Case
Key Takeaways On March 23, 2026, the U.S. Tax Court entered a stipulated decision in Agate Holdings LLC, Agate Manager LLC v. Commissioner under which the IRS conceded the partnership’s full $48.3 million deduction for a Louisiana conservation easement donation. The decision provides that accuracy-related penalties and civil fraud penalties do not apply for the 2018 tax year. According to the reported stipulation, the IRS’s concession was based solely on the fact that its Nov. 3, 2023 notice was not timely issued under Internal Revenue Code Section 6235. This development is significant because it highlights how procedural issues can be outcome-determinative in conservation easement cases. The taxpayer had accused the IRS of backdating documents to support otherwise time-barred penalties and adjustments, but the stipulated
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Settlement Dominoes: The FTC’s PBM Playbook Is Going Industrywide
The FTC’s insulin/pharmacy benefit managers (PBM) enforcement matter is starting to look less like a single case—and more like a regulatory reset executed through settlement. On March 3, 2026, the FTC extended the stay in its administrative proceeding against OptumRx and Caremark Rx (and affiliated entities) to allow additional time for settlement negotiations, with the parties disclosing that they are making “significant progress.” This development comes on the heels of the FTC’s Feb. 4, 2026 “landmark” settlement with Express Scripts, Inc., which imposes a 10-year set of operational commitments and compliance oversight tied directly to formulary, pricing, transparency and compensation structures. Why This Matters: Policy by Consent Order The FTC’s original theory—focused on PBM rebate-driven incentives and formulary design affecting insulin access and patient
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