Anil Shankar


Anil Shankar is a health care lawyer who 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. He is a partner in the firm’s Health Care & Life Sciences Sector.

Anil has been recognized by Chambers USA: America’s Leading Business Lawyers:

“Anil is brilliant. He has a knack for assimilating information and boiling complicated issues down to their essence. He exercises good judgment and has an intuitive understanding of our risk profile. He can also be creative.”

Medicaid Experience

Anil advises hospitals, clinics, health systems, other providers, managed care plans, and governmental entities on their participation in Medicaid programs. He has helped develop innovative new programs, including Medicaid supplemental payments, quality networks, state and local provider taxes or assessments, and public-private partnerships. He has extensive experience in the use of health care funding to address the social determinants of health and helped to design and implement California’s Whole Person Care pilots, which operate innovative programs 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 also assisted numerous companies seeking to enter the Medicaid program. Anil also has deep knowledge of Medicaid managed care and has helped plans and providers evaluate regulatory changes and structure alternative payment methodologies to meet their goals.

Anil has also successfully obtained millions of dollars of Medicaid funding providers and mental health delivery systems through successful challenges to program audits and disallowances.

340B Drug Pricing Program

Anil heads the firm’s robust 340B Drug Pricing Program practice, which counsels hospital systems, federally qualified health centers, and federal grantees with regard to their obligations and opportunities under the program. He advises clients on compliance and overpayment issues, 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.

Federal Relief and Grant Funds

During the coronavirus pandemic, Anil advised hospitals, health systems, governmental entities, nursing facilities, and other health care companies regarding their application, receipt, and use of federal relief funds, including the Provider Relief Fund and Coronavirus Relief Fund. He helped clients develop tracking and documentation systems, counseled providers regarding both over- and under-payments of funds, and drafted policies and procedures for use and reporting of funds. He advises recipients of grant funds on federal audits.

Awards and Recognition

  • Chambers USA, Health Care Law (2022 and 2023)


  • Faculty lecturer at the UCLA School of Law (teaches Health Care Compliance)
  • 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-speaker, “Strategies for Working with and Discharging Homeless Populations,” Hospital Association of Southern California’s 2024 Annual Meeting (May 21, 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-author, “COVID-19: Provider Relief Fund General Distribution – Phase 3,” Health Care Law Today (October 5, 2020)
  • Co-author, “COVID-19: HHS Publishes Long-awaited Reporting Requirements for Provider Relief Fund Recipients,” Health Care Law Today (September 23, 2020)
  • Co-author, “COVID-19: Take Two (for some) on Additional DHHS Provider Relief Funding,” Health Care Law Today (August 12, 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: Understanding HHS’s Plans to Disperse Provider Relief Funds Authorized By The CARES Act,” Health Care Law Today (April 27, 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)
  • 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)
  • Co-author, “Ninth Circuit Victory Opens Door to Medicaid Reimbursement Challenges Based on Equal Access Requirement,” AHLA Bulletin (August 2017)
07 November 2023 In the News

Anil Shankar Comments on Court Ruling Expanding Hospital 340B Use

Foley & Lardner LLP partner Anil Shankar is quoted in the Fierce Healthcare article, “'Stunning' court ruling broadens hospitals' 340B use, calls HRSA's enforcement authority into question,” discussing the U.S. District Court of South Carolina’s recent decision in Genesis Healthcare, Inc. v. Becerra.
1-3 November 2023 Events

Moss Adams 2023 Executive Health Care Conference

Partner and co-chair of Foley’s Providers of Health Care Services Area of Focus Larry Vernaglia, and partner Anil Shankar are speaking at the upcoming Moss Adams 2023 Executive Health Care Conference.
26 July 2023 Health Care Law Today

CMS Proposes Remedy for 340B-Acquired Drug Payment Policy for CY 2018-2022

Along with its calendar year 2024 Medicare Outpatient Prospective Payment System proposed rule, the Centers for Medicare & Medicaid Services have also published the long-awaited proposal to remediate the violations that arose from Medicare’s rate cuts for 340B drugs dispensed by 340B hospitals from January 1, 2018 through September 27, 2022.
01 June 2023 Press Releases

Foley Earns Top Rankings in Chambers USA 2023

Foley & Lardner LLP is pleased to announce that it has again been recognized by Chambers & Partners as one of the top law firms in the country in the 2023 edition of Chambers USA, America’s Leading Lawyers for Business.
30 March 2023 Manufacturing Industry Advisor

The Future of the 340B Program: 2023 Key Decisions

Critical decisions are pending before courts and legislators in 2023 that promise to shape the future of the 340B Drug Pricing Program, which provides discounts on outpatient drugs for certain health care providers, referred to as “covered entities.”
25-26 January 2023 Events

What You Should Know About Payor/Provider Convergence

Foley & Lardner invites you to our first What You Should Know About Payor/Provider Convergence program on the West Coast. This informative program will expand on what health systems, health plans, and insurance companies need to know on how to navigate the complex health care system.