Steven Chananie is a special counsel in the Corporate Practice Group in the firm's New York office, focusing on healthcare issues.
In his practice, Steven assists his clients in navigating the often complex and evolving healthcare regulatory environment. He has represented numerous healthcare providers, advising them on regulatory and fraud and abuse issues in the structuring of complex healthcare transactions; guiding them in the resolution of potential compliance problems; assisting them in implementing or modifying their compliance programs; and responding to government investigations.
With many years of experience specializing in healthcare regulatory and transactional matters, Steven has developed particular expertise in the following areas:
- He has advised a wide range of healthcare clients on the intricacies of Medicare and Medicaid reimbursement, documentation and coding issues, including traditional hospital reimbursement systems, physician fee-for-service, teaching physician rules and regulations, and Medicare Advantage HCC-RAF coding and reimbursement methodologies. Based on this expertise, he has conducted numerous internal investigations for clients and guided them through voluntary disclosures and refunds to governmental authorities, as well as to commercial and managed care payors. Such disclosures and refunds require careful attention to federal and state rules and regulations promulgated by the OIG, state authorities, and those under the Affordable Care Act and the False Claims Act.
- Steven's knowledge of the state and federal anti-referral laws – including the federal Stark Law, the Anti-Kickback Statute and the Civil Monetary Penalties Law – is extensive. He has worked with clients to structure compliant transactions that allow clients to achieve appropriate clinical and operational goals. He has also helped client's address the often difficult situation when an existing transaction or relationship has potentially become non-compliant under these laws.
- As a healthcare regulatory attorney, Steven has a deep knowledge of and experience with state and federal regulatory issues, including, among others, state corporate practice of medicine prohibitions, fee-splitting rules, federal and state exclusion rules, and state and federal compliance program requirements.
- Steven has worked over the years with clients to assess and address regulatory and compliance risks in their day-to-day operations, in entering into complex transactions (including mergers and acquisitions), and in implementing or enhancing compliance programs. He has, for instance, been deeply involved in regulatory due diligences for major transactions and has worked with clients on an ongoing basis as an advisor to their compliance program staff, legal counsel's office, and Board of Directors.
- Steven has also defended clients against civil government actions and investigations, including in False Claims Act cases, the negotiation of Corporate Integrity Agreements ("CIAs") with the OIG, threatened Anti-Kickback prosecutions, and various state and federal audits. He brings his knowledge of government enforcement efforts — along with his technical legal expertise and his practical understanding of how healthcare providers operate in the real world — to his guidance on regulatory and transactional matters.
His clients include academic medical centers, hospital systems, faculty practice plans, laboratories (both independent and hospital-based), physician practices, ambulatory surgery centers, nursing homes, and home health agencies.
Steven has lectured extensively on compliance, regulatory, defense and related issues. Chambers USA noted that he is "very responsive and thoughtful." Sources say: "He's just a fine human being. His expertise and his level of service coupled together make him an excellent attorney."
Prior to entering private practice, Steven was Chief of Appeals at the Queens County District Attorney's Office (1993 - 1996), Counsel to Field Operations and chief appellate counsel at the New York State Organized Crime Task Force (1987 - 1993), and an Assistant District Attorney at the Manhattan District Attorney's Office (1983 - 1987). While at the Manhattan District Attorney's Office, he took a leave of absence to clerk for former Chief Judge Judith Kaye on the New York State Court of Appeals. Steven has also taught Appellate Advocacy and Criminal Procedure as an adjunct professor at Brooklyn and Pace Law Schools.
