Thomas Tanabe
Biography
Thomas Tanabe is an associate in the Healthcare Transactions and Regulatory Practice Group in Haynes Boone's Dallas office. He advises healthcare providers, private equity sponsors, lenders, and other industry participants on a broad range of healthcare regulatory and transactional matters, including mergers and acquisitions, financings, joint ventures, and other strategic transactions.
While attending Texas A&M University School of Law, Thomas completed legal externships with the legal departments of multiple large health systems and a federal agency, providing him with valuable insight into the regulatory and operational challenges facing healthcare organizations.
Prior to law school, Thomas worked as a public health researcher and infectious disease data analyst for the State of Texas and local health departments.
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- Conduct comprehensive federal and state healthcare regulatory due diligence and compliance assessments in connection with healthcare mergers and acquisitions (M&A), private equity-backed platform and add-on acquisitions, joint ventures, debt financings and credit facilities, and other strategic business arrangements, with particular focus on corporate practice of medicine (CPOM), healthcare fraud and abuse, HIPAA and healthcare privacy, reimbursement, licensure, and related regulatory considerations.
- Advise clients on professional entity formation, healthcare transaction notification requirements, change of ownership (CHOW) filings, and provider enrollment, licensure, and other regulatory approvals arising in connection with healthcare transactions and restructurings.
- Provide healthcare regulatory compliance, operational risk management, and regulatory strategy advice to hospitals and health systems, physician groups, management services organizations (MSOs), dental service organizations (DSOs), healthcare technology and digital health companies, and other healthcare industry participants.
- Draft and review HIPAA Privacy Rule, Security Rule, and Breach Notification Rule policies and procedures, compliance documentation, and business associate agreements (BAAs) for covered entities and business associates including healthcare providers and healthcare technology companies.
- Conduct federal Anti-Kickback Statute (AKS), Stark Law, and other healthcare fraud and abuse analyses involving physician compensation arrangements, referral relationships, discount and rebate programs, marketing and advertising initiatives, management services agreements, and other service arrangements.
- Provide healthcare regulatory counsel to issuers and underwriters in connection with securities offerings and SEC filings in the life sciences and healthcare sectors.
- Assist healthcare organizations with compliance programs, internal investigations, and risk assessments, and represent them in government audits, investigations, and enforcement inquiries, including matters involving potential False Claims Act (FCA) liability.
- Provide guidance on provider enrollment, billing, and claims submission requirements under Medicare, Medicaid, CHIP, TRICARE, Medicare Advantage, and other federal and state healthcare reimbursement programs.
- Represent healthcare providers in third party payor and Medicare audit appeals, reimbursement disputes, and overpayment matters, including hearings before Administrative Law Judges (ALJs) of the Office of Medicare Hearings and Appeals (OMHA).
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- Dallas Bar Association, Health Law Section
- State of Bar of Texas, Health Law Section
- American Health Law Association
- American Bar Association, Health Law Section
- Diversity & Inclusion Fellowship Award 2025-2027
- Business & Transactions Healthcare Interest Group
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- "Contract Considerations for Health Care Technology Companies", co-author, Dallas Bar Association Headnotes, February 2026, Volume 51, Number 2.
- “Appeals Closed: HIPAA Reproductive Health Care Privacy Rule Remains Vacated,” co-author, American Health Law Association, September 25, 2025.
- “HIPAA Reproductive Health Care Privacy Rule Vacated,” co-author, American Health Law Association, July 22, 2025.
- “Redrawing the Lines: Texas Reforms Noncompete Agreements for Healthcare Professionals,” co-author, Haynes Boone client alert, June 9, 2025.
- “Hot Topics in Fraud for Healthcare Technology Companies,” co-author, Dallas Bar Association Headnotes, April 2025, Volume 50, Number 4.
- “HIPAA Security Rule Proposed Updates: Addressing Increasing Cyberthreats in Health Care,” co-author, American Health Law Association, January 29, 2025.
- “Compliance Deadline for HIPAA Reproductive Health Care Privacy Rule Looms While Uncertainty over Future Remains,” co-author, American Health Law Association, December 12, 2024.
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Education
- J.D., Texas A&M University School of Law, cum laude
- M.B.A., University of Texas at San Antonio
- M.P.H., University of Texas Health Science Center Houston
- B.S., Public Health, University of Texas at San Antonio, summa cum laude
- B.A., Sociology, University of Texas at San Antonio, summa cum laude
- Postgraduate Certificate in Healthcare Administration, University of Texas Health Science Center Houston
Admissions
- Texas
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