Our Team

Thomas E. Herrmann, JD

Professional Experience

As a Senior Vice President, Tom Herrmann handles compliance issues and advisory services for the full range of health care entities and professionals.  This includes the development, implementation, assessment, enhancement, and management of compliance programs.  His clients have ranged from large hospital systems, skilled nursing facilities, physician owned clinics, hospitals and practices, DME supply companies, to managed care organizations.  He is one of the most recognized experts in the country on issues related to the Anti-Kickback Statute and Stark Laws.  Thus, he is frequently called upon to assist clients with physician arrangements that may implicate those laws.  Mr. Herrmann has assisted a number of clients in meeting the compliance requirements of Corporate Integrity Agreements (CIAs), as well as acting as an Independent Review Organization (IRO) for providers and practitioners that have entered into a Corporate Integrity Agreement (CIA) with the U.S. Department of Health and Human Services (DHHS) Office of Inspector General (OIG) and New York Office of Medicaid Inspector General (OMIG).  He frequently is engaged to provide general advisory services to compliance programs and in addressing compliance high risk areas.  He also conducts regulatory “due diligence” compliance reviews for health care entities contemplating new business relationships.  He performs independent verification reviews related to self disclosures to Governmental authorities, and is involved in counseling clients on risk assessment and remediation strategies.  In addition, as a former Administrative Appeals Judge on the DHHS Medicare Appeals Council, he advises and assists clients with Medicare claims appeals, as well as on OIG administrative sanctions issues.  Mr. Herrmann participates and presents frequently at health care compliance and legal forums on “cutting” edge” issues in the health care enforcement and regulatory arena.  He has also authored articles for professional journals on various issues, such as the responsibilities of IROs and the OIG’s implementation of the “Responsible Corporate Officer” doctrine.

Previous Work

Mr. Herrmann has over 30 years of legal experience with the U.S. Department of Health and Human Services (HHS).  Most recently, he served for six years as an Appellate Judge on the Medicare Appeals Council, the final level of HHS administrative review.  In that capacity, he adjudicated health care provider, supplier, and beneficiary cases involving eligibility, coverage, and payment for health care services furnished to Medicare beneficiaries.

For the prior 20 years, Mr. Herrmann held various positions in the HHS Office of Inspector General (OIG).  He acted as the OIG Director of the Office of External Affairs where he supervised OIG policy professionals; developed and responded to legislative proposals relating to fraud, waste, and abuse in DHHS programs; drafted legislation and testimony for the OIG; and developed regulations and policy guidance implementing OIG administrative sanctions authorities.  He chaired a DHHS Task Force on Managed Care Issues to facilitate communications and activities between the Centers for Medicare & Medicaid Services (CMS) and OIG related to the Medicare+Choice Program subsequent to its enactment.  His responsibilities also included reviewing requests filed by excluded health care providers for reinstatement to Federal health care programs, and serving on the Federal Interagency Suspension and Debarment Coordinating Committee.

Mr. Herrmann served as Chief of the OIG Administrative Litigation Branch, and supervised the litigation of cases involving the OIG’s imposition of civil monetary penalties and program exclusions.  He managed the litigation of administrative sanction cases, as well as coordinated the handling of cases with the U.S. Department of Justice (DOJ) and DHHS Regional Offices.  Mr. Herrmann was engaged in the development and implementation of the OIG’s civil money penalty and exclusion authorities, including the promulgation of regulations, issuance of program guidance, and negotiation and litigation of cases.  He assisted in settlement negotiations, developed settlement agreements, and coordinated audits/investigations with DOJ and CMS.  He coordinated with the U.S. Department Justice and the Centers for Medicare & Medicaid Services (CMS) the investigation, litigation, negotiation, and settlement of health care fraud and abuse cases.  These responsibilities included development of Corporate Integrity Agreements (CIAs), as well as approval of Independent Review Organizations (IROs).  In addition, he served on the Federal Interagency Suspension and Debarment Coordinating Committee.

Education/Affiliations/Recognition

• Bachelor of Arts, Political Science, State University of New York at Stony Brook
• Juris Doctor, George Washington University National Law Center
• Member, District of Columbia and Virginia Bars
• Member, American Health Lawyers Association
• Board Member, Ronald McDonald House Charities of Greater Washington DC

Our Team

• Al Bassett
• Camella Boateng
• Jillian Bower
• Steve Brannan
• Chris Coleman
• Cornelia Dorfschmid
• Steve Forman
• Catie Heindel
• Tom Herrmann
• Rita Isnar
• Sharita Jennings
• Richard Kusserow
• Bill Moran
• Arpana Narain