Laura B. Morgan
PEOPLE

Laura B. Morgan

Partner
morgan.laura@dorsey.com

Overview

Laura helps healthcare industry clients navigate the complex universe of regulations applicable to their operations.

Laura is a healthcare regulatory attorney focusing on healthcare fraud and abuse and compliance. She has substantial experience in both the private and public sectors with laws including the Federal physician self-referral law (or “Stark Law”), Federal anti-kickback statute (AKS), Civil Monetary Penalties Laws, False Claims Act, and Medicare and Medicaid reimbursement issues. She advises healthcare industry clients regarding financial arrangements with physicians and other referral sources, regulatory components of transactions, compliance program operations, internal investigations, and self-disclosures.

Prior to rejoining the Firm in 2025, Laura was a Senior Counsel in the Industry Guidance Branch of the Office of Counsel to the Inspector General at the U.S. Department of Health and Human Services (HHS-OIG). Laura was previously with Dorsey from 2016–2022 and worked in the health group of another national law firm before that time.

Laura frequently writes and speaks about healthcare fraud and abuse and compliance topics. She currently serves on the American Health Law Association (AHLA) Fraud and Abuse Practice Group Leadership Team. 

Education & Admissions

Loyola University of Chicago School of Law (J.D., 2012), magna cum laude

Bethel University (B.A., 2005), summa cum laude

Admissions

  • Minnesota

Experience

Representative Work

HHS-OIG Industry Guidance Branch Experience

  • Reviewed and analyzed HHS-OIG advisory opinion requests and published advisory opinions.
  • Participated in the team that is updating HHS-OIG’s compliance program guidance and co-authored the Nursing Facility Industry Segment-Specific Compliance Program Guidance.
  • Developed and promoted OIG policies and guidance regarding the AKS.
  • Advised government officials on the application of the Federal fraud and abuse laws.
  • Responded to questions from industry representatives regarding compliance with the Federal fraud and abuse laws.

Private Practice Experience

  • Identified violations of the Stark Law by target entities during due diligence and advised regarding self-disclosure of such violations to the Centers for Medicare & Medicaid Services (CMS).
  • Developed compliance monitoring and auditing tools for referral source lease agreements for multi-state client operations to ensure such agreements comply with the Stark Law and AKS; trained client personnel in use of the tools.
  • Negotiated a settlement with HHS-OIG resulting from a self-disclosure of physician compensation arrangements potentially implicating the Stark Law and AKS.
  • Represented client in multi-year qui tam litigation regarding physician compensation arrangements potentially implicating the Stark Law and Medicare billing matters, resulting in a settlement with the Department of Justice (DOJ).
  • Assisted client with successfully obtaining grant of asylum in the United States.

News & Resources

Articles

HHS OIG Releases an Updated Health Care Fraud Self-Disclosure Protocol
Stark Regulatory Changes Require Modifying Certain Group Practice Compensation Methodologies by January 1, 2022
CMS Advisory Opinion Approves Parent and Wholly-Owned Subsidiary Qualifying as “Single Legal Entity” under the Stark “Group Practice” Definition
Stark Regulatory Changes Effective January 1, 2022 Require Modifying Certain Group Practice Compensation Methodologies
White Paper: Understanding the Final Rules to Revise the Anti-Kickback Statute and Beneficiary Inducement Civil Monetary Penalty Regulations
White Paper: Understanding the Final Rules to Revise the Stark Law Regulations
White Papers: Understanding the Final Rules to Revise the Stark Law, Anti-Kickback Statute and Beneficiary Inducement Civil Monetary Penalty Regulations
Much-Anticipated Final Rules to Revise Stark Law, Anti-Kickback Statute, Beneficiary Inducement CMP Regulations Released under “Regulatory Sprint to Coordinated Care”
Is Your Compliance Program More than a Paper Program? DOJ Issues Revised Guidance for Evaluating Corporate Compliance Programs
CMS Issues Explanatory Guidance on Stark Law Blanket Waivers
OIG Initiatives to Ease Provider Burdens Related to COVID-19
New CMS COVID-19 Blanket Waivers for Health Care Providers
Stark Law Blanket Waivers Related to “COVID-19 Purposes” Announced
CMS Announces Relief for Participants in Quality Reporting Programs in Response to COVID-19
2020 CPI-U and DHS Code List Updates Posted on CMS Website
CMS Finalizes Changes to the Stark Advisory Opinion Regulations; 2020 DHS Code List and CPI-U Updates
Sweeping Proposals Issued By CMS To Revise Stark Law Regulations
Sweeping Proposals Issued By OIG To Make Changes To The Anti-Kickback Statute Safe Harbors And Add An Exception To The Civil Monetary Penalty Law Governing Beneficiary Inducements
The “Regulatory Sprint to Coordinated Care” – Overview and Links to Further Resources from Dorsey & Whitney
A Massive Number of New Health Law Regulatory Proposals as Part of the “Regulatory Sprint to Coordinated Care”: Proposed Changes to the Stark Law, Anti-Kickback Statute, Beneficiary Inducement CMP, Privacy Laws Governing Substance Use Disorder Records, and the Stark Law Advisory Opinion Process
Proposed Drug Rebate and PBM Service Fee Regulations Abandoned by Administration
The Eliminating Kickbacks in Recovery Act of 2018 (EKRA): A New Federal Kickback Law Applicable to All Payors
CMS “Actively Working” on Stark Law Reforms to be Issued Later this Year; “Regulatory Sprint to Coordinated Care” Continues
OIG Seeks Public Input on Anti-Kickback Statute and Beneficiary Inducements CMP as part of the “Regulatory Sprint to Coordinated Care”
Calls for Modernizing the Stark Law Continue; CMS Seeks Public Input on Stark Law Reforms

News & Press Mentions

Former HHS-OIG Attorney Laura Morgan Rejoins Dorsey as a Healthcare Partner in Minneapolis
American Health Law Association Speaking of Health Law Podcast; Fraud and Abuse: Agency Interactions—Advisory Opinions
Dorsey & Whitney Names New Partners

Legal Writings

  • Co-Author, Nursing Facility Industry Segment-Specific Compliance Program Guidance (November 2024)
  • Co-Author, Stark Law Toolkit (2022 update), American Health Law Association Fraud and Abuse Practice Group (January 21, 2022)
  • Contributor, The Stark Law Explained: A Comprehensive Guide for the Health Care Industry, Attorneys and Compliance Professionals (Daniel H. Melvin II et. al, McDermott Will & Emery, 2016)
  • Author, The Sunshine Act: Shedding Light on Reporting Requirements, 2013 HEALTH CARE L. MONTHLY 8 (2013)
  • Author, Health Information Technology and Patient Safety: Proceed with Caution, in THE PATIENT SAFETY HANDBOOK, SECOND EDITION (Barbara Youngberg ed., 2012)
  • Author, The Independent Payment Advisory Board: Will it Effectively Curb the Medicare Growth Rate?, 20 ANNALS HEALTH L. ADVANCE DIRECTIVE 124 (2011)
  • Co-Author, 2010 Illinois Association of Healthcare Attorneys Annual Health Law Survey

Select Presentations

  • OIG Compliance Program Guidance: Nursing Facility ICPG, Health Care Compliance Association (“HCCA”) Healthcare Enforcement Compliance Conference (November 20, 2024)
  • Presenter, OIG General Compliance Program Guidance, HCCA Minneapolis Regional Healthcare Compliance Conference (September 13, 2024)
  • Advisory Opinion Process: A Discussion with Current and Former Government Officials Regarding the CMS and OIG Advisory Opinion Processes, AHLA Webinar (November 9, 2023)
  • Governance Webinar Series—Fraud and Abuse, Iowa Hospital Association Webinar (July 12, 2022)
  • Fraud and Abuse Bootcamp, Part I: The Stark Law (American Health Law Association, April 20, 2022)
  • The Regulatory Sprint to Coordinated Care (Minnesota CLE, January 12, 2021)
  • Sweeping Changes to the Stark and Anti-Kickback Regulations: Final Rules for Hospitals (Iowa Hospital Association, January 5, 2021)
  • Iowa Hospital Association 2020 Governance Forum – Regulatory Sprint to Coordinated Care (December 8, 2020)
  • Iowa Hospital Association Governance Webinar Series – Fraud and Abuse (2020)

Industries & Practices

  • Government Solutions & Investigations
  • Healthcare & Life Sciences
  • Healthcare Transactions & Regulations

Professional & Civic

Professional Achievements

  • American Health Law Association (AHLA) member (2010 to present)
    • Fraud and Abuse Practice Group Leadership Team, Vice Chair of Membership (2023–present)
    • Leadership Development Program Participant – Fraud & Abuse Practice Group (2020–2021)
  • Minnesota State Bar Association (MSBA) Health Law Section member (2016 to present)
    • Health Law Section Council Member (2020–2022)
  • Illinois Association of Healthcare Attorneys member (2010–2016)

Accolades

North Star Lawyer logo

  • MSBA North Star Lawyer, 2017-2019
  • Pro Bono Scales of Justice Award, 2016
Laura B. Morgan