Chris E. Rossman is a partner with Foley & Lardner LLP, co-chair of the Health Care Industry Team Transactions Work Group, and chair of the Medicare Work Group. He leads the firm's health care practice in Michigan. Mr. Rossman has represented health care clients exclusively throughout his 30+ year career. He has experience in all areas of health care law, with a concentration of experience in the M&A, transactions, reimbursement and payment, and compliance areas. His national practice has resulted in clients in over 25 states.
Mr. Rossman’s M&A and transactional experience has been focused on representing primarily hospitals and health systems. His strong background in reimbursement, payment and compliance issues, compiled with his transactional experience, gives him the ability to provide strategic advice in structuring transactions.
Mr. Rossman’s representative health corporate transactions includes:
- Transaction counsel in the creation of large Midwest health system structured as a Joint Operating Agreement (JOA) between a Catholic and non-Catholic hospital.
- Lead transaction counsel for creation of Texas Health Resources, a $4+ billion dollar health system in the Southwest U.S. The parties were Harris Methodist (Fort Worth), Presbyterian (Dallas), St. Paul (former Daughters of Charity Hospital), and Arlington Memorial (municipal hospital).
- JOA between two large Southwestern U.S. health systems. After two years of work, completion of legal documents and obtaining board approvals, the transaction did not close due to failure to meet all conditions to closure.
- JOA between two large Catholic hospitals in the upper Midwest U.S.
- Acquisition of several Midwestern U.S. hospitals.
- Merger of two Southeast U.S. hospitals. After preparation of legal agreements, the transaction did not close.
- Acquisition of large Michigan hospital by another hospital in the area.
- JOA between two hospitals in Michigan.
- "Sale" of majority interest in Midwest hospital to another area hospital.
- Acquisition by a large Southwest U.S. hospital of two large (100+ physicians each) physician management organizations.
- Represented Midwest health system in several acquisitions or JOAs.
- In total, representation of hospitals and health care systems in over 30 mergers and acquisitions, many of which involved Catholic and other faith-based hospitals and health systems.
- One lesson learned from his transactional experience: We learn more from deals that don't close than we do from deals that do close.
Related transactional experience includes:
- Advice on the creation of accountable care networks (ACOs) and other forms of integrated health care networks that provide coordinated care, including provider networks that contract directly with employer self-insured health plans.
- Creation of physician/hospital joint ventures for a variety of purposes, including ambulatory surgery centers, physician practice organizations, medical services organizations (MSOs) and physician/hospital organizations (PHOs).
- Creation of a wide variety of physician - hospital alignment structures, including clinical service line co-management agreements, other management agreements, under arrangements transactions, physician acquisitions and employment agreements, and on-call arrangements.
- Formation of a variety of forms of entities, including corporations, partnerships, limited partnerships, limited liability partnerships and limited liability companies.
- Review of the corporate structure of health care entities for purposes of compliance, governance, charitable trust, reimbursement and other issues.
Mr. Rossman’s reimbursement and payment experience includes the following:
- Representation of several Medicare group appeals and individual appeals that recovered well over $100,000,000 of Medicare reimbursement for his clients.
- Obtaining the first successful federal district court decision in 2003 upholding Medicare reimbursement for loss on disposition of assets notwithstanding the nonprofit structure of the corporations involved.
- Representation of hospitals in Medicaid lawsuits that successfully challenged state Medicaid policies.
- Advice to clients regarding Blue Cross Blue Shield of Michigan matters, including contract negotiations, appeals, litigation and state regulatory issues.
- Negotiation of managed care provider contracts with a variety of payors.
Mr. Rossman is past chairman of the Reimbursement and Payment Substantive Law Committee of the American Health Lawyers Association, and is a past member of the board of directors of the Southeast Michigan Chapter of the Healthcare Financial Management Association. He currently is the chairman of the board of directors of the Chamber Music Society of Detroit.
Mr. Rossman has been Peer Review Rated as AV® Preeminent™, the highest performance rating in Martindale-Hubbell's peer review rating system. He has also been selected by his peers for inclusion in The Best Lawyers in America® in health care since 1991, named Outstanding Hospital Lawyer - 2004 by Nightingale’s Healthcare News, and selected for inclusion in the 2006 - 2012 Michigan Super Lawyers® lists. In addition, he was named to DBusiness magazine's 2011 and 2012 lists of Top Lawyers in the area of health care law.
Mr. Rossman is a frequent speaker on health legal topics. Representative presentations include:
- Regular speaker at past American Health Lawyers Association (AHLA) Institute on Medicare and Medicaid
- November 2012 HFMA’s 59th Annual Fall Conference, “Accountable Care Organizations – How Provider Organizations are Addressing for Success”
- March 2011 AHLA Institute on Medicare and Medicaid, "ACOs, Medical Homes and Related Integration Initiatives," panelist with CMS representatives and other private attorney
- January 2011, Foley webinar, "Medicare Reimbursement after Health Care Reform – Navigating Significant Changes to Medicare Payment Policies," co-presenter
- October 2010, Michigan Health and Hospital Association Health Foundation Governance Leadership Forum, "ACOs: About as Far Away From Invisible As You Can Get"
- October 2010, The Accountable Care Association 2010 National Conference, "Recent Legal Developments"
- September 2010, Michigan Health Care Financial Management Association (HFMA), "Health Care Reform Law: Changes in Law Affecting Physician/Hospital Affiliation Strategies"
- September 2010, Foley & Lardner’s Executive Briefing Series, "Health Care Reform – Are You Ready for the Major Changes to Your Group Health Plans?"
- April 2010, Foley & Lardner’s Friday Focus Web Conference Series, "Strategies for Coping With Changes to Medicare Payment Policies"
- January 2010, Wisconsin HFMA Mega Conference, "Medicare Bad Debts"
- September 2009, HFMA’s 56th Annual Fall Conference, "Physician/Hospital Alignment - Cutting Edge Strategies: Regulatory and Payment Issues"
- September 2009, Foley & Lardner’s Friday Focus Web Conference Series, "Medicare Provider Enrollment Update and Enforcement Strategies"
- June 2008, Foley & Lardner’s Friday Focus Web Conference Series, "Provider Reimbursement Review Board (PRRB) Rules"
- March 2008, Michigan Institute for Continuing Legal Education’s 14th Annual Health Law Institute, "Hospital/Physician Collaboration"
- 2008, Arkansas HFMA, "Medicare Changes in Recent IPPS Regulations"
- November 2007, Foley & Lardner’s Quality of Care Breakfast Briefing Series, "How to Engage the Medical Staff to Achieve Quality Objectives"
- October 2007, Foley & Lardner’s Quality of Care Breakfast Briefing Series, "The Quality Revolution"
- Fall 2007, Great Lakes HFMA Chapter, "Recent Medicare appeal decisions and developments"
- Fall 2007, Michigan HFMA Fall Conference, "Medical education issues: Reimbursement, financial, compliance"
- June 2007, AHLA in-house counsel portion of annual meeting, "The Legal Ethics of Drafting Legal Opinions: In-House and Outside Counsel Perspectives"
- September 2006, Third Party Reimbursement Updates – Healthcare Financial Management Association – Great Lakes Chapter, "Third Party Reimbursement Updates"
- April 2006, Foley & Lardner’s Friday Focus Web Conference Series, "Medicare Reimbursement Appeals"
- March 2006, Michigan State Bar Association Institute for Continuing Legal Education, "Writing Legal Opinion Letters in Health Law - A Guide to Best Practices"
- January 2006, Foley & Lardner LLP (in association with the American Osteopathic Association) Web Conference, "Workshop on PRRB Appeals"
- November 2005, Foley & Lardner’s Friday Focus Web Conference Series, "Pay for Performance"
- June 2005, Masters Class in Southeast Michigan, presented by Foley & Lardner LLP, "Legal Issues Involved in Hospital Relationships with Blue Cross Blue Shield of Michigan"
- May 2005, Annual Spring Conference of the Western Michigan and Great Lakes Chapters of the Healthcare Financial Management Association, "Billing No Fault Automobile Insurers - Recent Legal Developments and Strategies"
His publications include:
- August 2011, American Health Lawyers Association, "Changes to LTCH Medicare payment rules"
- November 2010 , Foley & Lardner LLP Legal News Alert: Health Care, "CMS Request for Information Reinforces Belief That Many Approaches to ACOs Will Be Allowed"
- August 2010, American Health Lawyers Association, "CMS Issues Final IPPS Rules; Interim Final Rule on Three-Day Payment Window"
- August 2010, American Health Lawyers Association, "Policy and Payment Rate Changes for Inpatient Stays in Acute Care and Long Term Care Hospitals (Inpatient Prospective Payment System)"
- May 2010, Foley & Lardner LLP Legal News Alert: Health Care, "Health Care Reform Legislation Makes Significant Changes to Medicare Reimbursement Methods"
- 2010, Foley & Lardner LLP White Paper, "Transforming Health Care Through Accountable Care Organizations: A Critical Assessment," co-author
- November 2009, Foley & Lardner LLP Legal News Alert: Health Care, "CMS Relaxes Supervision Requirements for Hospital Outpatient Departments"
- September 2009, Foley & Lardner LLP Legal News Alert: Health Care, "No Summer Vacation for CMS: Multiple Significant Developments"
- January 2009, Foley & Lardner LLP Legal News Alert: Health Care, "Clinical Integration: A Guide to Working With the Federal Trade Commission to Enhance Care Through Pro-Patient, Pro-Innovation, Pro-Efficiency Provider Networks"
- January 2009, Health Lawyers Weekly, "Clinical Integration: A Guide to Working With The Federal Trade Commission to Enhance Care Through Pro-Patient, Pro-Innovation, Pro-Efficiency Provider Networks"
- January 2009, Foley & Lardner LLP Legal News Alert: Health Care, "FTC Settles Price-Fixing Charges Against Two Separate Physicians’ Groups"
- August 2008, Foley & Lardner LLP Legal News Alert: Health Care, "Provider Reimbursement Review Board Issues Rules Governing Medicare Part A Appeals and Extends Due Dates for Position Papers"
- May 2008, Foley & Lardner LLP Legal News Alert: Health Care, "CMS Implements Restrictive Rules for Medicare Part A Appeals"
- March 2008, Foley & Lardner LLP Legal News Alert: Health Care, "Medicare Part A Proposed Appeal Rules May Be Finalized in Near Future"
- February 2008, Foley & Lardner LLP Legal News Alert: Health Care, "CMS Issues 2007 Recovery Audit Contractor Status Document"
- January 2008, Foley & Lardner LLP Legal News Alert: Health Care, "CMS Delays Anti-Markup Rule With Respect to Purchased Interpretations and Other Services"
Mr. Rossman received his Juris Doctorate, magna cum laude, from Wayne State University Law School, where he was an editor of the Wayne Law Review. He also received a Bachelor of Arts degree with high honors from Michigan State University. Mr. Rossman is a member of the State Bar of Michigan, Health Law Section, the American Health Lawyers Association, and the Health Law Section of the American Bar Association.