Hoff

Samuel R. Hoff

Associate
Boston

I specialize in assisting healthcare providers with compliance issues and the structuring of business arrangements.

Sam Hoff’s practice is focused on compliance issues and the business of healthcare, with a particular emphasis on management service and other business arrangements between clinical and non-clinical entities. He works with clients ranging from hospitals and physician practices to cutting-edge life sciences companies and laboratories.

Sam advises clients on federal and state healthcare fraud and abuse laws. This work includes helping clients implement policies and maintain effective compliance programs. He frequently counsels clients on issues and laws relating to information privacy and security, including HIPAA, state data privacy laws, EU/GDPR, and breach response.

Sam also helps clients with various healthcare transactional matters. These projects include the preparation and negotiation of management services or “friendly PC” agreements, employment and consulting contracts, new entity formations, and medical and dental practice sales and acquisitions. He further advises clients on the development of corporate governance plans, including the preparation and revision of Bylaws, Operating Agreements, and Shareholder Agreements.

Education

  • Boston College Law School, J.D., 2015
  • Colby College, B.A., cum laude, 2009

Bar and Court Admissions

BAR ADMISSIONS
  • Massachusetts
  • Connecticut
COURT ADMISSIONS
  • U.S. District Court for the District of Massachusetts

Experience

FRAUD, ABUSE & COMPLIANCE
  • Implement comprehensive policy programs designed to achieve and maintain compliance with federal and state anti-kickback, physician self-referral, false claims, and other fraud and abuse laws, as well as Federal government health care program (e.g., Medicare) and private payer billing rules.
  • Train sales representatives and other employees of health care providers on interactions with physicians and other licensed practitioners.
  • Develop guidelines for administration of patient financial assistance programs.
  • Prepare application for Advisory Opinion from the Office of Inspector General of the U.S. Department of Health and Human Services.
  • Assist healthcare providers to comply with federal No Surprises Act and related state surprise billing laws, including by responding to patient allegations of overcharges and managing payment disputes with payers. 
DATA PRIVACY & SECURITY
  • Implement comprehensive data security and privacy policy programs and provide HIPAA-compliant documents (e.g., Notice of Privacy Practices and Business Associate Agreements) for variety of healthcare providers.
  • Advise on updates to data protection standards and consumer request response procedures in compliance with California (CPRA) and other state data privacy laws. 
  • Assist U.S.-based telehealth providers to structure EU/GDPR compliance plan.
  • Manage service provider’s response to breach of Protected Health Information held on behalf of healthcare clients in accordance with HIPAA and state law.
  • Counsel healthcare payers and providers on procedure for responding to subpoenas for health information.
TRANSACTIONS 
  • Metropolitan Partners Group, in a senior secured credit facility to the operator of multi-location, multi-specialty ambulatory surgical centers across New York and New Jersey
  • Establish management services arrangements (also known as “MSO-PC models” or “Friendly PC” arrangements) between clinical healthcare providers and non-clinical business entities in compliance with fraud and abuse, corporate practice of medicine, data privacy, and other applicable laws.
  • Represent buyers and sellers in connection with purchases and sales of medical, dental, ophthalmology, and other closely-held practices.
  • Prepare and negotiate service contracts between healthcare providers and referring entities.
  • Form new professional corporations and professional limited liability companies, and implement plan for maintaining compliance with state licensure rules and good standing requirements.
  • MDxHealth SA (Nasdaq/Euronext: MDXH), a foreign private issuer, in its acquisition of the OncoType DX Genomic Prostate Score business from Exact Sciences Corporation (Nasdaq: EXAS) for cash and equity consideration of up to $100 million, including a multi-year earn-out arrangement.

Honors & Involvement Overview

HONORS
INVOLVEMENT
  • Former Member (2017-2022), Board of Directors of Bridgewell, a 501(c)(3) public charity that provides a range of social and human services to approximately 8,000 Massachusetts residents struggling with developmental disabilities, autism, homelessness, and/or substance abuse.

Speaking Engagements Overview

  • “Artificial Intelligence for Health Care Providers: Practical Guidance and Traps for the Unwary,” Massachusetts Health Information Management Association, Virtual Education Workshop (September 2026)
  • "The 340B Program: A Shifting Landscape,” Massachusetts League of Community Health Centers, Health Center Compliance Academy (June 2026)
  • “2026 FQHC Risk Management Workshop,” Massachusetts League of Community Health Centers, Health Center Compliance Academy (June 2026)
  • “Artificial Intelligence in the Community Health Center: Navigating Compliance, Data Privacy, and other Considerations in a Rapidly Evolving Landscape,” Massachusetts League of Community Health Centers, 2026 Community Health Institute Annual Conference (May 2026)
  • "Compliance Considerations and Impact of 42 CFR Part 2 Final Rule," Massachusetts Health Information Management Association, Dot Wagg Legislative Virtual Seminar (November 2025)
  • "Gender-Affirming Care Policy Update," Massachusetts League of Community Health Centers, Member Office Hours (September 2025)
  • "Sound Judgment: Navigating the Legal Frontier of Ambient AI," Colorado Startup Week (September 2025)
  • “Key Privacy Considerations for Reproductive Health Information,” Massachusetts Health Information Management Association, 2025 Fall Conference Series (August 2025)
  • "Healthcare Legislative Panel," Massachusetts Health Information Management Association, 2025 Annual Conference (June 2025)
  • “Federally Qualified Health Center Risk Management: Regulatory Update & Best Practice Highlights,” Massachusetts League of Community Health Centers, 2025 Health Center Compliance Academy (June 2025)
  • “Federally Qualified Health Center Risk Management: Regulatory Updates & Best Practice Highlights,” Massachusetts League of Community Health Centers, 2025 Community Health Institute Annual Conference (April 2025)
  • “2025 Health Center Compliance: Hot Topics Due to Recent Federal Policy and Regulatory Changes,” Massachusetts League of Community Health Centers (February 2025)
  • "Developments in HIPAA and Related Issues in Health Information Law (That You Can't Learn from ChapGPT)," Rhode Island Health Information Management Association (November 2023)
  • "Overview of Legal Agreements,” Idaho Value-Based Care Education Series (May 2023)
  • “HIPAA Compliance in 2021 and Beyond,” MaHIMA Fall Conference Series (September 2021)