Alex Goldsmith has spent more than 30 years advising the healthcare industry, including more than two decades focused almost exclusively on healthcare providers and nearly half of his legal career serving as General Counsel and Associate General Counsel for two large healthcare systems. His practice is grounded in the operational realities of hospitals and provider organizations, enabling him to help clients navigate the legal, regulatory, compliance, and operational issues that arise in the delivery of patient care.

Alex has extensive experience drafting, reviewing, and negotiating a variety of healthcare agreements, including participation agreements, physician and clinician agreements, facility operations agreements, ancillary service agreements, vendor agreements, and patient-facing forms and agreements. He has also worked closely with corporate and facility leadership to develop and update administrative processes, policies, and procedures and with clinical teams to develop and document compliant clinical processes.

Alex is also well-versed in appealing payment denials issued by Medicare, Medicaid, and private payers. He helped develop and manage a program to appeal every Medicare denial a healthcare system received and has represented providers challenging payment denials in hundreds of ALJ hearings. He regularly trained physicians and other clinicians on effective testimony and documentation strategies in support of the appeals process.

For the last decade, Alex has focused on providing day-to-day legal support to hospitals, advising on a broad range of operational, regulatory, and provider-related issues, including:

• Regulatory Compliance
  • AKS, Stark, FCA, HIPAA, EMTALA, etc.
  • Federal Conditions of Participation and Payment
  • CMS regulations and guidance
  • The Joint Commission Elements of Performance

• Medical Staff and Provider Matters
  • Credentialing, privileging, licensure, FPPE & OPPE, and peer review
  • Medical Staff Bylaws, Rules & Regulations and Governing Body Bylaws
  • Collegial intervention, corrective action, fair hearings, and NPDB reporting
  • Allegations of disruptive behavior, sexual harassment, substance abuse, burnout, etc.

• Internal Investigations
  • Conducted and/or directed more than 100 internal investigations
  • Handled overpayment analyses and repayments to ensure compliance with FCA
  • Allegations of inadequate care, false documentation, conflicts of interest, etc.

• Hospital Operations and Patient Care Matters
  • CMS, state agency, and TJC surveys and Plans of Correction
  • Matters involving state administrative boards, including Boards of Medicine and Nursing
  • Patient capacity, consents to treat, POAs, DNRs, POLSTs, and other healthcare directives
  • Telehealth, utilization review, difficult discharges, RCAs, and mortality reviews

Prior to joining OGC, Alex served as Vice President & Associate General Counsel for Encompass Health, the nation’s largest owner and operator of inpatient rehabilitation hospitals. In that role, he advised more than 170 hospitals (in 37 states, with 40,000+ employees, and 8,000+ providers with clinical privileges) on the legal issues affecting day-to-day hospital operations, with a particular focus on provider-related issues.

Previously, Alex served as General Counsel of NaphCare, a leading national correctional healthcare company, where he oversaw the company’s legal, risk management, and compliance functions, while supporting medical, mental health, and pharmacy services across hundreds of facilities nationwide.

Earlier in his career, Alex was in private practice in Birmingham, Alabama, first at Burr & Forman and later as an equity partner at Christian & Small, representing healthcare providers in medical malpractice, products liability, business, and employment litigation matters. That litigation background continues to inform his practical approach to risk management, internal investigations, and dispute resolution.

Outside of work, Alex serves on the boards of several nonprofit organizations and volunteers regularly at a local food pantry and homeless shelter. He is an avid reader of literary fiction and enjoys meditation and mindfulness.