2023 Compliance & Internal Audit Conference – Speaker: Larry Vernaglia

By | October 26, 2023

Meet the speakers for the HFMA MA-RI Chapter and the New England Healthcare Internal Auditors (NEHIA) 2.5 day in-person educational conference from November 29 to December 1, 2023Click here to register!


Larry Vernaglia
Foley & Lardner LLP


Tell us about your career journey

I went to grad school at Boston University to study health law, where I earned my law degree and masters in public health back in the early 1990s.  I’ve now been advising hospitals and health systems both regionally and nationally for close to 30 years.  I started out as a young attorney doing cost report appeals to the Provider Reimbursement Review Board (PRRB), which was work nobody else in my group wanted to do!  But it helped me really understand how hospital finances worked.  From there, I grew into other areas of revenue cycle, billing, coding, compliance, managed care contracting, fraud & abuse, etc.  Being able to “follow the money” in health care has made me a more effective advocate and problem-solver for my health care clients.  I’m now a partner in the Health Care Industry Team at Foley & Lardner (named U.S. News’ #1 Health Care Law Firm in the country for 2023, and three times before when I served as Chair of our Health Team) where I have worked for the past 17+ years with a great group of colleagues.  I am lucky to be here!

In my free time, I teach health care law at my alma mater, BU Law.  One of the new classes I have been developing of the past few semesters is Health Care Corporate Compliance, a new offering at the law school.  I’ve been very fortunate to have a number of the region and nation’s top compliance professionals generally volunteer their time to speak to my class and meet with my students – in fact, several of them will be at this conference this week!


What are the top three health care trends that you think legal and compliance professionals should keep on their radar and why?

  1. Challenges of delivering care with a dramatically-increased cost structure (particularly staffing) during a time of reimbursement contraction.  When providers are continually told to do “more with less” mistakes can be made (and choices will be too too).  Compliance professionals need to be cognizant of that pressure – they are certainly feeling it in their own compliance departments – but also aware of the impact on the other teams that they serve within their organization.
  2. Impact of “site neutrality” and other payment and delivery systems changes that are intended to push care into settings outside of the 4 walls of the hospital – telemedicine, hospital at home/SNF at home, home-based primary care, remote patient monitoring, etc.  These are rapidly-changing modalities with rapidly-changing regulations that have major reimbursement impacts.  Add to that bad habits created during the pandemic.  That is my recipe for a compliance risk!
  3. I wouldn’t be responding to your question fully if it didn’t note the future impact of artificial intelligence on health care and compliance. Your governing boards are discussing it at every meeting, and your C-Suite is considering many use cases.  For compliance professionals this means a few things.  First, you need a seat at the table before these programs roll out.  You bring a particular discipline and perspective that will make these implementations more effective, plus you will be better able to perform risk assessments early, and audit later.    But second, compliance professionals will want to be seeing the opportunities to use these new tools to make your compliance programs more effective.  At this year’s HCCA New England Regional Meeting (which it has been my honor to co-chair for more than 20 years) we had an engaging discussion of this topic.  We are still at the earliest stages of learning about this development, but compliance professionals should put this on their list for 2024 for sure!


What does the future of health care look like for you?

I’ve been invited to speak on a panel on the topic of “The Future of Reimbursement” next month, and I have to say it is a really hard title to do justice to!  I fully anticipate that the role of the hospital will change from being the locus of care to being the convenor or hub of care and probably the payor of care too.  These trends are not new, but at least the changes to where care is delivered accelerated materially during the pandemic.  This is not going to backslide; it is going to advance.  I still don’t know how we are going to meaningfully change the reimbursement system in the near term – certainly not with a divided national political environment.  But there are a number of innovations on the private side that, I think may germinate good ideas that some future, more united, Congress might take up.


If somebody googled you, what would they not find out about you?

They would not find out the role health care played in my family and just how close to home I live!  I live in a house my grandfather built to serve as his home medical in 1941.  He practiced medicine here, and my father did too after graduating from his residency.  So it is fair to say that I have been living in (quite literally!) the Boston medical community for my entire life!