In 2021, Congress enacted the Corporate Transparency Act (the “CTA”) to “better enable critical national security, intelligence, and law enforcement efforts to counter money laundering, the financing of terrorism, and other illicit activity.”[1] The CTA, which became effective January 1, 2024,[2] is described, in detail, in a series of Proskauer alerts compiled by Proskauer’s CTA Task Force. The CTA will create a national registry of the “beneficial owners” and “company applicants”[3] of millions[4] of entities across the country. A reporting company must disclose certain information about its beneficial owners and (for entities formed in 2024 and later) company applicants, including: (i) legal name; (ii) date of birth; (iii) residential address (or business address for certain company applicants); (iv) unique identifying number from a non-expired government-issued identification document; and (v) an image of such identification document.[5] In addition, states are following the Federal government’s lead and have adopted similar regulatory regimes; last month, for example, New York enacted the LLC Transparency Act, which comes into effect in December 2024.

The CTA poses a unique compliance burden for large enterprises in the health care delivery sector. These entities ordinarily enter into a number of complex contractual arrangements with physician practices and facilities where ultimate “control” of the entity is bifurcated at best (e.g., clinical vs. non-clinical control) or otherwise ambiguous at worst. Health systems, practice management companies (MSOs/DSOs), and national telehealth companies may each be party to dozens of complex joint ventures and management agreements (“MSAs”) with nominee-owned physician practices (“Friendly PCs”) in states that adhere to the corporate practice of medicine doctrine (“CPOM”).

A Roadmap For Friendly PC Reporting Requirements

Pertinent questions for entities who have entered into MSAs with Friendly PCs include:

  • If you have relied upon an exemption to reporting under the CTA, such as the “large operating company” or “tax exempt entity” exemption, can your Friendly PCs also rely upon such exemption as your “subsidiaries”?
  • If not, can your Friendly PCs rely upon an exemption, individually, like the “large operating company” exemption?
  • If your Friendly PCs are ultimately required to report, who are the beneficial owners of your Friendly PC?

The questions above are fact-sensitive and depend on the MSAs and related agreements that were entered into with each Friendly PC.

Reporting Exemptions for Health Care Industry Stakeholders

The reporting rule lists 23 types of entities that are not required to file beneficial ownership information reports. Below, we discuss a number of important exemptions for health care entities:

  • Non-Profit Exemption. If a healthcare entity meets the description of Internal Revenue Code (IRC) § 501(c) and is exempt from tax by IRC § 501(a), the entity is exempt from the reporting requirements of the CTA.[6] Tax-exempt hospital systems or service providers that meet the foregoing requirements would be exempt from CTA reporting requirements.
  • Large Operating Company Exemption. As described in greater detail in this Proskauer post, any entity that (i) employs more than 20 full-time employees in the U.S. as determined under U.S. federal tax rules, (ii) in the previous year, filed U.S. federal income tax returns demonstrating more than $5,000,000 in gross receipts or sales (net of returns and allowances) in the aggregate (consolidated, if applicable), excluding gross receipts or sales from sources outside the U.S., and (iii) has an operating presence at a physical office within the U.S., and is exempt from the reporting rule as a large operating company.[7] Only full-time, W-2 employees of the entity itself qualify, and “FinCEN expects that companies will regularly evaluate whether they qualify (or no longer qualify) for the exemption.”[8] However, for an entity in an affiliated group (as defined by 26 U.S.C. § 1504(a)), the amount filed on a tax or information return shall be that of the consolidated return for the group. In addition to for-profit health systems and MSO/DSOs that meet the foregoing requirements, Friendly PCs with substantial operations may individually meet the requirements of a “large operating company,” and would, therefore, be exempt from the reporting rule. 
  • Subsidiary of Exempt Entity Exemption. Any entity whose “ownership interests are controlled or wholly owned, directly or indirectly,” by one or more eligible exempt entities is itself exempt from the reporting rule.[9] Whether a Friendly PC qualifies as an exempt “subsidiary” will depend upon whether the MSO/DSO with whom the Friendly PC contracts is deemed to directly or indirectly entirely control the ownership interests of the Friendly PC. Neither the CTA, nor the Reporting Rule, nor FinCEN’s commentary in the Federal Register provide a clear definition of “control” for purposes of the exempt entity exemption.[10] However, as noted in this Proskauer post, FinCEN recently updated its guidance to clarify that, in order to qualify for the subsidiary exemption, the subsidiary entity’s ownership interests must be entirely (fully, 100%) owned or controlled by one or more eligible exempt entities. As such, the analysis regarding the meaning of control is fact-sensitive, but the question of whether partial control over some but not all ownership interests could satisfy the test has been clearly answered by FinCEN (and the answer is no; only entire control will satisfy the test). For example, an MSO may potentially be deemed to entirely control the ownership interests of the Friendly PC if the MSO and the Friendly PC have entered into a succession planning agreement that may vest the MSO with the discretionary authority to name successor equity holders. The analysis is fact-sensitive, varies depending upon the agreements in place, and limited guidance has been issued by FinCEN to date on the matter.
  • Inactive Entity Exemption.  There is also an exemption available for “inactive entities” that: (i) existed on or before January 1, 2020; (ii) are not engaged in active business; (iii) are not owned by a foreign individual; (iv) have not been involved in a change of ownership within the last year; (v) have not sent or received money in an amount greater than $1,000 in the last year; and (vi) do not otherwise have any assets in the U.S. or abroad.[11] Entities in the health care sector that engage in no business activities, but have not otherwise had their legal existence canceled or terminated under applicable state law, may fall within this exception.

Who are the “Beneficial Owners of a Friendly PC”?

A beneficial owner includes any individual who directly or indirectly: (i) exercises substantial control over a company, or (ii) owns or controls at least 25% of the ownership interests of a company. An individual is deemed to have “substantial control” over a reporting company if the individual, in part:

  • serves as a “senior officer” of the reporting company;
  • has authority over the appointment or removal of any senior officer or a majority of the board of directors (or similar body);
  • directs, determines, or has substantial influence over certain important decisions made by the reporting company; or
  • has any other form of substantial control over the reporting company.[12]

An individual may “directly or indirectly” exercise substantial control through any contract or relationship, including: (i) “rights associated with any financing arrangement”; (ii) “control over one or more intermediary entities that separately or collectively exercise substantial control over a reporting company”; or (iii) “arrangements or financial or business relationships, whether formal or informal, with other individuals or entities acting as nominees.”[13]

In a customary Friendly PC relationship, individuals who trigger the reporting obligations would generally include (i) clinicians with a 25% or greater equity stake in the Friendly PC, (ii) senior officers of the Friendly PC, and (iii) potentially, MSO employees with substantial influence over decisions made by the Friendly PC, depending upon the terms of the MSA between the Friendly PC and MSO.

Can health care regulators access beneficial ownership information reported to FinCEN?

Federal law enforcement agencies (and state law enforcement agencies with court authorization) may request access to information reported under the CTA. FinCEN may share reported information with federal agencies “involved in law enforcement activity, for use in furtherance of such activity.”[14] Law enforcement activity “includes both criminal and civil investigations and actions, such as actions to impose civil penalties, civil forfeiture actions, and civil enforcement through administrative proceedings.”[15]

Similarly, FinCEN may share reported information with “a State, local, or Tribal law enforcement agency” that is authorized by law to engage in the investigation or enforcement of civil or criminal violations of law, but only if a court of competent jurisdiction has authorized the agency to seek such information.[16]

As such, agencies pursuing regulatory enforcement actions under a wide variety of civil and criminal health care laws may access and leverage reported information, even where such agencies may not otherwise have had independent statutory authorization or regulatory authority to collect, through other means (e.g., provider enrollment applications, regulatory filings, etc.), the broad types of beneficial ownership information reportable under the CTA.

What are the penalties for non-compliance?

Penalties for violating the reporting rule can be substantial. Non-compliance with the reporting rule can result in civil penalties of up to $500 per day, and criminal penalties can also be imposed, including fines of up to $10,000 or imprisonment for up to two years.[17]

Proskauer’s CTA Task Force and health care group will continue to monitor for developments related to the CTA and any applicable FinCEN guidance. The CTA must be analyzed on a case-by-case basis, and health care industry stakeholders should seek guidance from counsel to ensure compliance with the reporting obligations.


[1] See CTA § 6402(5)(D) (setting forth the “sense of Congress” for enacting the legislation, and codified as a statutory note to 31 USC § 5336). The CTA was enacted as part of Division F, Title LXIV, of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021, Public Law 116–283 (Jan. 1, 2021) (the “NDAA”). Division F of the NDAA contains the Anti-Money Laundering Act of 2020, which includes the CTA.

[2] Entities that trigger the reporting obligation have a limited amount of time to file their initial BOI. For example, entities formed before the effective date have until January 1, 2025 to file. 31 CFR § 1010.380(a). Entities formed in 2024 have 90 days to file.

[3] Beneficial owners and company applicants include, for example those individuals who own, control, or form an entity, as described herein. Company applicants include (i) the individual who directly files the document that forms the company, and (ii) the individual who is primarily responsible for directing or controlling the filing of the relevant document. See 31 CFR § 1010.380.

[4] FinCEN, the regulator tasked with the CTA’s implementation, estimates “that there will be approximately 32 million reporting companies in Year 1 of the reporting requirement and approximately 5 million new reporting companies each year thereafter.” See 87 Fed. Reg. 77,408 (Dec. 16, 2022) (available at: https://www.federalregister.gov/d/2022-27031). Some believe FinCEN’s figures significantly underestimate the number of reporting companies.  

[5] See 31 CFR § 1010.380(b)(ii).

[6] 31 CFR § 1010.380(c)(2)(xix).

[7] 31 CFR § 1010.380(c)(2)(xxi).

[8] 87 Fed. Reg. 59,543 (Sept. 30, 2022).

[9] 31 CFR § 1010.380(c)(2)(xxii).

[10] See, e.g., 31 USC § 5336;31 CFR § 1010.380; 87 Fed. Reg. 59,498 (Sept. 30, 2022).

[11] 31 CFR § 1010.380(c)(2)(xxiii).

[12] See 31 CFR § 1010.380(d)(1)(i).

[13] See 31 CFR § 1010.380(d)(1)(ii).

[14] See 31 USC § 5336(c)(2)(B)(i)(I); 31 CFR § 1010.955(b)(1) (eff. Feb. 20, 2024); 88 Fed. Reg. 88,732 (Dec. 22, 2023).

[15] See also Fact Sheet: FinCEN, Beneficial Ownership Information Access and Safeguards Final Rule (Dec. 21, 2023), available here. See also 31 CFR § 1010.955(b)(1)(iii) (eff. Feb. 20, 2024).

[16] See 31 USC § 5336(c)(2)(B)(i)(II); 31 CFR § 1010.955(b)(2) (eff. Feb. 20, 2024); 88 Fed. Reg. 88,732 (Dec. 22, 2023).

[17] See 31 USC § 5336(h)(3)(A) (setting forth that “any person that violates… [the reporting obligations] (i) shall be liable to the United States for a civil penalty of not more than $500 for each day that the violation continues or has not been remedied; and (ii) may be fined not more than $10,000, imprisoned for not more than 2 years, or both”).

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Photo of David Manko David Manko

David is Chair of the Firm’s Health Care Group, with a national practice representing clients in the health care services sector in complex business transactions (private equity, M&A and joint ventures) and regulatory matters. After more than 25 years, David has developed deep…

David is Chair of the Firm’s Health Care Group, with a national practice representing clients in the health care services sector in complex business transactions (private equity, M&A and joint ventures) and regulatory matters. After more than 25 years, David has developed deep healthcare industry expertise which he leverages to provide practical, creative and actionable advice to clients. Recently, David has been involved with representing stakeholders as they navigate a shifting healthcare landscape arising from COVID-19 including CARES Act compliance matters and implementing new healthcare delivery models.

Chambers USA recognizes David as a regulatory and transactional healthcare lawyer who earns impressive reviews from peers and clients alike.” “He is a master negotiator and is second to none in his responsiveness,” says one commentator, who adds that “he turns around whatever needs to be done promptly and efficiently.”

As one of the architects of the NYS ACO statute and regulations and a former member of the NYS Value Based Payment Workgroup, David has deep expertise in regulatory and transactional  issues involving large provider networks and risk bearing entities. David has also worked with clients to develop demonstration projects with the Center for Medicare and Medicaid Innovation.

In the community, David is dedicated to expanding access to primary care services for underserved populations. For almost 10 years, he has been an active member of the Board of Directors of Primary Care Development Corporation (“PCDC”). PCDC is a nonprofit Community Development Financial Institution dedicated to providing low-cost debt financing to not-for-profit organizations to expand and improve primary care in underserved communities.

Photo of Andrew Bettwy Andrew Bettwy

Andrew Bettwy is a partner in the Corporate Department and co-head of the Finance Group. His principal focus is the representation of financial institutions, private equity sponsors, and public and privately held companies in leveraged finance and other financing transactions. Andrew represents both…

Andrew Bettwy is a partner in the Corporate Department and co-head of the Finance Group. His principal focus is the representation of financial institutions, private equity sponsors, and public and privately held companies in leveraged finance and other financing transactions. Andrew represents both lenders and borrowers in a wide range of transactions involving multiple industries and diverse debt capital structures, including acquisition financings, recapitalizations, multiple lien and subordinated debt financings, debtor-in-possession and exit financings, and private placements.

Andrew has represented several leading financial institutions while at Proskauer, including Bank of America, Citibank, CoBank, Credit Suisse, Imperial Capital, Jefferies Finance and Lazard Capital Markets.

Andrew is co-chair of Proskauer’s CARES Act Team and a part of the Firm’s cross-disciplinary, cross-jurisdictional Coronavirus Taskforce helping to shape the guidance and next steps for clients impacted by the pandemic.

Photo of Jeffrey A. Horwitz Jeffrey A. Horwitz

Jeffrey A. Horwitz is a partner in Proskauer’s Corporate Department where he co-heads our Private Equity Real Estate practice and runs our internationally recognized Hospitality, Gaming & Leisure Group. He also has served as co-head of Mergers & Acquisitions and as a member

Jeffrey A. Horwitz is a partner in Proskauer’s Corporate Department where he co-heads our Private Equity Real Estate practice and runs our internationally recognized Hospitality, Gaming & Leisure Group. He also has served as co-head of Mergers & Acquisitions and as a member of our Executive Committee. Jeff is a general corporate and securities lawyer with broad-based experience in mergers and acquisitions, cross-border transactions, and long-term joint ventures. He is regularly engaged to advise boards, management teams and investors on strategic matters, from litigation to personnel to transactions. Jeff is also the head of the Firm’s cross-disciplinary, cross-jurisdictional Coronavirus Taskforce helping to shape the guidance and next steps for clients impacted by the pandemic.

Jeff counsels clients on the full range of their activities, from seed capital to public offerings, acquisitions and operational matters, often acting as outside general counsel. He represents major financial institutions, sovereign wealth funds, private equity and family offices in sophisticated financial and other transactions. He represented Merrill Lynch Global Private Equity in connection with its equity participation in the $33 billion acquisition of HCA in what was then the largest LBO ever. He has handled deals aggregating nearly $200 billion in value, including tender offers, “going-private” transactions, IPOs, restructuring and structured finance transactions, and mergers and acquisitions in industries as diverse as biotechnology and aerospace, retail and cable television, and education and scrap metal. He regularly handles transactions outside the U.S., including Europe, the Middle East, Asia, Latin America, Australia, South Africa and India.

Leading our Private Equity Real Estate group, he works with a team of 75 lawyers from across the firm advising on complex transactions and disputes relating to real estate, and particularly hotels. Jeff has handled virtually every type of matter, and has worked with virtually every major player in these industries, including transactions for nearly 3,500 hotels comprising more than 275,000 rooms and involving more than $12 billion. His experience, both in and outside the U.S., extends to hotel and casino development and construction; portfolio and single-property acquisitions; sales and restructurings; financings; management; marketing; reservations systems; litigation counseling and strategic planning; and ancillary services. This breadth of work is key to executing complex and sophisticated transactions, such as the $2.9 billion acquisition of Fairmont Raffles by AccorHotels and its investments in Huazhu, Banyan Tree Hotels & Resorts, Brazil Hotel Group, sbe Entertainment and 21c Museum hotels, among others.

As a senior member of our Entertainment Group, Jeff represents The Broadway League (the national trade association for Broadway theatre), the Tony Awards®, and various other joint venture events and producers. In the media industry, Jeff has advised on the acquisition and sale of television, radio, newspaper and magazine properties, and the acquisition and sale of advertising, promotion and marketing agencies, and related joint ventures. He also advises rights holders, including our long-time clients The Leonard Bernstein Office and The Balanchine Trust. He leads our team representing TSG Entertainment in film-slate financing deals.

Jeff also frequently represents start-up and development-stage companies, as well as established “traditional” businesses, in online, Internet-related or technology businesses. He has handled organizational and structuring matters, venture capital and other equity placements, restructurings (from “down” rounds to recapitalizations to M&A solutions). He has both company-side and investor experience.

As a frequent speaker at real estate and hospitality events, Jeff regularly presents about hotel management agreements at The Hotel School at Cornell’s SC Johnson College of Business, NYU’s Jonathan M. Tisch Center of Hospitality, and on M&A and investment matters at lodging investment conferences around the world, including the NYU Hospitality Industry Investment Conference in New York, Americas Lodging Investment Summit in Los Angeles, the International Hotel Investment Forum in Berlin and the Hotel Investment Conference Asia-Pacific in Hong Kong.

Jeff is a member of the American Hotel & Lodging Association (AHLA) Hospitality Investment Roundtable, ULI (and its Hotel Development Council) and the Advisory Board of the Cornell Center for Real Estate and Finance and has served as a member of the Editorial Board of the Cornell Hotel and Restaurant Administration Quarterly and a member of the Advisory Board of the Cornell Center for Hospitality Research. He is a director of The New York Hospitality Council, Inc., a not-for-profit forum for hospitality industry leaders, and is a member of the Real Estate Capital Policy Advisory Committee of The Real Estate Roundtable. He also has served as a director of the America-Israel Chamber of Commerce, and as a member of the French-American Chamber of Commerce in the U.S. and the American Society of Corporate Secretaries. He was the Chairman of the Board of Labyrinth Theater Company and a director of The Jewish Community Center in Manhattan for more than 15 years, a member of the Executive Committee of the Lawyers’ Division of UJA-Federation for more than five years and an officer of the Henry Kaufmann Foundation for more than a dozen years. He currently serves as Chairman of the Board of The American Playwriting Foundation and Building for the Arts and is a member of the Board of Directors of StreetSquash and The George Balanchine Foundation. He also served as a Vice Chair of the Associates’ Campaign for The Legal Aid Society.

Jeff has been with the firm for his entire career and lives in Manhattan and Connecticut.

Photo of Yuval Tal Yuval Tal

Yuval Tal is a partner in our Corporate Department where he co-heads our internationally recognized Hospitality, Gaming & Leisure Group. Yuval also heads our Asia practice. He is a general corporate and securities lawyer with diverse experience in cross-border mergers & acquisitions (public…

Yuval Tal is a partner in our Corporate Department where he co-heads our internationally recognized Hospitality, Gaming & Leisure Group. Yuval also heads our Asia practice. He is a general corporate and securities lawyer with diverse experience in cross-border mergers & acquisitions (public and private, debt and equity), long-term joint ventures, private equity real estate and corporate and real estate finance. He advises clients on the full range of their activities including any form of financing, operational matters and commercial transactions. He advises sponsors and funds on the structuring, execution, entering into, restructuring and exiting of investments.

Yuval has decades of experience representing clients on complex, first in kind transactions.  His strength is providing original, workable and practical solutions that get the deal done. Qualified in New York, Hong Kong and Israel, Yuval has negotiated transactions in six continents and has experience representing clients on cross border transactions, including inbound to or outbound from Asia. Yuval regularly works with clients in various industries including real estate, hospitality, entertainment, sports, financial services, technology and life sciences.

Yuval is co-chair of Proskauer’s CARES Act Team and was an active member of the Firm’s cross-disciplinary, cross-jurisdictional Coronavirus Taskforce which helped to shape business guidance for clients impacted by the pandemic.

As an international M&A lawyer, Yuval has many years of experience dealing with complicated, non-customary transactions involving parties from different countries, cultures and legal systems.  He has represented private equity, family offices, corporations and individuals in structuring, restructuring, managing and disposing of investments in Asia, Europe and the United States.  He is typically called upon to strategize and structure complex transactions that do not follow a prescribed form or pattern. Yuval’s experience enables him to forsee future issues and clients have commented on his “ability to think seven moves ahead of the competition”. Yuval is also well known for his ability to broker deals between opposing parties in order to get the deal done, irrespective of the legal, business or practical obstacles. His efforts have earned him recognition by Legal 500Chambers Asia Pacific and IFLR1000, where clients have referred to his “ability to play the honest broker to all parties involved, and to bridge the different cultures, legal systems and language barriers and to continually solve the unsolvable, is what allowed us to get this difficult deal done” and another stated “he was completely invested in the deal in a way lawyers seldom are, and his creativity and efforts allowed us to bridge considerable gaps between the parties and find common ground”.

As co-head of our Hospitality, Gaming & Leisure Group, Yuval has worked on virtually any kind of transaction, including mixed-use development and construction, acquisition and sale, restructuring and public offerings of real estate, hotel and casino companies. He has completed numerous high profile transactions involving the buying, selling and combining Asian and Western based hotel operating companies, including AccorHotels’ [EPA:AC]  US$2.9 billion acquisition of Fairmont, Raffles and Swissôtel brands, its acquisition of Tribe, Australia’s first integrated modular hotel brand, Accor’s long-term alliance with Huazhu Hotels Group (also known as China Lodging Group [Nasdaq: HTHT]) and its strategic partnership with Singapore-based Banyan Tree Holdings [SGX:B58]. He also advised Formosa International Hotels’ sale and resulting joint venture with Intercontinental Hotels Group with respect to the Regent brand.  Recent transactions include the formation of  Ennismore, a worldwide hospitality lifestyle platform which currently owns 14 brands and operates over 100 properties; and the sale of the Mexico-based Hoteles City Express brand to Marriott for $100 million.  His real estate and hospitality work has included transactions for brands and properties from China to India to the United States to Australia. He also has many years of experience with hotel licensing, franchising and management.

Yuval’s broader Private Equity Real Estate experience includes working on The Recording Academy’s (The Grammys) deal to develop Grammy Museums in China, a public/private deal to finance an office building in Delhi, India; acquisitions of hotels in Bangkok by a large Japanese institutional investor and a joint venture between a Hong Kong developer and an Asian based private equity fund for the acquisition and redevelopment of a property in Kowloon into a mixed use property including co-living and co-working properties.

Yuval is a member of the Hospitality Development Council of ULI in both the United States and Asia and was previously  a member of the Steering Committee of the Asian council; he was also a member of the Law 360 2020 Hospitality Editorial Board. He is a regular speaker at real estate and hospitality related conferences such as the Hotel Investment Conference Asia-Pacific in Hong Kong.

Prior to rejoining Proskauer in 1999, Yuval practiced law in Israel, representing Israeli clients in transactions in Europe and the United States and European and U.S.-based clients in transactions in Israel. He handled transactions for major publicly traded Israeli companies such as Clal (Israel) Ltd., LifeWatch, Kitan Consolidated Ltd., Orckit Communications Ltd., ECI Telecom Ltd., Scitex Corporation Ltd. and Tecnomatix Technologies Ltd. Since joining Proskauer, Yuval has continued to represent Israeli clients on a wide range of corporate and securities matters.

Photo of Elanit Snow Elanit Snow

Elanit Snow is a senior counsel in the Corporate Department and a member of the Finance Group.

Elanit represents financial institutions, hedge funds, private equity funds and multinational corporations on complex over-the-counter derivatives and other synthetic financing transactions and secondary market and distressed…

Elanit Snow is a senior counsel in the Corporate Department and a member of the Finance Group.

Elanit represents financial institutions, hedge funds, private equity funds and multinational corporations on complex over-the-counter derivatives and other synthetic financing transactions and secondary market and distressed debt trading. She represents clients in structuring and negotiating ISDA, MRA, GMRA, MSFTA, clearing, prime brokerage and other related documentation. Elanit advises clients on structuring bespoke transactions to gain synthetic leverage or to hedge exposure to key market risks. Elanit also advises clients on the legal, compliance and regulatory requirements of the Dodd-Frank Act applicable to derivatives transactions.

Elanit represents both buyers and sellers on a diverse range of transactions involving syndicated loans, bankruptcy claims and other distressed and illiquid assets.

Photo of Jonian Rafti Jonian Rafti

Jonian Rafti is an associate in the Corporate Department and a member of the Health Care Group. Since law school, his practice has exclusively focused on representing a variety of clients in the health care sector, including hospitals and health systems, physician organizations…

Jonian Rafti is an associate in the Corporate Department and a member of the Health Care Group. Since law school, his practice has exclusively focused on representing a variety of clients in the health care sector, including hospitals and health systems, physician organizations, telehealth platforms, and digital health companies.

Jonian provides legal advice on a range of regulatory, corporate, and transactional matters governing the practice of medicine and the health care industry, including: federal and state fraud and abuse compliance; HIPAA; scope of practice limitations; telehealth encounter requirements; practice expansions; and general corporate and business planning.

Jonian is a Certified Information Privacy Professional (CIPP/US). As a law student, he worked at the Charities Bureau of the New York State Office of the Attorney General on matters affecting state not-for-profit corporations.