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Adam D. Romney Partner adamromney@dwt.com Seattle T F 206.757.8238 206.757.7238 Los T F 213.633.6801 213.633.6899 Adam Romney is a partner at Davis Wright Tremaine and works from the firm s Seattle and Los offices. He supports health care providers on a variety of issues including: Complex health care regulatory, reimbursement, and compliance matters Telemedicine services and technology issues Clinically integrated networks, ACOs, bundled payments, and other innovative payment models Adam is a member of the Washington State Telemedicine Collaborative and has worked for the Office of the General Counsel at the U.S. Department of Health and Human Services and the Office of Medicare Hearing and Appeals. He also worked as a legislative staffer specializing in Medicare and Medicaid issues. Representative Experience Regulatory and reimbursement counsel for hospitals and health systems Counsels hospitals and health systems on complex regulatory, reimbursement, and compliance issues involving all aspects of Medicare participation and payment; Medicaid fee-for-service and waiver programs; state licensing; and other areas. Clinically integrated networks and accountable care organizations Counsels organizations that contract with health plans, self-insured plans, the Medicare Shared Savings Program, or state Medicaid programs to provide integrated services and accept risk-based payment. Other innovative payment systems Provides advice to providers and health plans regarding structures and models for innovative payment models, including bundled payments, gainsharing, pay for performance, and other alternative payment models. Hospital telemedicine departments Advises hospitals on regulatory and compliance matters associated with their telemedicine service lines such as telestroke, telehospitalist, tele-icu, primary care, case management, behavioral health, nutrition, and others. EDUCATION J.D., University of Colorado Law School, 2005 B.A., Political Science, French, University of Utah, 2001, cum laude RELATED PRACTICES Health Care Regulation & Compliance Antitrust Litigation Health Care Health Care Operations Health Information Health Information Privacy, Security & Breach Response Health Care Mergers & Acquisitions Health Care Reform Physician Groups Digital Health Law Telemedicine ADMITTED TO PRACTICE Washington, 2013 Colorado, 2006 California, 2009 Virtual professional staffing companies Assists organizations who offer professional telemedicine staffing for virtual physicians, nurse practitioners, psychologists, social workers, therapists, nutritionists, and others. Telemedicine technology vendors Works with companies who provide software and mobile solutions to allow other health care organizations to offer telemedicine services to patients in their markets. Telemedicine subject matter expert Works with accrediting organizations on the development of telemedicine accreditation programs and is a frequent speaker at local and national telemedicine events.

Additional Qualifications Associate, Caplan & Earnest LLC, Boulder, Colo. Office of Medicare Hearings and Appeals; Office of General Counsel U.S. Dept. of Health & Human Services Staff member for U.S. Congressman Jim Matheson (Utah 2nd) Professional & Community Activities American Bar Association American Health Lawyers Association Washington State Society of Healthcare Attorneys Health Care Financial Management Association Health Care Compliance Association Advisories 01.06.17 Bundles of Bundles : CMS Announces New Mandatory Bundled Payment Programs for Heart Attack, Heart Surgery, and Hip and Femur Fractures 06.20.16 Materiality Matters: SCOTUS Rules on FCA Implied Certification 03.31.16 M.D. Phone Home: New Legislation Expands Telemedicine in Washington 02.12.16 Tick, Tock, Shock: CMS Provides Welcome Guidance in the Final Regulation for 60- Day Rule 11.23.15 Medicare to Implement CJR: Mandatory Bundled Payment Program for Joint Replacement Surgeries 07.27.15 Recent Stark Developments: A Moving Target Where a Miss is as Good as a Mile 07.06.15 Changes to the Two-Midnight Rule on the Horizon 06.17.15 OIG Fraud Alert: Physicians in the Cross Hairs 06.16.15 Medicare Shared Savings Program: Final Rule 05.14.15 Compliance Guidelines for Governing Boards: Some Further Thoughts and Comments 04.30.15 Hold the Phone! Washington Adopts Telemedicine Parity Law 04.27.15 OIG Issues Board Guidance on Compliance Oversight 04.22.15 The SGR Fix: Congress Charts a New Course for Physician Payments and Gainsharing 09.25.14 Department of Justice Files First False Claims Act Lawsuit Against Physician-Owned Distributorship 07.10.14 The Dark Side of Health Care Reform: The First 60-Day Rule False Claims Act Case 06.25.14 Finishing at the Top of the Class: The Risks Faced by High Achievers on the Medicare Billings List

04.16.14 Emerging EHR Risks: When Documentation May Not Be Enough (or Too Much) 08.19.13 Trouble Ahead for One-Day Inpatient Stays: New Pre-Billing Challenges Loom 07.08.13 Legislature Amends Washington Anti-Rebate Statute 12.13.12 Washington Attorney General's Office Opinion Undermines Electronic Health Records Donation Programs 08.31.11 CMS Announces Bundled Payment Demonstration Project 07.06.11 The Financial Effects of ACO Risk Sharing 05.23.11 Are There Enough ACO $hared $avings to $hare? 05.23.11 CMS Innovation Center Advertises Opportunities for "ACO Pioneers" 05.09.11 How IRS Guidance Addresses ACO Participation for Exempt Hospitals and Other Health Care Organizations 05.02.11 If You Build It, Who Will Come? 04.18.11 Proposed Quality Measures for ACOs 04.15.11 ACOs: The Fraud & Abuse Waivers Finding a Path Through the Maze 04.11.11 What the Proposed ACO Regulations Say About Legal Structures and Governance 04.06.11 Antitrust Enforcement Agencies Issue Proposed Guidance on ACOs 04.05.11 The New ACO Regs: They're Here (Well, Sort of ) 07.13.10 HHS Issues Proposed Rules to Implement Privacy and Security Provisions of HITECH Act 04.01.10 Health Care Reform: The Regulatory, Compliance, and Fraud and Abuse Developments Providers Must Understand Now News 02.26.13 Davis Wright Tremaine LLP s Annual Health Care Regulatory and Compliance Update to Provide Essential Guidance on Current Legal Issues Presentations 05.24.16 Presenter, "Changes to Physician Reimbursement Under CMS's MACRA Proposed Rule," American Bar Association, Webinar 05.05.16 "What s All the FUSS About Telemedicine and WHAT Is the Risk?" 36th Annual Educational Conference, Southern California Association for Healthcare Risk Management, Rancho Mirage, Calif. 04.29.16 "Retail Medicine: Shop Until You Drop," 2016 WSSHA Spring Health Law Conference and Annual Meeting, Seattle

02.24.16 "2016 Health Care Regulatory and Compliance Update," Davis Wright Tremaine, Los 02.24.16 "Telemedicine is Exploding! Prepare for Compliance Challenges," Davis Wright Tremaine Compliance Seminar 02.18.16 "TeleMental Health Services: Overcoming Legal Hurdles," Strafford Webinar Jan. 6-7, 2016 "Preparing for the Comprehensive Care Joint Replacement Program," Davis Wright Tremaine, Los 12.08.15 "Preparing for CJR: The Risks and Opportunities in CMMI s New Mandatory Bundled Payment Program," 2015 Health Care Webinar Series: What You Need to Know, Davis Wright Tremaine, Webinar 09.28.15 "Fraud and Abuse Laws in Telemedicine," Fraud and Compliance Forum, American Health Lawyers Association 08.15.15 "EHR Issues: Documentation Risks, Record Requests and Telemedicine Parity" 05.07.15 "The Lawyer s Top Compliance Issues: Why Compliance Officers Are Calling Lawyers In 2015," 2015 Health Care Webinar Series: What You Need to Know, Davis Wright Tremaine, Webinar 02.24.15 "Navigating the Minefields of Direct-to-Consumer Health Care," 2015 Health Care Webinar Series: What You Need to Know, Davis Wright Tremaine, Webinar 02.19.15 "2015 Health Care Regulatory and Compliance Update," J.W. Marriott at LA Live, Los 12.17.14 "Navigating Reverse False Claims and Medicare Overpayments Amid Strict Enforcement of the 60-Day Rule," Strafford, Webinar 06.27.14 "Emerging ACO Compliance and Operational Issues," WSBA Health Law Seminar, Health Care: A Brave New World of Integrations and Affiliations, Seattle 06.13.14 "High-Speed Health Care Via Video Chat and Smart Phones: Compliance in the Age of Telehealth" 03.19.14 "High-Speed Health Care via Video Chat and Smart Phones: How Telemedicine Can Work For You" 02.12.14 "2014 Health Care Regulatory and Compliance Update," J.W. Marriott at LA Live, Los 11.15.13 "Emerging Payment Models An Overview of the Antitrust, Regulatory, Contracting and State Law Issues," California Society of Healthcare Attorneys Fall Seminar, Los 11.05.13 "Beyond Theory into Practice: Legal Issues Arising Out of the Operation and Expansion of ACOs," Fourth National Accountable Care Organization Congress, Los 08.19.13 "Reimbursement Appeals and State and Federal Audit Program," MultiCare Health System, Tacoma, Wash. 07.10.13 "Top 10 Reimbursement & Regulatory Issues for 2013," MultiCare Health System, Tacoma, Wash.

03.07.13 "2013 Health Care Regulatory and Compliance Update," J.W. Marriott at LA Live, Los 02.20.13 "Pay for Performance Legal Issues," The Eighth National Pay for Performance Summit, San Francisco 02.13.13 "A Primer on Medicare and Medicaid Reimbursement for Drugs and Devices," Organization of Regulatory and Clinical Associates, Bellevue, Wash. 11.02.12 "Medicare/Medicaid Audit Programs," Washington State Society of Healthcare Attorneys, Vancouver, B.C. 08.16.12 "2012 Legislative Update," Southern California Healthcare Financial Management Association Educational Program, Los 06.15.12 "Attack of the RACs (and other Government Audit Programs) Getting to Level III," 2012 HCCA Northwest Regional Conference, Seattle 02.07.12 "2012 Health Care Regulatory and Compliance Update." Davis Wright Tremaine, Los 11.03.11 "Current Medical Home Legal and Regulatory Issues," Medical Home Web Summit 2011 03.23.10 "2010 Health Care Regulatory and Compliance Update," Millennium Biltmore Hotel, Los Publications Feb. 2016 "Medicare and Telemedicine," Chicago Medicine Jan. 2016 "Medicare and Telemedicine: New Payments on the Horizon," Health esource, American Bar Association, Vol. 25 No. 3 Oct. 2015 "Skype Sessions: Emerging Legal Issues in Tele-Mental Health Services," The Health Lawyer, American Bar Association Health Law Section, Vol. 28, No. 1 2013 "Medicaid Provider Enrollment Update (Georgia, Ohio, South Carolina and Washington)," American Health Lawyers Association, Reimbursement Accreditation and Payment and Accreditation Certification and Enrollment Practice Groups 2012, 2013 "Summary of Fraud and Abuse Statutes and Regulations in Washington," American Health Lawyers Association December 2009 "Helping Nonprofits Make Their Mark," Davis Wright Tremaine Pro Bono Report 1996-2016 Davis Wright Tremaine LLP. ALL RIGHTS RESERVED. Attorney Advertising. Prior results do not guarantee a similar outcome.