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Cassandra L. Paolillo



[email protected]



Cassie’s practice primarily involves advising health care clients on transactional and regulatory matters. Cassie has served as deal counsel on a number of transactions, including mergers and acquisitions, joint ventures, and affiliations for clients across the health care spectrum, including a Fortune 250 kidney care company, and providers of radiology services, addiction treatment, and behavioral health services. She also regularly acts as a subject matter expert, advising clients on HIPAA/privacy compliance, telehealth and other digital health matters, corporate practice issues, professional and facility licensing, determinations of need/certificates of need, and Medicare and Medicaid compliance. Cassie also has experience advising non-profit organizations on matters related to formation and corporate governance. 

Throughout her career, Cassie has worked with providers, payors, and individual patients, so she understands the unique challenges facing clients in the ever-changing health care landscape. She enjoys working with interdisciplinary teams to come up with creative solutions to her clients’ problems. 

Prior to joining Mintz, Cassie worked as in-house counsel at a national senior living company. There she advised the business on matters related to state and federal health care regulations, physician arrangements, reimbursement, fraud and abuse, and HIPAA/privacy. Cassie’s in-house experience informs current her practice, enabling her to anticipate and relate to clients’ legal and business needs.

Cassie is particularly passionate about addressing access to behavioral health and substance use disorder treatment, especially for underserved communities, and she currently serves on the Board of the South Boston Collaborative Center, a substance abuse and mental health treatment center located in South Boston. 


  • Suffolk University Law School (JD, summa cum laude)
  • Boston College (BA, cum laude)


  • Member, American Health Law Association
  • Member, Boston Bar Association
  • Board Member, South Boston Collaborative Center


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Last week, CMS announced its final Physician Fee Schedule Payment Policies (the “Final Rule”), which will become effective January 1, 2022. The Final Rule included several updates to Medicare coverage of telehealth services, including a number of COVID-19 related changes that will be extended or be made permanent. As previously covered, while temporary orders allowing expanded use of telehealth have increased access to care across the country during the public health emergency (“PHE”), the regulatory environment for telehealth has always been somewhat unsettled. The changes in the Final Rule described below signal a move towards increased access to telehealth for Medicare beneficiaries as regulators acknowledge the potential benefits of these alternate methods of delivering care.
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As we’ve previously covered, the COVID-19 pandemic has brought about a major increase in the prevalence of telehealth services, due in large part to regulatory flexibilities at the federal and state levels. Beginning in March 2020, state Medicaid programs across the country loosened requirements for coverage of telehealth services provided to Medicaid beneficiaries, reducing barriers by allowing audio-only services and covering a broader scope of services delivered via telehealth. The increase in telehealth has resulted in improved access to behavioral health services in particular, but according to an OIG report issued earlier this week, state Medicaid programs will need to increase their oversight of these services if the telehealth flexibilities become permanent.
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As previously discussed, many of the telehealth flexibilities in place during the COVID-19 pandemic are set to expire at the end of the federal Public Health Emergency (PHE), unless federal and state legislators act to make the changes permanent. A recent bill introduced by Representative Robin Kelly (D-IL) suggests that Congress is interested in expanding access to telehealth services for Medicare and Medicaid beneficiaries if the benefits of increased access to telehealth can be demonstrated. According to a press release issued by Representative Kelly’s office, “Telehealth has the potential to help equalize healthcare access for underserved populations. However, we need data to understand utilization, cost, fraud, privacy and how to serve those left behind by the digital divide.”
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Massachusetts Public Health Council Approves Amendments to Clinic Licensure Regulations

May 11, 2021 | Blog | By Daria Niewenhous, Cassandra Paolillo

On April 28, the Massachusetts Public Health Council (“PHC”) approved final proposed amendments to the clinic licensure regulations. The amended regulations include changes related to serious reportable events, mobile sites, mental health and substance use disorder services, among other updates. The final regulations, which we've summarized here, are expected to be published in the May 14, 2021 Massachusetts Register.
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Health Law Diagnosed — Telehealth Transformation: Where We Are and Where We’re Headed

April 9, 2021 | Podcast | By Ellen Janos, Cassandra Paolillo

The ability to provide health care from a remote location has been around for many years, but with the arrival of COVID-19, hospitals, physicians, and other health care providers have had to rapidly rethink their traditional models of health care delivery.
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Telehealth Update: States Move to Permanently Expand Access to Telehealth

March 30, 2021 | Blog | By Cassandra Paolillo, Ellen Janos

Over the past year the telehealth landscape has been a patchwork of temporary waivers and regulations, expanding access during the COVID-19 pandemic but leaving providers and patients uncertain about whether the positive coverage and reimbursement changes and relaxation of pre-pandemic restrictions would continue in the future. In recent weeks, we have seen a number of state actions making permanent changes to expand access to telehealth. These changes suggest a positive trend towards making telehealth an integral part of the care delivery system, although the complicated regulatory frameworks still present challenges to providers seeking to treat patients via telehealth.
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Since the beginning of the pandemic, telehealth providers have seen a dramatic increase in demand for their services along with a number of temporary regulatory measures aimed at expanding telehealth access to more patient populations. In this post, we outline some important developments that will bring greater certainty to telehealth providers and suggest that expanded access to telehealth is here to stay.
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HIPAA Amendments and Other Trump Regulatory Actions on Hold

January 21, 2021 | Blog | By Dianne Bourque, Cassandra Paolillo

In the waning days of the Trump administration, the Office for Civil Rights (“OCR”) announced a number of new initiatives, including proposed HIPAA amendments, discussed here, and a very recent COVID-19 related Notice of Enforcement Discretion. Under the Notice of Enforcement Discretion, published on January 19, 2021, OCR announced that it would not impose penalties for non-compliance with HIPAA on covered entities making good faith use of online or web-based applications for COVID-19 vaccination scheduling. With the swearing in of President Biden, these and other regulatory initiatives, including all regulations that have been sent to the Office of the Federal Register, but not yet published, are to be withdrawn until a department or agency head appointed by President Biden reviews and approves the rule.
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The Department of Health and Human Services (HHS) is pushing ahead in its Regulatory Sprint to Coordinated Care with a new proposed rule, announced by HHS’ Office for Civil Rights on December 10, to modify the HIPAA Privacy Rule. This proposed rule follows HHS’ 2018 Request for Information on Modifying HIPAA Rules to Improve Coordinated Care, which sought to identify regulatory impediments to value-based care presented by HIPAA. With this proposed rule, HHS aims to “reduce burden on providers and support new ways for them to innovate and coordinate care on behalf of patients, while ensuring that [HHS] uphold[s] HIPAA’s promise of privacy and security,” according to HHS Deputy Secretary Eric Hargan. It would achieve these objectives through a variety of updates to the Privacy Rule, which we highlight in this blog post, along with initial reactions from our HIPAA privacy team.
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As COVID-19 infection rates continue to rise in areas of the country, telehealth continues to play an important role in the delivery of healthcare, especially to those most vulnerable to the virus. Existing telehealth waivers continue in effect under the Public Health Emergency, and new legislation seeks to expand telehealth access through home health services. Plus, join us for a webinar on the future of telehealth.
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Telehealth: What's Next?

Women Business Leaders of the U.S. Health Care Industry Foundation (WBL) Event

Online Event

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