Steven C. Chiu

Health Plan Licensure and Compliance

• Established Medicare Advantage plan sponsored by a large statewide academic medical center-anchored health system, including acquisition of state health plan license, development of central policies and procedures, and negotiations of key provider and vendor contracts.
• Established and obtained licensure for numerous health plans, including Medicare Advantage Organizations, Medicaid Managed Care Plans, and risk-bearing providers / restricted health plans, and assisted each in responding to regulatory inquiries relating to all licensure requirements.

Health Systems Reimbursement and Revenue Cycle

• Revised revenue cycle policies and procedures for large national health care system to ensure compliance with federal No Surprises Act surprise billing and good faith estimate requirements and state law counterparts.
• Established and negotiated the terms of a corrective action plan relating to price transparency postings and responded to inquiries from government regulators and consumer advocate groups regarding compliance with hospital price transparency rules.
• Revised Financial Assistance Policy and Billing and Collection Policy and related revenue cycle procedures for large regional nonprofit tax-exempt health care system in response to changes in state charity care laws and IRS / Treasury regulations.
• Provided health systems with analysis of reimbursement changes that would result from decisions to pursue the opening of new children’s hospitals and the proposed acquisition of a county psychiatric hospital by a state-operated academic medical center.
• Negotiated favorable settlement with HHS of outstanding claims for graduate medical education payments payments to teaching hospitals treating Medicare Advantage enrollees.

Government Audit Representation and Response

• Led multi-year effort to conduct top-to-bottom revisions of national insurer’s Medicare Advantage and Medicare Part D prescription drug policies and procedures to lift an enrollment freeze imposed by the Centers for Medicare and Medicaid Services.
• Obtained favorable recoupment action settlement with state Medicaid agency for large Federally-Qualified Health Center (FQHC) network of what would have been a business-threatening penalty by providing analysis of the proper application of FQHC prospective payment system Medicaid managed care reconciliation rules.

Transactions - Regulatory Clearance and Impact Analyses

• Obtained waiver of state insurance agency’s restructuring and conversion public hearing requirement for nonprofit health plan’s acquisition of for-profit Medicaid managed care plan.
• Obtained waiver of major transactions merger review under California AB 595 for internal health plan reorganizations involving a specialized plan’s redomiciling of a parent entity and the sale and purchase of shares among plan owners.
• Obtained Illinois Department of Insurance regulatory approval of an acquisition of a Medicaid business as part of a national three-party merger and divestiture.
• Obtained waiver of California Office of Health Care Affordability’s Cost & Market Impact Review for a Restricted Knox-Keene plan whose shareholders were seeking to obtain a majority stake via a buy-out of other shareholders.
• Obtained California Department of Managed Health Care (DMHC) approval of management services organization partial insourcing for a Restricted Knox-Keene Medi-Cal managed care plan; also obtained CA DMHC approval of a change in management services organizations for a commercial health plan.
• Conducted reverse due diligence of major health insurer’s proposed acquirer and accurately predicted the potential for devaluation of acquirer’s stock related to opioid litigation liability of acquirer’s pharmacy and related operations; shifted terms of multi-billion dollar deal to involve cash consideration in lieu of equity.

• Pasadena Top Attorneys, Pasadena Magazine, 2023–2024
• The Best Lawyers in America, 2023–2026