Health Care Counsel

Arent Fox's health care law blog offers news, analysis, and insights for the health care industry.

Health Care Counsel

Thomas E. Jeffry Jr.

Thomas Jeffry, Partner at Arent Fox
Thomas E. Jeffry Jr.
Los Angeles, CA

Tom Jeffry is a partner in the Health Care group. His practice is devoted to business and regulatory compliance, including compliance investigations, corporate integrity programs, and transactions. Tom represents hospital systems and other providers along with managed care organizations in many areas, including development and construction of health facilities, mergers and acquisitions, drafting and negotiating contracts, and advising on fraud and abuse issues. In addition, he has extensive experience in corporate governance, nonprofit tax and antitrust issues related to integrated delivery systems, health information technology, bioethics, privacy and security, and HIPAA Administrative Simplification regulations.

Previous Work

Prior to joining Arent Fox, Tom was a partner at a large international law firm in the health law department. Previously, he served as city attorney for Jackson, California, and as county counsel for Alpine County, California. He was also the director of communications for the American Academy of Dermatology.

Professional Activities

Tom is an active member of the American Bar Association, the American Health Lawyers Association, and the Health Care Compliance Association. Previously, he served as the vice chairman of the California Medical Association Foundation.

Publications, Presentations, and Recognitions

Tom has been recognized in the Southern California edition of Super Lawyer every year since 2004. He also has been ranked in Chambers USA in their 2013 edition. He is the author of numerous articles and is a regular speaker. Publications and presentations include:

  • “Closing the Deal in the Healthcare M&A Sector: Tips for Clients and Attorneys," Chapter in “Navigating Health Care Transactions – Leading Lawyers on Conducting Due Diligence and Developing Effective Deal Strategy for Health Care Clients," Aspatore Inside the Minds Series, July 2013
  • Moderator, Bisnow's Orange County Healthcare Real Estate Summit, Newport Beach, CA, May 31, 2013
  • “HIPPA Enforcement: OCR on the Doorstep,” 9th Annual Healthcare Law Compliance Symposium, Los Angeles, CA, October 4, 2012
  • “An Overview of Recent Challenges to Hospital Transactions: Is the FTC Really More Aggressive?” Becker’s Hospital Review, May 1, 2012
  • “Invasion of the RACs, Stories and Strategies from the Front Line,” American Health Lawyers Association In-House Counsel Program, June 27, 2010
  • “Compliance Corrective Action Plans: Why and How,” Health Care Compliance Association West Coast Regional Conference, June 18, 2010
  • “Structuring, Implementing and Monitoring Service Contracts: A Team Sport of Compliance, Quality, Legal, and Human Resources,” Health Care Compliance Association Compliance Institute, April 19, 2010
  • “The HITECH Act and You: Things to Know to Maximize the Benefits and Minimize the Pain,” HITECH: Is Your Hospital Ready for this Opportunity? presented by the Hospital Association of Southern California, California Hospital Association, and Arent Fox LLP, January 2010
  • “New Privacy Laws Impacting the Health Care Work Place, California Hospital Association Labor and Employment Law” seminar, November 2009
  • “Doing Business With (or as) a Distressed Company,” California Society for Health Care Attorneys Fall Seminar, November 2009
  • Red Flag Rules Compliance Deadline Approaches: Providers should focus on identity theft prevention program implementation, February 9, 2009
  • “When Does the Medicare Secondary Payer Rule Prevent Medicare Coverage of Clinical Trial ‘Complications’?” Health Lawyers News, March 1, 2008
  • “Charities’ Support of Commercial Clinical Research,” Taxation of Exempts, Sept./Oct. 2007
  • FTC Delays Enforcement of Red Flag Rules to May 1, 2009, October 23, 2008
  • New California Laws Strengthen Patient Privacy, October 3, 2008
  • FTC Releases Restrictive New Prerecorded Telemarketing Rules: Prior written, signed agreements, automated opt-out mechanisms to be required, HIPAA exempt, August 25, 2008
  • Health Care Providers: Don’t Miss the Red Flags, August 19, 2008
  • “Health Care Regulatory and Compliance Update,” Co-hosted with Hospital Association of Southern California, May 20, 2008
  • AIRI Annual Meeting on Increasing Revenue Streams, September 1, 2007
  • Clinical Trials Coverage – Dashed Expectations, But Stay Tuned, July 13, 2007
  • Hospital Association of Southern California Healthcare Regulatory Compliance Update, May 1, 2007
  • California Association of Health Plans on Managing the Press after an Incident, March 1, 2007
  • “Pay for Performance,” Healthcare Financial Management Association, March 1, 2007
  • “Financial Incentives and Gainsharing: Pay for Performance and Gainsharing Legal Issues,” The Second National Pay for Performance Summit, Los Angeles, California, February 15, 2007
  • 13th Annual HIPAA Summit on EHR Acquisition, Implementation and Monitoring legal issues, September 1, 2006
  • Health Care Compliance Association 12th Annual Compliance Institute on joint ventures in imaging centers, April 1, 2006
  • “PFP and Financial Incentives and Legal Issues: Basic Legal Issues in Implementing Healthcare Incentives and Pay for Performance Programs,” National Pay for Performance Summit, Los Angeles, California, February 7, 2006
  • 3rd National Conference on Medical Affairs on Implementation of Medicare Part D, December 1, 2005
  • AIRI 44th Annual Meeting on Legal Issues Affecting Research Institutes, September 1, 2005
  • Gainsharing Opportunities Expand for Physicians and Hospitals, June 22, 2005
  • 10th Annual Health Care Compliance Association on HIPAA and Research, June 1, 2005
  • Los Angeles County Bar Association on Physician Practice Revenues, April 1, 2005
  • Healthcare Information and Management Systems Society-Southern California Chapter Meeting on Sarbanes-Oxley, October 1, 2004

Life Beyond the Law

Tom unwinds on the beach walking his two Golden Retrievers. He loves to sail and crews on racing boats during the summer. His hobbies include digital photography and cooking.


Blog Posts by Thomas E. Jeffry Jr.

E-Health, HIPAA / Health Privacy & Security, Telemedicine & E-health
Congress on Notice: Health Care Cybersecurity is in Critical Condition

Earlier this month, the Health Care Industry Cybersecurity Task Force sent to Congress the Report On Improving Cybersecurity in the Health Care Industry. The Report provided a grim assessment that “health care cybersecurity is a key public health concern that needs immediate and aggressive attention.” Consistent with its mandate under the Cybersecurity Act of 2015, the Task Force included in the Report “six high-level imperatives” to address cybersecurity issues in health care with a total of 21 recommendations and 104 suggested action items to implement those recommendations.

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Pharmaceutical & Device Compliance, Prescription Drug Pricing & Government Price Reporting, Wholesaler & Pharmacy Benefits Compliance
New Year…Same Rules? HHS Makes Few Changes in Recent 340B Drug Pricing Program Final Rule
The Health Resources and Services Administration, part of the Department of Health and Human Services, published a Final Rule on January 5, 2017 addressing how 340B covered outpatient drug “Ceiling Prices” are to be calculated under the 340B Drug Pricing Program, and how participating drug manufacturers may be subject to certain monetary penalties for violation of the 340B statute (the Final Rule). The provisions of the Final Rule are effective March 6, 2017, and HHS indicated that it will begin enforcing the requirements of the Final Rule at the beginning of the second quarter of 2017, meaning April 1, 2017. 
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Anti-Kickback Statute, Office of Inspector General Developments
New Final Regulations Provide Overdue Guidance on Permissible Arrangements Between Providers, Financial Relief for Patients

Over two years after proposing rules for comment, the Office of Inspector General for the Department of Health and Human Services (OIG) just published a final rule which revises and adds new safe harbors to the Anti-Kickback Statute (AKS) and amends the definition of “remuneration” under the Civil Monetary Penalty (CMP) rules. The change to the definition provides for exceptions to the prohibition of the offer or transfer of certain Medicare beneficiary inducements tied to their choice of provider for covered health care items or services. 

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Arent Fox LLP, founded in 1942, is internationally recognized in core practice areas where business and government intersect. With more than 350 lawyers, the firm provides strategic legal counsel and multidisciplinary solutions to clients that range from Fortune 500 corporations to trade associations. The firm has offices in Los Angeles, New York, San Francisco, and Washington, DC.