Overview

Raja Sékaran leverages more than 25 years of experience in leadership roles at health care organizations, as a former health law enforcement attorney, and in private practice to help industry players navigate business law and health care regulatory issues.

Clients throughout the health care industry regularly seek Raja’s guidance. They include health care delivery systems and hospitals (including academic medical centers), physician groups, independent practice associations (IPAs), health plans, medical device companies, trade associations, private equity investors, and a county’s local health authority, among others.

For health care providers, Raja counsels on governance issues, regulatory compliance, government investigations and white-collar defense, Medicare and Medicaid, and revenue cycle matters. For health plans and other payers, Raja provides advice on network contracting and issues relating to the laws of managed care, including the Knox-Keene Act in California. He also serves as counsel to California's private-sector health insurance exchange for small group insurance.

Clients benefit from Raja’s experience and relationships in both the private and public sectors. Raja started his health law career in private practice and then transitioned to a role as Senior Counsel in the Office of Inspector General (OIG) for the U.S. Department of Health & Human Services. At the OIG, he represented the agency in administrative and civil litigation under the False Claims Act (FCA), negotiated numerous Corporate Integrity Agreements (CIAs), conducted CIA site visits of health care providers, and drafted OIG advisory opinions on the federal Anti-Kickback Statute. After leaving public service, Raja held several corporate leadership positions: Vice President of Regulatory Affairs of a national, publicly traded health care company; Chief Legal Officer and Compliance Officer (respectively) of two California health plans; and Vice President & Associate General Counsel of one of the largest health care delivery systems in the United States.

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Raja draws from his varied background to deftly assist clients in corporate transactions, regulatory matters, disputes, government investigations, and voluntary compliance activities. Additionally, as a registered lobbyist, he has actively promoted his clients’ interests through legislative proposals and before federal and state agencies.

Raja also possesses extensive experience in corporate governance issues. He serves as the board-appointed counsel to the largest IPA in Northern California, participating in all board and executive committee meetings. Earlier in his career, Raja served for 12 years as staff to the Audit & Compliance Committee of one of the country’s largest health care delivery systems. As chair of the audit committee (and former chair of the corporate governance and board development committee) of an owner and operator of senior living communities, Raja oversees annual audits and enterprise risk management. Because of his leadership in multiple professional settings, Raja has earned a strong reputation within the legal and health care industries.

Before joining Epstein Becker Green, Raja served as co-chair of the Health Care Group at a national law firm, where he was also the co-chair of the Racially & Ethnically Diverse Affinity Group and a member of that firm’s Diversity, Equity & Inclusion Committee and Political Action Committee Board.

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Focus Areas

Experience

  • Serves as lead outside general counsel to an IPA consisting of over 5,000 physicians throughout Northern California. Raja provides guidance and representation on a range of matters—from corporate governance and regulatory compliance to policy formation, payer negotiations, and physician disciplinary proceedings.
  • Serves as lead outside regulatory counsel to a publicly traded company operating IPAs, health plans, and medical groups, by supporting mergers, acquisitions, and payer strategy, including a recent $200 million transaction for the purchase of a health plan and IPA’s management company.
  • Serves as lead counsel for a local health authority in its attempt to create a new health plan offering a single-plan Medi-Cal managed care program for a California county. This involves navigating a complicated regulatory framework among the California Department of Managed Health Care, the California Department of Health Care Services, and the U.S. Centers for Medicare & Medicaid Services.
  • Serves as lead health care regulatory counsel to a major Southern California academic medical center consisting of multiple hospitals and affiliates in the Los Angeles metropolitan area, providing counsel and transactional support to the client on regulatory matters, physician transactions, coding, billing, and operations.
  • Serves as lead counsel for a joint venture among multiple Southern California hospital associations that became the primary shared organization providing patient safety and quality data analytics to California hospitals. Raja advised on the design and build of a data analytics program to comply with privacy, data security, and antitrust laws.
  • Represents an electronic health record company in responding to a government subpoena related to physician transactions under the Stark Law and Anti-Kickback Statute.
  • Has represented various clients in more than 100 government investigations at the state and federal levels, including approximately 75 under the FCA.
  • Has represented telemedicine companies and device manufacturers in investigations brought by professional boards under the California Department of Consumer Affairs.
  • Provided public policy advocacy and legal representation to an optical medtech company in matters involving the Federal Trade Commission and the U.S. Food and Drug Administration.
  • Provided legislative advocacy at both the federal and state levels for multiple COVID-19 testing companies, including lobbying for a disease advocacy organization to secure continued state funding for its disease registry.
  • Navigated health care clients through regulatory, operational, and enforcement issues relating to the COVID-19 pandemic, including advising on telemedicine issues, revenue cycle, and billing implications of COVID-19 testing under the CARES Act, and lobbying government agencies to accept new testing modalities.
  • Represented a cooperating witness in a U.S. Department of Justice prosecution arising from its COVID-19 Fraud Task Force, negotiating a plea agreement and serving as counsel of record through the sentencing phase.
  • Led the internal investigation into a complex cybersecurity attack (involving spear phishing and identity theft) on a health plan client, resulting in a loss of nearly $1 million. Using Raja’s investigative report, the FBI identified the hacker’s location and opened a grand jury proceeding of an identified suspect. Raja’s team successfully recovered most of the stolen funds via insurance claims and a settlement with a bank.
  • Co-led a multidisciplinary team to advise a health plan and Northern California-based IPA on their merger and sale to a population health management company, navigating the client through multiple transactions to combine strategic corporate transactional structures, avoiding significant regulatory risks at both the federal and state levels and securing regulatory approval from the Department of Managed Health Care.
  • Represented a radiology, gastroenterology, and telemedicine group in its mergers, ownership structure reorganization, and relationship to its management services organization.
  • Served as regulatory counsel to private equity investors in successful sales and acquisitions of interests in a speech-language pathology group, a clinical trial company, and a group of surgery centers.
  • Secured from a Medicaid agency a stay of the suspension of Medicaid program payments to a specialty pharmacy that supplies HIV/AIDS medication to vulnerable and low-income individuals, by demonstrating to the Medicaid agency the devastating effect the suspension would have had on vulnerable individuals.
  • Led the representation of a nonprofit health care system spanning three states and including hospitals, clinics, and physician groups. Raja handled regulatory matters involving physician transactions and billing of federal health care programs, including leading privileged audits, investigations, policy formation, and, when necessary, self-disclosures to government agencies.

Recognition

  • Chambers USA: America’s Leading Lawyers for Business: California—Healthcare, "Leader in Their Field" (2021 to 2024); “Notable Practitioner” (2020)
  • Daily Journal: “Top Healthcare Lawyer” (2020 to 2022)
  • The National Law Journal: “Healthcare Trailblazers” (2020)

Credentials

Education

  • Georgetown University Law Center (LL.M., with distinction in Healthcare Law, 1997)
  • Cornell Law School (J.D., 1992)
    • Concentration in Business Law & Regulation
  • University of California, Berkeley (B.A., with distinction, 1988)

Bar Admissions

  • California

Professional & Community Involvement

  • American Health Lawyers Association
  • Elder Care Alliance, Board of Directors, Chair of Audit Committee
  • Health Care Compliance Association
  • South Asian Bar Association
  • Law360 Health Editorial Advisory Board (2019 to 2020)
  • California Society for Healthcare Attorneys, President (2013 to 2015)

Media

Events

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Past Events

  • The Bridge Group's 2021 Fall Meeting: Private Equity & M&A—What’s Happening
  • The Bridge Group's 2021 Fall Meeting: Government Enforcement Update
  • HCCA's Virtual Regional Healthcare Compliance Conference: Regulatory, Enforcement Updates and Hot Topics
  • 5th Annual West Coast Ambulatory Surgery Center Seminar: Reimbursement Strategies
  • 5th Annual West Coast Ambulatory Surgery Center Seminar: Monitoring Compliance and Physician Relationships
  • Hardesty Healthcare Solutions Luncheon Series: A Day in the Life of a Healthcare Regulatory Lawyer
  • 4th Annual West Coast Ambulatory Surgery Center Seminar: Opportunities and Limitations for ASCs in a Value-Based Environment
  • American Health Lawyers Association Webinar: What Keeps You and Your Clients Up at Night? Brainstorming Thorny Fraud and Abuse Issues
  • California Society for Healthcare Attorneys Fall Meeting: Different Sides/Different Perspectives – Review of Topical False Claims Act Healthcare Cases
  • 2017 AHLA Annual Meeting: When 21st Century Innovations Meet a 20th Century Legal Framework: Issue Spotting for the Healthcare Lawyer

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