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Thomas W. Coons

Senior Counsel

Thomas W. Coons represents a broad range of health care providers and practitioners, and focuses his practice on Medicare and Medicaid payment issues.

Featured Experience

Represented a private health system in successful litigation against CMS medical education payment issue regarding FTE calculation during cap "base year."

Represented a large private health system in successful litigation case against CMS involving whether off-campus location satisfied Medicare's provider-based rules.

Guided hundreds of hospitals and their counsel through Medicare's rules related to site neutrality payments, space sharing arrangements, co-mingling of personnel and other survey, certification, and provider-based issues.

Professional Biography

Overview

Mr. Coons has a long history of counseling and litigating on behalf of hospital systems, academic medical centers, community hospitals, and other health care entities regarding Medicare payment, coverage, and compliance. He is a national authority on a variety of issues, including Medicare's provider-based rules, payments for graduate medical education, Medicare's nursing and allied health rules, and Medicare's teaching physician rules, as well as other issues that hospitals frequently face.

Mr. Coons is a former member of the board of directors of the American Health Lawyers Association (AHLA), is the past chair of that organization's Medicare and Medicaid Payment Institute, and is a Fellow of the organization. He is a frequent speaker at conferences on Medicare payment and compliance issues. 

Before entering private practice, Mr. Coons served as senior attorney in the Office of the General Counsel at the Department of Health and Human Services where he handled major controversies involving reimbursement and coverage under the Medicare program. Prior to that, Mr. Coons was in private practice where he was engaged in civil and white collar criminal matters, including the representation of a major Watergate figure.

Representative Matters
  • In settlement with government, recovered more than $60 million for hospitals seeking additional Medicare DSH payments.

  • Represented a private health system in successful litigation against CMS medical education payment issue regarding FTE calculation during cap "base year."

  • Represented a large private health system in successful litigation case against CMS involving whether off-campus location satisfied Medicare's provider-based rules.

  • Guided hundreds of hospitals and their counsel through Medicare's rules related to site neutrality payments, space sharing arrangements, co-mingling of personnel and other survey, certification, and provider-based issues.

  • Counseled hundreds of hospitals and their counsel regarding Medicare's rules pertaining to medical education payments, including establishing new teaching hospitals and new programs, training in non-hospital sites, special rules for foreign medical graduates, per resident amount calculations, FTE counts and caps, and other issues.

  • Successfully obtained a reversal of CMS sanctions on behalf of a hospital following a survey of the hospital arising from a patient's death.
Professional Honors & Activities

Professional Memberships

  • Member – American Bar Association
  • Member – American Health Lawyers Association (AHLA)
    • Fellow (2010 – present)
    • Board of Directors (2004 – 2009)
    • Life Members
      • Chair (2015 – 2016)
    • AHLA Institute on Medicare and Medicaid Payment Issues
      • Co-chair, Program Planning Committee (1998 – 2003)
      • Mentoring Program
    • Public Interest Contributor
  • Member – District of Columbia Bar Association
    • Section on Health Law
      • Chair (1999 – 2000)

Honoraries

  • Fellow – American Health Lawyers Association
  • Listed in The Best Lawyers in America®, Health Care Law Category (2010 – 2020)
  • Listed in Maryland Super Lawyers, Health Care (2007, 2009 – 2010, 2013) 
  • Listed in Expert Guides to the Leading Lawyers – Best of the Best USA 2007, 2009 Healthcare Category
  • AV® Preeminent™ Peer Review Rated by Martindale-Hubbell
Professional Background
  • Office of the General Counsel, Health Care Financing Division, Department of Health and Human Services, Attorney
  • Law Clerk to the Honorable Alexander Harvey, II, United States District Court for the District of Maryland
Publications

Industries

Education

  • Georgetown University Law Center, J.D.
    • Law Fellow
    • Editor – Journal of Law & Policy in International Business
  • University of Tennessee, B.S.

Admissions

  • District of Columbia
  • Maryland
  • Virginia
  • Court of Appeals of Maryland
  • Court of Appeals of the District of Columbia
  • Supreme Court of Virginia
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. Court of Appeals for the Fifth Circuit
  • U.S. Court of Appeals for the Fourth Circuit
  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Court of Appeals for the Seventh Circuit
  • U.S. Court of Appeals for the Third Circuit
  • U.S. Supreme Court

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