PRIVATE PRACTICE, San Juan, Puerto Rico
2002 to the present
- Providing government relations, public policy analysis and development, strategic direction and support, environmental analysis, regulatory and taxation compliance, managed care, contracting, Medicare/Medicaid reimbursement, market access and supply chain logistics advisory services to a global publicly traded renal replacement therapy provider, a number of global biopharmaceutical companies, a international trade association, and a US-based health insurance company.
- Providing consultation services to financial analysts at investment management firms regarding the Commonwealth government’s fiscal situation and health insurance markets.
- Representing a medical data exchange provider on U.S. and Commonwealth Disproportionate Share, SSI and 340b reimbursement issues (Puerto Rico, USVI and US).
- Provided advice to a hospital in contract negotiations, receivables management, Medicare/Medicaid, managed care and general corporate matters.
- Provided government affairs and strategic advice and counsel to an Austria-based global food and beverage company.
- Represented a France-based alternative energy equipment manufacturer in a litigation matter.
- Served as expert witness in four litigation matters involving complex Medicare regulatory issues (fraud and abuse, renal dialysis centers, hospital billing procedures and home health services).
- Counseled the Office of the Dean of the School of Medicine of the University of Puerto Rico regarding Medicare and Medicaid reimbursement issues and clinical research grants.
- Provided general advice and counsel on corporate, HIPAA, government audit and accounting issues to an MBHO and negotiated a $70M/year contract with the Medicaid Agency in Puerto Rico.
- Represented a small group physician practice and an IDTF in administrative actions before the HHS OIG and implementing a compliance program.
- Provided legislative consulting services to a US-based campaign finance, ethics and lobbying editorial service.
KPMG LLP, Hartford, CT and New York, NY
Director, Forensic and Litigation Services (Health Care Practice Group), 2000-2001
Responsible for directing revenue-generating activities utilizing a combination of direct sales through industry contacts, proposal design and development and attendance at health care industry meetings. Completed consulting assignments, including:
- Compliance and training program design and implementation for a medical college.
- Compliance program assessment for a 200-bed community hospital.
- Compliance program development for a Durable Medical Equipment provider.
- Anti-money laundering due diligence for a bank acquisition in México.
- Claims fraud detection analysis for a Property and Casualty insurer in Puerto Rico.
UNITEDHEALTH GROUP, Hartford, CT
Director, Business Practices (Compliance), Government Operations Division, 1997-2000
Directed the Division’s Business Practices (Compliance) Program, which consisted of 1,400 employees, $120M/yr revenue, 9 locations, and 5 government contracts.
- Led a cultural transformation and trained employees on linking values to business decisions and outcomes. Established strategic direction for the Division as a member of the senior leadership team.
- Managed relations with HCFA (now CMS), including negotiation of a $2M reimbursement for previously unidentified, but reimbursable, costs and divestiture settlement issues (for example, advance agreement on termination costs).
- Enhanced the Division’s Code of Conduct, hotline management protocols and annual employee training.
- Responsible for the Division’s internal audit function and external audit responses.
- Conducted internal investigations regarding business practices issues.
- Managed outside counsel (government contracts and general corporate).
- Testified before the Cost Accounting Standards Board Review Panel on the application of the Cost Accounting Standards to Medicare Contractors (June 18, 1998).
BLUE CROSS/BLUE SHIELD OF THE NATIONAL CAPITAL AREA, Washington, DC
Associate General Counsel, 1995-1997
Advised senior management on a broad range of corporate law issues with emphasis on government contracts (FEHBP and Medicare), compliance audits and regulatory compliance matters, accounting and procurement regulations (CAS and FAR), general business transactions and insurance/managed care law. Provided legal and business advice for the development of an HMO product for federal employees. Designed and implemented a corporate-wide Code of Conduct and compliance training program. Handled service mark and trademark regulatory matters. Managed relations with outside counsel.
BLUE CROSS/BLUE SHIELD OF TEXAS, Dallas, TX
Attorney I, 1994-1995; Associate Attorney, 1993-1994
Responsible for a variety of corporate law matters including government contracts, joint ventures, antitrust and compliance audits. Provided legal counsel to an international joint venture team by assisting in the negotiation of a transaction between two domestic insurers and a Mexican insurance company. Served as counsel to a CHAMPUS bid preparation team. Implemented a corporate-wide Code of Conduct training program. Handled service mark and trademark regulatory matters. Managed relations with outside counsel.
BICKEL & BREWER, Dallas, TX
Associate Attorney, 1990-1992
Analyzed legal issues, drafted memoranda and briefs, and conducted discovery and motion practice for commercial litigation, securities and real estate law matters.
J.D., Boston University, Boston, MA, 1990
A.B., cum laude, Harvard University, Cambridge, MA, 1987 (Accelerated Graduation)
Certificate in Latin American Studies
Other Education: Wharton Executive Education, Managing People, 1999
State Bar of Texas; U.S. Court of Appeals, 1st Circuit; U.S. District Court, Northern District of Texas; U.S. District Court for the District of Puerto Rico; U.S. Court of Appeals for the Armed Forces; U.S. Army Court of Criminal Appeals
College of the State Bar of Texas
Private Sector Coalition of Puerto Rico
Renal Council of Puerto Rico
Program Co-Chair, Health Care Compliance Association Conference, Puerto Rico
Planning Committee, Annual Meeting, Inter-American Bar Association, Puerto Rico
Major, U.S. Army Reserve, Judge Advocate General’s Corps