Anil Shankar is a partner and health care lawyer with Foley & Lardner LLP, and a member of the firm’s Health Care Practice. He provides strategic counsel to health care providers as they navigate complex regulatory and reimbursement matters, with a particular focus on the Medicaid program and issues affecting safety net providers.
Anil has been recognized by Chambers USA: America’s Leading Business Lawyers:
““He’s smart, patient and always comes up with creative solutions to complicated problems.”
“We often ask Anil to work on thorny issues that he parses with sophistication and nuance that is essential to solving problems.”
Anil is a lecturer at the UCLA School of Law, where he teaches Health Care Compliance.
Medicaid Experience
Anil is a leading expert on the intricacies of the Medicaid program and routinely advises hospitals, clinics, health systems, trade associations, managed care plans, and governmental entities on their participation in Medicaid programs. He regularly counsels clients on the impact of state and federal policy changes and helps identify and design programs to succeed in a challenging regulatory or reimbursement environment, including demonstration projects, quality networks, state and local provider taxes, alternate payment models, and public-private partnerships. He counsels clients on specialized Medicaid payments including disproportionate share hospital (DSH) funding, state-directed payments, upper payment limit reimbursement, and other supplemental funding. He has extensive experience in the use of health care funding to address the social determinants of health, and has helped clients obtain Medicaid funding for individuals experiencing homelessness, individuals leaving incarceration, individuals with significant mental health disorders, and other vulnerable populations.
He advises clients on numerous Medicaid reimbursement and compliance issues, including overpayment investigations and analyses. He has assisted several companies seeking to enter the Medicaid program and has defended providers facing termination or other sanctions from state Medicaid agencies.
340B Drug Pricing Program
Anil has counseled hospitals, clinics, and grantees on their participation in the 340B Drug Pricing Program for more than 15 years. He advises clients on compliance and program design , self-disclosures, internal and governmental audits, 340B contracting, and has helped to restructure entities to maximize 340B Program savings.
Behavioral Health
Anil has extensive experience advising clients on behavioral health reimbursement, operational, and compliance issues. He has counseled hospitals on health systems seeking to expand their behavioral health offerings, including strategic counseling to avoid licensing, regulatory, and reimbursement pitfalls. In addition, Anil has helped design systems to protect and share confidential patient information, including behavioral health information. He works with local behavioral health directors, providers, and managed delivery systems on issues related to funding, reimbursement, program development, and strategic implementation.
Audits and Appeals
Anil advises health care providers and companies to track and oversee federal grants and reimbursement, including hemophilia treatment center funds, Ryan White funds, 340B funds, FQHCs, and has advised them during related audits. He has recovered millions of dollars by successfully challenging Medicaid reimbursement audit findings.
Representative Experience
- Advised multiple California counties on legal considerations and strategies for structuring local indigent care programs to support individuals adversely impacted by implementation of Medicaid cuts.
- Counseled health system on legal obligations and response to 340B program data requests.
- Conducted privileged investigations of multiple billing and compliance issues, including Medicare and Medicaid reimbursement and FQHC billing.
- Successfully appealed and settled a behavioral health provider’s termination from a state Medicaid program, resulting in their reinstatement.
- Reviewed managed care contracts and drafted subcontractor and billing agreements for entities entering the Medicaid program.
Awards and Recognition
- Chambers USA, Health Care Law (2022 – present)
Affiliations
- Faculty lecturer at the UCLA School of Law
- Member, American Health Lawyer’s Association
- Member, California Society for Health Care Attorneys
- Member, Los Angeles County Bar Association (Health Law Section)
- Member, American Bar Association (Health Law Section)
Publications and Presentations
- Co-Author, “New Federal Focus on Fraud, Waste and Abuse May Signal Changes for the Health Care Industry,” Health Care Law Today (April 20, 2026)
- Co-Author, “Immigrant Access to Health Centers: Confronting Unknowns in the Administration’s Revised Interpretation of PRWORA,” ABA Health Law Section (December 2025)
- Presenter, “How H.R. 1 Slashed Medicaid Budgets: What This Means for You,” (October 15, 2025)
- Co-Author, “HHS Plan to Cut Immigrant Benefits Spurs Provider Questions,” Law360 (August 11, 2025)
- Author, “One Big Beautiful Bill: Slashed Budgets Will Disrupt the Medicaid Program,” Health Care Law Today (July 17, 2025)
- Co-author, “Gender-Affirming Care: What the Supreme Court’s Ruling in Skrmetti Means for Health Care Providers Nationwide,” Health Care Law Today (July 1, 2025)
- Co-author, “California Agency Cracks Down on High-Cost Hospitals,” Health Care Law Today (May 6, 2025)
- Co-author, “The 340B Drug Pricing Program: Top Five Things to Know,” Health Care Law Today (September 17, 2024)
- Co-speaker, “Strategies for Working with and Discharging Homeless Populations,” Hospital Association of Southern California’s 2024 Annual Meeting (May 21, 2024)
- Author, “Medicaid: CMS Final Rules Aim to Expand Access, Provide Parity with Commercial Markets,” Health Care Law Today (May 13, 2024)
- Co-author, “Health-Related Social Needs: Three Trends in Leveraging Community Partnerships,” Health Care Law Today (March 27, 2024)
- Co-author, “CMS Proposes Remedy for 340B-Acquired Drug Payment Policy for CY 2018-2022,” Health Care Law Today (July 26, 2023)
- Co-author, “The Future of the 340B Program: 2023 Key Decisions,” Health Care Law Today (March 30, 2023)
- Co-speaker, “Social Determinants of Health,” What You Need to Know About Payor/Provider Convergence (Jan 26, 2023)
- Moderator, “The Urgency of Behavioral Health Integration and Whole Person Care,” Moss Adams Conference (Nov. 3, 2022)
- Author, “California Moves to Transform the Behavioral Health Delivery System – Are Payers and Providers Ready?,” Health Care Law Today (Oct. 31, 2022)
- Co-author, “340B Hospitals Win in Medicare OPPS Supreme Court Decision,” Health Care Law Today (June 21, 2022)
- Co-speaker, “Strategies for Difficulty to Discharge Patients,” California Association of Public Hospitals member meeting (December 8, 2021)
- Presenter, “PRF Reporting,” California Association of Public Hospitals and Health Systems member meeting (September 16, 2021)
- Co-author, “Payment Dispute with a Medicaid Health Plan? State Not Obligated to Help, According to Federal Court,” Health Care Law Today (July 14, 2021)
- Co-author, “Court Sides with Drug Manufacturers in Ongoing 340B Litigation,” Health Care Law Today (June 22, 2021)
- Co-author, “HHS Extends Timeline for Spending Provider Relief Fund,” Health Care Law Today (June 14, 2021)
- Co-author, “Congress Requires New Medicaid Payment Reporting,” Health Care Law Today (February 23, 2021)
- Co-author, “Congress Overrides HHS Guidance on Use of Provider Relief Funds,” Health Care Law Today (January 11, 2021)
- Co-author, “New HHS Board will Hear 340B Drug Pricing Disputes,” Health Care Law Today (December 15, 2020)
- Co-presenter, “COVID-19 Provider Relief Funds – Use of Funds, Attestations, and Risk Analysis,” Foley & Lardner LLP Web Conference (April 28, 2020)
- Co-author, “COVID-19: Federal Agencies Prepare to Distribute Unprecedented Federal Financial Relief for the Health Care Industry,” Health Care Law Today (March 30, 2020)
- Co-author, “CMS Proposes Enhanced Scrutiny over Medicaid Supplemental Payments,” Health Care Law Today (November 20, 2019)
- Co-author, “Voluntary Behavioral Health Integration in Medi-Cal: What Can be Achieved under Current Law,” California Health Care Foundation (October 21, 2019)
- Co-author, “Off-Campus Hospital Outpatient Departments Take Another Hit in CMS Final Rule,” Health Care Law Today (November 14, 2018)
- Co-author, “A Novel Strategy for Increasing Access to Treatment for Hepatitis C Virus Infection for Medicaid Beneficiaries,” Annals of Internal Medicine (July 17, 2018)
- Co-author, “Policy Brief: A novel strategy for increasing access to Hep C treatment for Medicaid beneficiaries,” USC-Brookings Schaeffer Initiative for Health Policy (May 2018)
New Federal Focus on Fraud, Waste and Abuse May Signal Changes for the Health Care Industry
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Immigrant Access to Health Centers: Confronting Unknowns in the Administration’s Revised Interpretation of PRWORA
Foley Attorneys Outline H.R. 1’s Sweeping Changes to Medicaid
How H.R.1 Slashed Medicaid Budgets: What This Means For You
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HHS Guidance Excluding Non-Qualified Aliens from More Federal Programs Raises Questions for Providers and Grantees
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