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Allison M. Cohen


Allison Cohen's practice focuses on advising academic medical centers, teaching hospitals, health systems, and other for-profit and non-profit providers on a wide range of Medicare and Medicaid payment, coverage, and compliance issues.

Featured Video

Navigating Through the Termination of COVID-19 Public Health Emergency (PHE) and Other Emergency Declarations August 10, 2022

Professional Biography

Ms. Cohen counsels health care providers and suppliers with respect to Medicare coverage and reimbursement issues, including those relating to graduate medical education payments, billing for inpatient and outpatient services, cost reporting issues, complying with provider-based rules, the 60-day Overpayment Rule, and the False Claims Act. On behalf of clients, she also provides advice on structuring agreements and arrangements between providers and suppliers to comply with applicable billing and reimbursement requirements as well as federal fraud and abuse laws and regulations. In addition, Ms. Cohen has experience with Medicare audits and appeals and representing health care organizations in Provider Reimbursement Review Board appeals.

Ms. Cohen is active in providing regulatory counsel with respect to telehealth arrangements and agreements to provide other remote or digital health services. In this area, her practice includes analyzing and structuring telemedicine agreements between hospital systems, practitioners, and other health care providers. She regularly evaluates telemedicine arrangements and provides guidance regarding reimbursement, fraud and abuse, licensure, scope of practice, supervision, and corporate practice of medicine matters.

Her recent engagements have included advising clients on regulatory issues related to:

  • Provider-based rules and co-location guidance
  • Incident to, split/shared, and teaching physician billing rules
  • Establishment of new medical and dental residency programs
  • Medicaid, state medical board telehealth requirements, supervision, and scope of practice issues for national providers and suppliers

Prior to joining Baker Donelson, Ms. Cohen served as a senior policy and regulatory specialist for the Association of American Medical Colleges (AAMC), and as a public policy specialist for the Susan G. Komen Advocacy Alliance.

  • American Health Law Association (AHLA)
    • Vice Chair, Academic Medical Centers and Teaching Hospitals Practice Group (July 1, 2023 – present)
  • District of Columbia Bar Health Law Community
    • Chair, Steering Committee (July 1, 2020 – July 1, 2023)
    • Co-Chair, Steering Committee (July 1, 2018 – June 30, 2020)
    • Co-Chair, New Practitioners Committee
  • Member – Women's Bar Association of the District of Columbia 
  • Co-presenter – "The Intricacies of Billing with APPs, Residents, and Auxiliary Personnel: Which Rules Apply and What Do They Require?," with Chip Hutzler, Partner, HMS Valuation Partners, AHLA Institute on Medicare & Medicaid Payment Issues (March 2023)
  • "AHLA Telemedicine Webinar Series Part I: The Evolving Telehealth Framework" (March 2023)
  • "Graduate Medical Education (GME) Payment Update," 2023 ADEA Annual Session and Exhibition (March 2023)
  • Co-presenter – "Alexa, Call My Doctor, Telehealth and Virtual Care in a Post-COVID PHE World," with Catherine Allison, Assistant General Counsel, University of Kentucky and Gayle Lee, Director of Physician Payment Policy and Quality, Association of American Medical Colleges, AHLA Academic Medical Centers and Teaching Hospitals Institute (January 2023)
  • "You Used to Call Me on My Cell Phone: Preparing for Post-PHE Telehealth," ABA Physicians Legal Issues: Healthcare Delivery & Innovation Conference (September 2022)
  • "Preparing for Post-PHE Telehealth," NCHCA CLE (September 2022)
  • Co-presenter – "Telehealth Soup to Nuts," with Gayle Lee, Director, Physician Payment Policy and Quality, AHLA In-House Counsel Program, Chicago, Illinois (June 2022)
  • "Innovations in Healthy Aging 2022 Summit: Bridging Academia and Industry" (June 2022)
  • "Graduate Medical Education (GME) Payment Update," 2021 American Dental Education Association Annual Session and Exhibition (March 2021)
  • "Legal Liability Considerations Arising Out of Telehealth Interactions," AHLA Long Term Care and the Law 2021 (March 2021)
  • "Integrating Telemedicine and Communications Technology-Based Services in Hospitals, Health Systems, and Physician Practices," AHLA Virtual Physicians and Hospitals Law Institute 2021 (February 2021)
  • "The Integration of Telemedicine and Communications Technology-Based Services in the Teaching Hospital Environment During the COVID-19 Public Health Emergency and Beyond," AHLA Virtual Academic Medical Centers and Teaching Hospitals Institute 2021 (January 2021)
  • "Telemedicine and Telehealth: An Ever-Changing Opportunity and Regulatory Landscape," D.C. Bar Health Law Community (April 2019)
  • "Telehealth: Navigating Emerging Opportunities," CLE Seminar for In-House Counsel (June 2018)
  • "Telehealth Policy Changes CY 2018 Physician Fee Schedule," American Osteopathic Information Association "Connected Care: Telemedicine in Practice," Webinar (December 2017)
  • "GME Funding: Current State and Innovative Proposals," American Osteopathic Association (AOA) Tri-Bureau Meeting (November 2017)
  • "MedPAC and Short Stays," presentation to the COTH Administrative Board (December 2014)
  • "Medicare GME Funding: Current Rules, Growth Opportunities, and a Look to the Future," presentation to Residency Program Directors, University of Virginia Health System (November 2014)
  • "The Two Midnight Rule and Physician Order and Certification Requirements," AHLA Physician In-House Counsel Group Webinar/Educational Call (October 2014)
  • "2015 IPPS/OPPS Payment Rules, Part II: The Can't Miss Issues from the Industry's Perspective," AHLA Regulation, Accreditation and Payment (RAP) Practice Group Webinar (September 2014)
  • "GME Payments: Today and in New Payment Models," presentation to the AAMC Advisory Panel on Healthcare (September 2014)
  • "Update on Medicare's Two Midnight Rule and Related Inpatient Stay Requirements," AHLA Institute on Medicare and Medicaid Payment Issues (March 2014)


  • American University Washington College of Law, LL.M., Health Law & Policy Concentration, 2011
  • University of Maryland School of Law, J.D., 2007
  • Duke University, B.A., Public Policy Studies, 2002


  • District of Columbia
  • Maryland Court of Appeals
  • U.S. District Court for the District of Maryland

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