Hannah L. Cross
Partner
Suite 900
Washington, D.C., 20001
Hannah is a partner in the Healthcare Regulatory, Compliance, and Operations Practice and focuses her practice on fraud and abuse, compliance, and internal investigations. Having deep knowledge of the Stark Law, the Anti-Kickback Statute, and the Civil Monetary Penalties Law, Hannah regularly provides advice and counsel to healthcare providers on...
Hannah is a partner in the Healthcare Regulatory, Compliance, and Operations Practice and focuses her practice on fraud and abuse, compliance, and internal investigations. Having deep knowledge of the Stark Law, the Anti-Kickback Statute, and the Civil Monetary Penalties Law, Hannah regularly provides advice and counsel to healthcare providers on compliance with these laws. She is also well-versed in Medicare enrollment and billing rules, regulations, and guidance documents and provides practical counseling to providers on these topics. She leads internal investigations as part of compliance programs as well as guides clients through investigations pursuant to government enforcement actions.
In her transactional practice, she oversees the regulatory due diligence process for complex healthcare acquisitions and investments, including nursing home, physician practice group, and hospital transactions. She works closely with clients to identify, assess, and manage compliance and reimbursement risks that may affect deal structure or valuation. Her diligence work often involves navigating federal and state licensure, reimbursement, and fraud and abuse considerations, and coordinating with transactional counsel, lenders, and consultants to develop practical risk mitigation strategies that align with business objectives.
Hannah also serves as outside general counsel to a broad range of healthcare providers and entities, including nonprofit professional medical societies. In this capacity, she provides strategic corporate, operational, and regulatory advice on governance, compliance program design, contracting, policy development, and interactions with payors and government agencies. Her experience includes guiding boards and leadership teams through complex compliance and ethical matters, advising on organizational structure and oversight, and supporting mission-driven organizations in maintaining transparency and accountability in their operations.
Hannah is certified in Healthcare Compliance (CHC) by the Society of Corporate Compliance and Ethics and the Health Care Compliance Association (SCCE/HCCA). This national accreditation reflects a professional level of competence and experience in compliance processes used in assisting healthcare business organizations to understand and address legal obligations and promote organizational governance and integrity through the operation of effective compliance programs.
Hannah is a frequent speaker and writer and contributes to national healthcare organizations, including speaking directly to boards, large audiences, and legal and compliance departments.
compliance with these laws. She is also well-versed in Medicare enrollment and billing rules, regulations, and guidance documents and provides practical counseling to providers on these topics. She leads internal investigations as part of compliance programs as well as guides clients through investigations pursuant to government enforcement actions.
In her transactional practice, she oversees the regulatory due diligence process for complex healthcare acquisitions and investments, including nursing home, physician practice group, and hospital transactions. She works closely with clients to identify, assess, and manage compliance and reimbursement risks that may affect deal structure or valuation. Her diligence work often involves navigating federal and state licensure, reimbursement, and fraud and abuse considerations, and coordinating with transactional counsel, lenders, and consultants to develop practical risk mitigation strategies that align with business objectives.
Hannah also serves as outside general counsel to a broad range of healthcare providers and entities, including nonprofit professional medical societies. In this capacity, she provides strategic corporate, operational, and regulatory advice on governance, compliance program design, contracting, policy development, and interactions with payors and government agencies. Her experience includes guiding boards and leadership teams through complex compliance and ethical matters, advising on organizational structure and oversight, and supporting mission-driven organizations in maintaining transparency and accountability in their operations.
Hannah is certified in Healthcare Compliance (CHC) by the Society of Corporate Compliance and Ethics and the Health Care Compliance Association (SCCE/HCCA). This national accreditation reflects a professional level of competence and experience in compliance processes used in assisting healthcare business organizations to understand and address legal obligations and promote organizational governance and integrity through the operation of effective compliance programs.
Hannah is a frequent speaker and writer and contributes to national healthcare organizations, including speaking directly to boards, large audiences, and legal and compliance departments.
Experience
Representative Matters
- Performed Stark Law compliance investigation for an acute care hospital.
- Conducted and managed due diligence on behalf of a REIT in its acquisition of the real property associated with 130 Texas skilled nursing facilities and the simultaneous transfer of operations of the same.
- Advised an international professional medical society Board of Directors on governance, regulatory, contract, and policy matters.
- Conducted and managed due diligence on behalf of a REIT in its acquisition of the real property associated with 61 Florida skilled nursing and assisted living facilities and the simultaneous transfer of operations of the same.
- Represented numerous providers in Provider Relief Fund Decision Reviews, resulting in favorable determinations and retention of payments.
- Negotiated settlement with the U.S. Department of Health and Human Services Office of Inspector General on behalf of a hospital through the Provider Self Disclosure Protocol.
- Led internal investigations for multiple hospital system clients and delivered memorandums to Board of Directors.
- Created and executed strategies for reviewing and maintaining compliance with the Stark Law for multiple health care systems.
- Provided detailed 50-state survey of nursing pool license requirements and employment agency requirements for national nurse staffing agency.
- Advised tax-exempt hospitals on financial assistance policies and procedures in compliance with 501(r) requirements.
- Developed and administered integrated clinical trial document review, tracking, negotiation, and management solution for a biopharmaceutical company.
- Drafted policies and procedures relating to clinical trial negotiations for major biopharmaceutical company.
- Represented hospital in petition to the Centers for Medicare and Medicaid Services, resulting in receipt of favorable Critical Access Hospital co-location advise to allow a new behavioral health facility to be established.
- Provided specialized Medicare and Medicaid reimbursement advice to litigation teams in defense of multiple False Claims Act Qui Tam actions.
- Advised national telehealth provider on Medicare enrollment regulations and rules relating to telehealth services.
- Provided health care regulatory due diligence advice in multiple transactions.
- Advised hospital systems and physician groups on state licensing requirements.
- Counseled health care organizations on compliance program effectiveness and provided suggested processes relating to the same.
Previous Professional Experience
- Associate, Florida law firm (2013–2015)
- Law clerk, Office of Hearings, Centers for Medicare and Medicaid Services (Fall 2012)
- Summer graduate associate, Medicaid Fraud Unit, New York City Human Resources Administration (Summer 2012)
- Law clerk, Office of General Counsel, Sinai Hospital of Baltimore (2011–2012)
- Legal intern, Central Office of Legal Affairs, New York City Health and Hospitals Corp. (Summer 2011)
Educational Activities
- University of Maryland School of Law
- Student Attorney, Maryland Law Clinic: HIV/AIDS Health Delivery & Child Welfare Legal Issues
Education
-
University of Maryland Francis King Carey School of Law,
JD
(2013)
- Health Law Certificate
- Manuscripts Editor, Journal of Health Care Law and Policy
-
University of Wisconsin–Madison,
BA,
Political Science and Classical Humanities
(2010)
- Certificate in European Studies
Admissions
- District of Columbia
- Florida
- U.S. District Court for the District of Columbia
- Supreme Court of the United States
Representative Matters
- Performed Stark Law compliance investigation for an acute care hospital.
- Conducted and managed due diligence on behalf of a REIT in its acquisition of the real property associated with 130 Texas skilled nursing facilities and the simultaneous transfer of operations of the same.
- Advised an international professional medical society Board of Directors on governance, regulatory, contract, and policy matters.
- Conducted and managed due diligence on behalf of a REIT in its acquisition of the real property associated with 61 Florida skilled nursing and assisted living facilities and the simultaneous transfer of operations of the same.
- Represented numerous providers in Provider Relief Fund Decision Reviews, resulting in favorable determinations and retention of payments.
- Negotiated settlement with the U.S. Department of Health and Human Services Office of Inspector General on behalf of a hospital through the Provider Self Disclosure Protocol.
- Led internal investigations for multiple hospital system clients and delivered memorandums to Board of Directors.
- Created and executed strategies for reviewing and maintaining compliance with the Stark Law for multiple health care systems.
- Provided detailed 50-state survey of nursing pool license requirements and employment agency requirements for national nurse staffing agency.
- Advised tax-exempt hospitals on financial assistance policies and procedures in compliance with 501(r) requirements.
- Developed and administered integrated clinical trial document review, tracking, negotiation, and management solution for a biopharmaceutical company.
- Drafted policies and procedures relating to clinical trial negotiations for major biopharmaceutical company.
- Represented hospital in petition to the Centers for Medicare and Medicaid Services, resulting in receipt of favorable Critical Access Hospital co-location advise to allow a new behavioral health facility to be established.
- Provided specialized Medicare and Medicaid reimbursement advice to litigation teams in defense of multiple False Claims Act Qui Tam actions.
- Advised national telehealth provider on Medicare enrollment regulations and rules relating to telehealth services.
- Provided health care regulatory due diligence advice in multiple transactions.
- Advised hospital systems and physician groups on state licensing requirements.
- Counseled health care organizations on compliance program effectiveness and provided suggested processes relating to the same.
Previous Professional Experience
- Associate, Florida law firm (2013–2015)
- Law clerk, Office of Hearings, Centers for Medicare and Medicaid Services (Fall 2012)
- Summer graduate associate, Medicaid Fraud Unit, New York City Human Resources Administration (Summer 2012)
- Law clerk, Office of General Counsel, Sinai Hospital of Baltimore (2011–2012)
- Legal intern, Central Office of Legal Affairs, New York City Health and Hospitals Corp. (Summer 2011)
Educational Activities
- University of Maryland School of Law
- Student Attorney, Maryland Law Clinic: HIV/AIDS Health Delivery & Child Welfare Legal Issues
Media
Recognitions
- The Best Lawyers in America® Ones to Watch, Health Care Law (2021–2026)
Hannah is a partner in the Healthcare Regulatory, Compliance, and Operations Practice and focuses her practice on fraud and abuse, compliance, and internal investigations. Having deep knowledge of the Stark Law, the Anti-Kickback Statute, and the Civil Monetary Penalties Law, Hannah regularly provides advice and counsel to healthcare providers on... compliance with these laws. She is also well-versed in Medicare enrollment and billing rules, regulations, and guidance documents and provides practical counseling to providers on these topics. She leads internal investigations as part of compliance programs as well as guides clients through investigations pursuant to government enforcement actions.
In her transactional practice, she oversees the regulatory due diligence process for complex healthcare acquisitions and investments, including nursing home, physician practice group, and hospital transactions. She works closely with clients to identify, assess, and manage compliance and reimbursement risks that may affect deal structure or valuation. Her diligence work often involves navigating federal and state licensure, reimbursement, and fraud and abuse considerations, and coordinating with transactional counsel, lenders, and consultants to develop practical risk mitigation strategies that align with business objectives.
Hannah also serves as outside general counsel to a broad range of healthcare providers and entities, including nonprofit professional medical societies. In this capacity, she provides strategic corporate, operational, and regulatory advice on governance, compliance program design, contracting, policy development, and interactions with payors and government agencies. Her experience includes guiding boards and leadership teams through complex compliance and ethical matters, advising on organizational structure and oversight, and supporting mission-driven organizations in maintaining transparency and accountability in their operations.
Hannah is certified in Healthcare Compliance (CHC) by the Society of Corporate Compliance and Ethics and the Health Care Compliance Association (SCCE/HCCA). This national accreditation reflects a professional level of competence and experience in compliance processes used in assisting healthcare business organizations to understand and address legal obligations and promote organizational governance and integrity through the operation of effective compliance programs.
Hannah is a frequent speaker and writer and contributes to national healthcare organizations, including speaking directly to boards, large audiences, and legal and compliance departments.
Experience
The following is a selected sampling of matters and is provided for informational purposes only. Past success does not indicate the likelihood of success in any future matter.Representative Matters
- Performed Stark Law compliance investigation for an acute care hospital.
- Conducted and managed due diligence on behalf of a REIT in its acquisition of the real property associated with 130 Texas skilled nursing facilities and the simultaneous transfer of operations of the same.
- Advised an international professional medical society Board of Directors on governance, regulatory, contract, and policy matters.
- Conducted and managed due diligence on behalf of a REIT in its acquisition of the real property associated with 61 Florida skilled nursing and assisted living facilities and the simultaneous transfer of operations of the same.
- Represented numerous providers in Provider Relief Fund Decision Reviews, resulting in favorable determinations and retention of payments.
- Negotiated settlement with the U.S. Department of Health and Human Services Office of Inspector General on behalf of a hospital through the Provider Self Disclosure Protocol.
- Led internal investigations for multiple hospital system clients and delivered memorandums to Board of Directors.
- Created and executed strategies for reviewing and maintaining compliance with the Stark Law for multiple health care systems.
- Provided detailed 50-state survey of nursing pool license requirements and employment agency requirements for national nurse staffing agency.
- Advised tax-exempt hospitals on financial assistance policies and procedures in compliance with 501(r) requirements.
- Developed and administered integrated clinical trial document review, tracking, negotiation, and management solution for a biopharmaceutical company.
- Drafted policies and procedures relating to clinical trial negotiations for major biopharmaceutical company.
- Represented hospital in petition to the Centers for Medicare and Medicaid Services, resulting in receipt of favorable Critical Access Hospital co-location advise to allow a new behavioral health facility to be established.
- Provided specialized Medicare and Medicaid reimbursement advice to litigation teams in defense of multiple False Claims Act Qui Tam actions.
- Advised national telehealth provider on Medicare enrollment regulations and rules relating to telehealth services.
- Provided health care regulatory due diligence advice in multiple transactions.
- Advised hospital systems and physician groups on state licensing requirements.
- Counseled health care organizations on compliance program effectiveness and provided suggested processes relating to the same.
Previous Professional Experience
- Associate, Florida law firm (2013–2015)
- Law clerk, Office of Hearings, Centers for Medicare and Medicaid Services (Fall 2012)
- Summer graduate associate, Medicaid Fraud Unit, New York City Human Resources Administration (Summer 2012)
- Law clerk, Office of General Counsel, Sinai Hospital of Baltimore (2011–2012)
- Legal intern, Central Office of Legal Affairs, New York City Health and Hospitals Corp. (Summer 2011)
Educational Activities
- University of Maryland School of Law
- Student Attorney, Maryland Law Clinic: HIV/AIDS Health Delivery & Child Welfare Legal Issues
Education
-
University of Maryland Francis King Carey School of Law,
JD
(2013)
- Health Law Certificate
- Manuscripts Editor, Journal of Health Care Law and Policy
-
University of Wisconsin–Madison,
BA,
Political Science and Classical Humanities
(2010)
- Certificate in European Studies
Admissions
- District of Columbia
- Florida
- U.S. District Court for the District of Columbia
- Supreme Court of the United States
Practice Areas
- The Best Lawyers in America® Ones to Watch, Health Care Law (2021–2026)
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