Adam J. Hepworth

Senior Counsel


Adam J. Hepworth is a senior counsel and health care lawyer with Foley & Lardner LLP. His practice focuses on Medicaid and Medicare, internal audits and investigations, health privacy laws, and compliance with health care fraud and abuse laws.

Adam has represented hospitals, Federally Qualified Health Centers (FQHCs), and other providers in numerous Medicaid administrative appeals. He argued Tulare Pediatric Health Care Center v. State Department of Health Care Services, resulting in a decision from the California Court of Appeals recognizing the State’s obligation to pay FQHCs a Medi-Cal per-visit rate that reflects their full costs when they contract with an outside medical group.

Adam has written, presented, and counseled clients on how to navigate federal and state health privacy laws—including HIPAA and the federal substance-use-disorder privacy regulations at 42 CFR Part 2—when developing integrated models of care that address the social determinants of health. He has also helped clients pursue reimbursement opportunities available for innovative delivery systems under Medicaid waiver programs and advanced payment models.

Adam has often assisted health care providers to comment on federal and state rules addressing Medicaid managed care, Medicaid and Medicare reimbursement, the 340B Drug Pricing Program, HIPAA, the federal substance-use-disorder privacy regulations, and Knox-Keene licensing requirements. He has also worked on state legislation addressing FQHC reimbursement, telehealth, Medicaid waiver programs, and mental health delivery systems.

Prior to joining Foley, Adam was a law clerk for Judge Harris L Hartz on the United States Court of Appeals for the Tenth Circuit.


  • Recognized, The Best Lawyers in America®: Ones to Watch (2021)
  • Recognized, Chambers USA, Healthcare (2020-2021)


  • Stanford Law School (J.D., 2013)
    • Co-editor, Stanford Journal of Law, Science, and Policy
    • Student fellow, Center for Law and the Biosciences
  • Stanford University (B.A., with distinction, 2009)
    • Phi Beta Kappa
    • Interdisciplinary Honors, Ethics in Society


  • California

Professional Memberships

  • Member, California Society for Health Care Attorneys
  • Member, American Health Lawyer’s Association
  • Member, Los Angeles County Bar Association (Health Law Section)

Selected Publications and Presentations

  • “Federally Qualified Health Centers (FQHCs) – Overview and Emerging Issues,” Presentation to AHLA Educational Call (April 9, 2021)
  • Co-author, “Congress Requires New Reporting for States That Make Medicaid Supplemental Payments,” Health Care Law Today (February 23, 2021)
  • “Diving Deeper into the Revised Stark and Kickback Rules,” Foley & Lardner Webinar Presentation (January 26, 2021)
  • Co-author, “New HHS Board Will Hear 340B Drug Pricing Disputes,” Health Care Law Today (December 15, 2020)
  • “Social Determinants of Health: Use of Medicare and Medicaid Funds,” Presentation to County Counsel’s Association of California’s Health and Welfare Fall 2020 Study Section Meeting (October 29, 2020)
  • “Digging Deeper in Your Audits: An Investigative Approach to Effective Compliance, the 60-day Rule, and Identifying Overpayments,” Presentation to AHLA Virtual Fraud and Compliance Forum (September 29, 2020)
  • Co-author, “Patient Records: Part 2 Final Rule Reduces Substance Use Disorder Record Sharing Barriers,” Health Care Law Today (July 15, 2020)
  • “Medicaid Payment Reform – Uncertain Future of Supplemental Payments,” Presentation to American Health Law Association (May 5, 2020)
  • Co-author, “COVID-19: CARES Act Overhauls Federal Substance Use Disorder Privacy Law,” Foley's Coronavirus Resource Center & Health Care Law Today (March 26, 2020)
  • Co-author, “FQHCs: Practical Impacts of Governance Requirements,” Health Care Law Today (January 8, 2020)
  • Co-author, “FQHCs: Four Reimbursement Traps for the Unwary,” Health Care Law Today (December 9, 2019)
  • Co-author, “CMS Proposed Enhanced Scrutiny over Medicaid Supplemental Payments,” Health Care Law Today (November 20, 2019)
  • Co-author, “FQHCs: The Nuts and Bolts of Medicaid Reimbursement,” Health Care Law Today (November 13, 2019)
  • Co-author, “Five Tips for Contracting with Federally Qualified Health Centers,” Health Care Law Today (November 7, 2019)
  • Co-author, “Proposed Changes to Part 2 Rules Ease Substance-Use Disorder Record Sharing,” Health Care Law Today (August 27, 2019)
  • “Yes, We Can Share Behavioral Health Data: Common Misconceptions and Barriers to Information Exchange,” Presentation at Michigan Health Information Network Legal Summit (June 3, 2019)
  • Co-Author, “DC District Court Holds that Medicare Payment Cuts for 340B Drugs Exceeded Agency’s Authority,” Health Care Law Today (January 8, 2019)
  • “Substance Use Disorder Privacy Laws: Navigating Federal and State Requirements,” Presentation at Health Care Compliance Association, San Francisco Regional Conference (November 30, 2018)
  • “Recent Trends and Hot Topics in Healthcare: Unraveling the ACA,” Presentation to Association of Corporate Counsel (August 7, 2018)
  • “42 CFR Part 2 and Integrated Models of Care,” Presentation to Florida Hospital Association (March 28, 2018)
  • Co-author, “California: Proposed Legislation Regulating Health Care Rates for Payors and Providers,” Health Care Law Today (April 19, 2018)
  • Co-author, “California Medicaid Agency Proposes Significant Restrictions on FQHC and RHC Reimbursement,” Health Care Law Today (March 13, 2018)
  • Co-author, “SAMHSA Finalizes Second Round of Changes to Federal Substance Use Disorder Privacy Rule,” Health Care Law Today (January 11, 2018)
  • “Administrative Enforcement Tools,” Health Law Handbook, 2017 Edition (2017)
  • “Medicaid Reimbursement Update,” Presentation to County Counsels’ Association of California (November 17, 2017)
  • “Ninth Circuit Victory Opens the Door to Medicaid Reimbursement Challenges Based on Equal Access Requirement,” AHLA Bulletin (August 23, 2017)