Thomas Herrmann advises health care clients on compliance and regulatory matters, with a focus on development and management of effective health care compliance programs. Mr. Herrmann works with a variety of health care organizations, including hospital, managed care, physician practice and long-term care. Mr. Herrmann is a recognized expert on issues related to the federal Anti-Kickback Statute, Stark Law and the False Claims Act. Accordingly, he is frequently engaged by clients to evaluate physician arrangements and other arrangements that may have a legal implication, assess high risk areas as it relates to legal and regulatory requirements and conduct due-diligence reviews for mergers or acquisitions. He undertakes independent verification reviews for potential self-disclosure to government agencies and counsels clients on risk assessment and remediation strategies. Mr. Herrmann also works with health care clients who are preparing to or who have already entered into a Corporate Integrity Agreement (CIA), by assisting these organizations with implementing policies and processes to comply with the CIA, engaging as an Independent Review Organization, or advising the Board as a Compliance Expert.
Previous Work Experience
Mr. Herrmann has over 30 years of legal experience with the U.S. Department of Health and Human Services. Prior to joining Strategic Management, Mr. Herrmann served a six-year term as an Administrative Appeals Judge on the HHS Medicare Appeals Council. 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. Additionally, Mr. Herrmann held various high-level positions in HHS OIG, including Director of the OIG’s Office of External Affairs, chaired the Task Force on Managed Care, served on the Federal Interagency Suspension and Debarment Coordinating Committee and served as Chief of the Administrative Litigation Branch in the OIG Counsel’s Office.