Hoyt Sze advises health systems, academic medical centers and healthcare providers on complex healthcare enforcement and compliance matters, bringing a practical, operations-minded perspective shaped by his experience as in-house counsel, external counsel and a chief compliance officer. He has extensive experience guiding clients through the full life cycle of a healthcare investigation, from evaluating initial complaints to performing internal and external investigations to completing corrective actions that fix vulnerabilities.
Hoyt was previously managing counsel and interim deputy general counsel of the systemwide health law group at the University of California, where he oversaw all healthcare investigations, including evaluating initial complaints and scoping and managing investigations. He also frequently briefed senior leadership and the Board of Regents on individual investigations and enterprise risk. As longtime external counsel, he conducted complex investigations, responded to subpoenas and civil investigative demands and interfaced with the U.S. Department of Justice and other agencies. As a chief compliance officer, Hoyt led post-investigation remediation, including revising policies and procedures, conducting trainings, formulating audits and addressing tone-at-the-top and other root causes. He also has deep experience with fraud and abuse laws, including the Anti-Kickback Statute, the Stark Law, the False Claims Act and the Civil Monetary Penalties Law, as well as relevant healthcare regulatory areas, such as Medicare billing and coding and conditions of participation. With a broad foundation in healthcare law, an understanding of operational realities and a holistic perspective, Hoyt provides knowledgeable, practical advice to his clients during investigations.
Hoyt also has advised higher education institutions on high-level research and conflict-of-interest investigations. While at the University of California, he was the Office of General Counsel’s systemwide expert on foreign influence, performed a variety of investigations and helped adopt significant compliance measures, including a multi-factor risk-based approach to assessing institutional research collaborations with non-U.S. partners.
Hoyt serves on the Planning Committee for the American Health Law Association’s Annual Meeting. He also frequently speaks and writes on healthcare fraud and abuse and investigative topics, as well as enforcement issues facing higher education institutions.