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Christopher frequently handles mergers and acquisitions of healthcare enterprises and structuring business transactions among healthcare providers to address the industry's changing business and regulatory environment. He also handles operating issues affecting both for-profit and tax-exempt healthcare providers, including hospitals, physician groups and group purchasing organizations (GPOs).

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J.D., University of Tulsa College of Law, 1998

B.A., University of Tulsa, 1991

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Christopher regularly advises healthcare clients, including large healthcare systems, physician groups and other healthcare companies, on various corporate, regulatory and compliance matters, including the following:
<ul>
<li>Advises clients on the development and operation of clinically integrated networks (CINs) and Accountable Care Organizations (ACOs) that participate in the Medicare Shared Savings Program (MSSP) and other Centers for Medicare &amp; Medicaid Services’ (CMS) ACO Models.</li>
<li>Provides counsel on developing and operating group purchasing organizations (GPOs), including forming new GPOs, contracting and regulatory/compliance matters.</li>
<li>Advises health care companies with respect to state corporate practice of medicine, physician fee-splitting, anti-kickback and physician self-referral matters, including making disclosures under CMS’s Stark Law Self-Referral Disclosure Protocol (SRDP).</li>
<li>Advises on structuring transactions and negotiating and drafting agreements, including acquisition agreements, joint venture agreements, affiliation agreements, hospital service line management and professional service agreements and “friendly PC” agreements.</li>
<li>Advises clients on mergers and acquisitions of healthcare enterprises and structuring business transactions among healthcare providers to address the industry&#8217;s changing business and regulatory environment.</li>
<li>Counsels clients on HIPAA privacy and security policies for healthcare providers (covered entities) and IT companies (business associates).</li>
<li>Counsels clients with respect to drafting and negotiating health information technology (IT) agreements.</li>
</ul>
Accountable Care Organizations and Clinically Integrated Networks
<ul>
<li>Provides counsel on developing and operating ACOs, including applying to CMS to participate in the MSSP and other CMS ACO Models.
<ul>
<li>Advises in structuring ACOs, including single and regional ACO health system models, joint venture and collaboration efforts among independent ACOs, etc.</li>
<li>Advises clients as they expand their ACO activities (e.g., ACO fraud and abuse waiver arrangements, integrating with physicians and post-acute care providers, commercial value-based payor contracting, etc.).</li>
</ul>
</li>
<li>Advises clients on the development and operation of CINs and third-party payor contracting, including value-based payor arrangements.</li>
</ul>
Group Purchasing Organizations and Related Arrangements
<ul>
<li>Served as the lead attorney in representing various clients in connection with the development and operation of group purchasing organizations (GPOs), including negotiating related GPO agreements (e.g., GPO member agreements, vendor agreements, etc.) and compliance/regulatory matters.</li>
<li>Represented a state hospital association in structuring a long-term arrangement with a national GPO to operate a regional GPO.</li>
<li>Advised a GPO client with respect to strategic planning in connection with its traditional group purchasing activities and related activities (e.g., distributions, private label, etc.).</li>
<li>Advised healthcare clients with respect to compliance with the Federal Anti-Kickback Statue, the Robinson-Patman Act and the Nonprofit Institutions Act.</li>
</ul>
Structuring Hospital/Physician Integration Arrangements
<ul>
<li>Advises both hospital and physician groups in developing comprehensive management and professional services arrangements, including structuring, drafting and negotiating related agreements (e.g., acquisition/lease agreements, professional services and management agreements, etc.).</li>
</ul>

Christopher N. Kanagawa

Christopher N. Kanagawa

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