Terra Lord Parten

Representative Experience

• Represented a regional health system in launching an enterprise-wide population health services organization and in structuring participation in alternative payment models.
• Assisted numerous healthcare organizations with COVID-19 related issues including the CARES Act Provider Relief Funds, SBA Paycheck Protection Program, CMS blanket waivers, EMTALA issues concerning over-burdened emergency departments, state surge plans, telehealth flexibilities, vaccine mandates, and state licensure flexibilities.
• Represented a multi-state, post-acute provider enterprise in the multimillion-dollar sale of enterprise involving over 50 business entities.
• Served as general counsel to hospitals and physician practices with respect to all aspects of compliance with their Corporate Integrity Agreement with the Office of Inspector General (OIG) of the Department of Health and Human Services.
• Represented clients in governmental and internal investigations relating to billing and coding issues, OIG-excluded personnel, and Stark Law and federal anti-kickback statute compliance, including preparing self-disclosures to government agencies and negotiating settlements.
• Obtained full dismissal on behalf of physician practice in qui tam case based on alleged Medicare fraud.
• Represented an academic medical center (AMC) in structuring affiliation agreements and financial relationships among AMC components in a manner compliant with the Stark Law and Federal Anti-Kickback Statute.
• Represented healthcare organizations in forming multi-provider joint ventures in compliance with fraud and abuse laws.
• Negotiated the purchase and sale of practices and facilities including advising on state and federal change of ownership requirements and processes, antitrust considerations, tax-exempt organization considerations, fair market value requirements, and third-party payer reimbursement issues.
• Represented one of the largest regional health systems in the development of a clinically integrated network of healthcare providers.
• Represented a large healthcare investment company in reorganizing and simplifying its capitalization and organizational structure through a series of mergers and other related transactions including, among other things, an $8 million private securities offering and $45 million credit facility.
• Represented a rural hospital management company on issues related to privacy and security, billing and reimbursement, staffing and physician compensation, open meetings and records laws, COVID-19 matters, and other transactional and regulatory compliance matters.
• Defended an urgent care facility in connection with an involuntary retroactive revocation of Medicare billing privileges related to alleged violations of OIG exclusion authorities.
• Represented healthcare providers in structuring and effectuating sales to private equity groups, including dental practices, dermatology clinics, optometry clinics, and others.
• Represented the shareholders of an Oklahoma health maintenance organization (HMO) in the strategic acquisition of an HMO from a multibillion-dollar public company in Houston, Texas.
• Represented the management and employees of a 77-store grocery chain in acquiring the company via an employee stock ownership plan (ESOP) from the second-largest retailer-owned grocery wholesaler in the United States.
• Representation of durable medical equipment company in appeal of Medicare contractor’s flawed use of statistical sampling and extrapolation to determine overpayment.
• Represented one of the nation’s largest not-for-profit blood center in the acquisition of independent community blood centers and related regulatory approvals, including U.S. Food and Drug Administration (FDA), Centers for Medicare and Medicaid Services (CMS), and state agencies.
• Represented Fortune 500 hospital management company in procuring a Certificate of Need and state licensure for a 56-bed psychiatric hospital.
• Represented pharmacy investor in the acquisition of independent community pharmacies in Oklahoma and Texas and related regulatory approvals, including the Drug Enforcement Agency (DEA), Centers for Medicare and Medicaid Services (CMS), and applicable state-controlled substances and Medicaid agencies.
• Represented the shareholders of an Oklahoma HMO in the sale of the company’s equity interest to a private equity group for consideration of approximately $47 million.