Charles Normand is a partner in the Health Law Practice Group with extensive experience representing a broad range of local and national health care providers on transactional, regulatory, compliance, and related matters. Mr. Normand's experience within the health care industry, as both outside and in-house counsel and as a former Medicare provider representative, gives him a unique and practical perspective to help solve client needs.
Mr. Normand has represented clients in a variety of complex transactions, including mergers; acquisitions; affiliations; reorganizations; and financings, including hospital affiliations and disaffiliations. He has counseled clients on structuring and negotiating affiliations and business relationships among health care providers as well as on related regulatory, reimbursement, financing, and corporate matters. He focuses on a variety of specialized health care areas, including Medicare and Medicaid reimbursement and coverage issues, response to third-party and governmental audits and investigations, Stark law and fraud and abuse analysis, HIPAA, medical records and information technology issues, and compliance program guidance. He frequently speaks at regional and national venues on health care compliance, fraud and abuse, and HIPAA issues.
Prior to joining Robinson & Cole, Mr. Normand was the founding partner of Normand Law, Ltd., a health care- and business-focused law firm in Providence, Rhode Island, where he worked for clients across a broad range of entities, including hospitals, nursing homes, individual physicians, physician groups, for-profit and nonprofit health care providers, privately held businesses, and national and international companies.
Professional Associations
- American Health Lawyers Association
- Rhode Island Bar Association
Community Involvement
- Nurse Practitioner Associates for Continuing Education (NPACE), Board of Directors
- AARP Rhode Island, Executive Advisory Committee
- Rhode Island Quality Institute's Policy and Legal Committee for Development of Health Information Exchange
- Rotary Club of Jamestown, Rhode Island
- American Red Cross, Rhode Island Chapter, Past Chairman of Board of Directors
Experience
- Compliance, regulatory, EMTALA, and HIPAA counseling of national behavioral health company and dialysis services companies. *
- Representation of a large multisite physician group practice on contract, reimbursement, ancillary service arrangements, and Stark and anti-kickback law compliance. *
- Representation of providers in connection with federal and state subpoena and investigation of possible Medicare and Medicaid overpayments, false claims, and related issues and negotiation of settlements with U.S. Attorney, HHS-OIG, and state Medicaid fraud control units. *
- General corporate advice to a multistate restaurant company and its shareholders. *
- Development of corporate compliance programs for hospitals, nursing homes, physician groups, academic medical center foundation, imaging company, and a computer services company. *
- Representation of diagnostic imaging centers in the development of MRI, PET, and nuclear cardiac testing facilities and related regulatory, reimbursement, and contract issues. *
- Representation of multistate nursing home company in the acquisition of four nursing homes out of receivership, regulatory approval process, and $25 million acquisition loan. *
- Representation of cardiology group practice in negotiation of exclusive cardiology services agreement with community hospital's cardiology program joint venture. *
- Representation of custom handblown glass company with development of buyout and operational issues for LLC operating agreement. *
- Representation of buyers and sellers of physician practices and structuring of buy-in and earn-out provisions for physicians joining or leaving a practice. *
- Representation of a publicly traded medical products manufacturer concerning the structuring of numerous distributor agreements and discount, rebate, and group purchasing arrangements for compliance with federal regulatory requirements. *
- Local counsel to regional nursing home provider in $64 million refinancing and subsequent $45 million participation loan. *
- Representation of seller in $66 million sale of four assisted living facilities in Massachusetts, New Hampshire, and Vermont. *
- Representation of home and hospice care provider in a disaffiliation from a large health care system and conversion to a freestanding entity, including negotiation of deal terms, representation before the Attorney General's Office on proposed use of nonprofit foundation assets, and representation before the Department of Health for regulatory approval and transfer of ownership licenses. *
- Regulatory counsel to multistate dialysis company. *
- General counsel to family office/nondepository trust company. *
- Representation as deal counsel in affiliation of nursing home system and adult day care system. *
- General counsel to multistate pathology group practice. *
- Representation of hospital bone marrow transplant (BMT) program in the successful opposition to CON application of competing hospital system. *
- Representation of provider in response to third-party payor, Medicare, and OIG postpayment audit and investigation. *
- Representation of hospital medical system in affiliation with Catholic community hospital and formation of nonprofit health care system. *
* Atty. Normand was counsel in these representative matters before joining Robinson and Cole.
Publications & Presentations
Articles
- "OIG Issues Draft Supplemental Compliance Program Guidance for Hospitals" (6/2004), a client alert of Normand Law, Ltd.
- "Health Information Privacy Rules: Compliance Issues and Practical Steps" (6/2001), published in NORCAL Mutual Insurance Company's Claims Rx
- "Special Fraud Alert: OIG Cautions Physicians Regarding Office Space Rental Arrangements" (3/2000), a client alert of Brown Rudnick Berlack Israels
- "Health Care Compliance Programs: A different type of risk management" (April/May 1998), published in Journal of Healthcare Safety, Compliance and Infection Control
Presentations
- Panelist on electronic medical records (9/2008), presented at Health Care Compliance Association Annual Conference, Waltham, Massachusetts
- "Emerging Issues Update" (9/2007) presented at Health Care Compliance Association Annual Conference, Waltham, Massachusetts
- "Corporate Governance, Measuring Compliance Effectiveness, and Creating an Ethical Culture" (9/2006) presented at Health Care Compliance Association, New England Annual Region 1 Conference, Woburn, Massachusetts
- "Stark Reality: The Regulations Are Finally Here" (10/2004) presented at Rhode Island Medical Group Management Association (MGMA), Providence, Rhode Island
- "Stark II, Parts 1 and 2" (September 2004) presented at Massachusetts MGMA, Westborough, Massachusetts
- "HIPAA Explained" (4/2004) presented at Rhode Island Bar Association CLE Seminar, Providence, Rhode Island
- "Hot Regulatory Topics: Health Care Compliance Association" (9/2003) presented at New England Annual Region 1 Conference, Woburn, Massachusetts
- "HIPAA - Health Information: Confidentiality, Conflicts and Compliance - Meeting Your Obligations Under State & Federal Law" (8/2003) presented at Warwick, Rhode Island
- "HIPAA Made Simple: A Practical Guide to Compliance" (5/2002) presented at ProHealth Forum, Farmington, Connecticut
- "Demystifying HIPAA: What You Need to Know" (3/2002) presented at Rhode Island Medical Society, Warwick, Rhode Island
- "Privacy of Health Care Information Under HIPAA: Minimum Necessary Standards - Stay Tuned" (10/2001) presented at Healthcare Financial Management Association, Providence, Rhode Island
- "Stark II Impact on Physician Arrangements" (10/2001) presented at NORCAL Mutual Insurance Company, San Francisco, California
- "Fraud and Abuse in Mental Health" (9/2001) presented at Massachusetts Hospital Association, Framingham, Massachusetts
- "Stark II Final Regulations Phase I (Stay Tuned for Phase II)" (4/2001) presented at Massachusetts and Rhode Island MGMA
News
8.31.11, Robinson & Cole's Health Law Practice and Providence Office Expand