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 significant experience working with health care providers to comment on proposed federal and state rules and legislation, including comments addressing Medicaid managed care, Medicare reimbursement cuts, CMS Innovation Center models, the 340B Drug Pricing Program, the federal substance-use-disorder privacy regulations, Knox-Keene licensing requirements, and FQHC reimbursement.

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)


  • 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

  • “Medicaid Payment Reform – Uncertain Future of Supplemental Payments,” Presentation to American Health Lawyers Association (May 5, 2020)
  • “COVID-19: CARES Act Overhauls Federal Substance Use Disorder Privacy Law,” Foley's Coronavirus Resource Center & Health Care Law Today (March 26, 2020)
  • “FQHCs: Practical Impacts of Governance Requirements,” Health Care Law Today (January 8, 2020)
  • “FQHCs: Four Reimbursement Traps for the Unwary,” Health Care Law Today (December 9, 2019)
  • “CMS Proposed Enhanced Scrutiny over Medicaid Supplemental Payments,” Health Care Law Today (November 20, 2019)
  • “FQHCs: The Nuts and Bolts of Medicaid Reimbursement,” Health Care Law Today (November 13, 2019)
  • “Five Tips for Contracting with Federally Qualified Health Centers,” Health Care Law Today (November 7, 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)
  • “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)
  • “California Medicaid Agency Proposes Significant Restrictions on FQHC and RHC Reimbursement,” Health Care Law Today (March 13, 2018)
  • “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)
  • “Battling the Opioid Epidemic: A Legislative Update,” ACC Docket, Vol. 35, No. 8 (October 1, 2017)
  • “Health Care Reform Returns to the Spotlight,” Health Care Law Today (September 18, 2017)
  • “Ninth Circuit Victory Opens the Door to Medicaid Reimbursement Challenges Based on Equal Access Requirement,” AHLA Bulletin (August 23, 2017)
  • “Proposed Rule Would Slash Medicare Payment for 340B Drugs,” Health Care Law Today (July 20, 2017)
  • “Senate Releases Repeal and Replace Legislation on ACA: The Better Care Reconciliation Act of 2017,” Health Care Law Today (June 27, 2017)
  • “SAMHSA Proposes Major Changes to Federal Substance Abuse Privacy Rule,” Health Care Law Today (February 9, 2016)
  • “Potential Part B Drug Payment Cuts for 340B Hospitals,” Health Care Law Today (January 19, 2016)
  • “New Guidance Outlines Requirements for State Innovation Waivers,” Health Care Law Today (December 17, 2015)
  • “Court Strikes Down 340B Orphan Drug Rule Again: Will This Impact the “Mega Guidance?” Health Care Law Today (October 19, 2015)
  • “CMS Proposes Major Update to Medicaid Managed Care Regulations,” Health Care Law Today (May 28, 2015)