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Cody Keetch

(he/him/his)

Associate

[email protected]

+1.212.692.6760

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Cody focuses his practice on health care matters. He dedicates a large portion of his practice to complex health care industry transactions, including mergers and acquisitions, joint ventures, and affiliations, for health care providers and investors across the United States. His recent health care industry merger and acquisition experience includes transactions for a Fortune 250 company, a nephrology practice group, and providers of radiology services.

In addition to his transactional practice, Cody provides counsel to non-profit organizations on matters related to formation and corporate governance and advises digital health companies on general business and corporate matters, including day-to-day corporate governance, corporate compliance, contracting, and HIPPA compliance. He also advises digital health companies on regulatory matters related to telehealth and the corporate practice of medicine.

Cody is actively involved in pro bono matters and regularly advises non-profit organizations on corporate governance matters and matters related to obtaining tax-exempt status.

Prior to joining Mintz, Cody was an associate at a Long Island, New York–based boutique law firm that serves the health care industry, where he handled transactional and corporate matters.

While attending law school, Cody had a number of internships and externships focusing on legal issues affecting the health care sector, including with the American Cancer Society, the Centers for Disease Control and Prevention, and the Health Care Bureau of the New York State Attorney General’s Office.

Cody participated in the Transactional Law Certificate Program at Emory University School of Law.

viewpoints

In this post, we summarize the reforms under Article 28 of the New York Public Health Law and changes to general hospital and nursing home staffing laws and discuss what these changes mean for both. 
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Effective October 1, 2022, Connecticut adopted the Interstate Medical Licensure Compact (IMLC) and the Psychology Interjurisdictional Compact (PSYPACT). As of the date of this post, Connecticut joins 38 other states who have adopted the IMLC and 34 other states that have adopted the PSYPACT. This blog post provides an overview of the IMLC and PSYPACT and analyzes its impact in Connecticut. 
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New York Office of Medicaid Inspector General Proposes Regulations on Self-Disclosure Program

September 26, 2022 | Blog | By Karen Lovitch, Jean D. Krebs, Cody Keetch

This post is the third and final installment of our blog series on the proposed regulations published by the New York State Office of Medicaid Inspector General (OMIG). The proposed regulations would repeal the current Part 521 - Provider Compliance Programs of Title 18 of the New York Codes, Rules and Regulations in its entirety and establish new requirements for providers to detect and prevent fraud, waste, and abuse in the Medicaid Program under a new Part 521: Fraud, Waste, and Abuse Prevention (Part 521). If enacted, the proposed rules would implement changes related to Medicaid provider compliance programs, Medicaid managed care organization (MMCO) fraud, waste, and abuse prevention, and Medicaid providers’ “obligation to report, return, and explain Medicaid overpayments through OMIG’s Self-Disclosure Program.”
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On July 26, 2022, we published a blog post detailing part one of three of proposed regulations published by the New York State Office of Medicaid Inspector General (OMIG). The proposed regulations would repeal the current Part 521 - Provider Compliance Programs of Title 18 of the New York Codes, Rules and Regulations (NYCRR) in its entirety and establish new requirements for providers to detect and prevent fraud, waste, and abuse in the Medicaid Program under a new Part 521: Fraud, Waste, and Abuse Prevention (Part 521). In this post, we summarize the second subpart of Part 521 covering proposed regulations that would require MMCOs to develop and implement programs to detect and prevent fraud, waste, and abuse in the Medicaid program.
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The New York State Office of Medicaid Inspector General (OMIG) published proposed regulations in the July 13, 2022 issue of the New York State Register.  The proposed regulations would repeal the current Part 521 - Provider Compliance Programs of Title 18 of the New York Codes, Rules and Regulations (NYCRR) in its entirety and establish new requirements for providers to detect and prevent fraud, waste and abuse in the Medicaid Program under a new Part 521: Fraud, Waste, and Abuse Prevention (Part 521). This blogpost highlights certain provisions from the first of Part 521’s three subparts, Subpart 521-1, that are relevant to New York Medicaid providers as they structure and update their compliance programs.
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White House Issues Telehealth Guidance on Substance Use Disorder Services

July 11, 2022 | Blog | By Lara Compton, Cody Keetch, Jean D. Krebs

On June 22, 2022, the White House Office of National Drug Control Policy (ONDCP) issued guidance advocating for Congress and federal agencies to make permanent certain telehealth access measures for people struggling with substance use disorders (SUD). The guidance, titled Telehealth and Substance Use Disorder Services in the Era of Covid-19: Review and Recommendations (Guidance), made four recommendations geared at increasing telehealth access, utilization, and equity among individuals who have experienced an SUD. This blogpost with provide an analysis of the four recommendations and their implications. 
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On May 11, 2022, New York Governor Kathy Hochul announced the creation of the Department of Financial Services’ Pharmacy Benefits Bureau. Governor Hochul noted that the Pharmacy Benefits Bureau is the first of its kind in the country. The Pharmacy Benefits Bureau will be tasked with implementing and overseeing new licensing and reporting requirements impacting Pharmacy Benefit Managers (PBMs) in New York. This blog post provides an analysis of the intended purpose of the Pharmacy Benefits Bureau and an overview of the new PBM guidance from the Department of Financial Services.
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Many of our nation’s 18 million veterans experience significant day-to-day challenges related to their time in the military. Through our pro bono legal counsel and the firm’s community services, including a holiday gift drive for veterans, we assist many nonprofit and advocacy organizations working to improve veterans’ lives.
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New York To Require Licensure of Pharmacy Benefit Managers

February 25, 2022 | Blog | By Cody Keetch, Jean D. Krebs

In an effort to counteract rising prescription drug costs and health insurance premiums, New York Governor Hochul signed S3762/A1396 (the Act) on December 31, 2021.  This legislation specifies the registration, licensure, and reporting requirements of pharmacy benefit managers (PBMs) operating in New York. The Superintendent of the Department of Financial Services (Superintendent) will oversee the implementation of this legislation and the ongoing registration and licensure of PBMs in New York. Notably, this legislation establishes a duty of accountability and transparency that PBMs owe in the performance of pharmacy benefit management services.
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Throughout 2021, former Governor Andrew Cuomo introduced sweeping legislation to initiate reform in nursing homes licensed under Article 28 of the New York Public Health Law. While many of these laws took effect this past year, some are set to take effect in the New Year and beyond. Below we provide a brief overview of three that are taking effect in January 2022.
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Cody Keetch

(he/him/his)

Associate

New York