Ross C. D'Emanuele

Ross C. D'Emanuele

Minneapolis P +1 (612) 343-2161 F +1 (612) 340-2868 Palo Alto P +1 (650) 565-2265 F +1 (650) 857-1288


Ross works in the healthcare provider, payor, and drug and medical device segments of the healthcare industry. His areas of expertise include healthcare fraud and abuse, Stark and anti-kickback laws, pharmaceutical and medical device licensing, co-development, and supply arrangements, HIPAA and other privacy and security laws, reimbursement rules and appeals, clinical trial agreements and regulation, FDA regulation, open payments and state "Sunshine Act" laws, accountable care organizations, value-based reimbursement, and telemedicine.

Education & Admissions

University of Virginia School of Law (J.D., 1996), Journal of Law and Politics

Syracuse University (B.A., Political Science, 1989), magna cum laude; Phi Beta Kappa


  • Minnesota
  • Only admitted in Minnesota
  • U.S. Supreme Court
  • U.S. District Court for the District of Minnesota


Representative Experience

  • Drafted and negotiated pharmaceutical and medical device co-development, co-marketing, and supply arrangements in the U.S. and internationally.
  • Successfully appealed various Medicare post-payment contractor (e.g., RAC, ZPIC) overpayment determinations.
  • Created a corporate and contracting structure for ExceleraRx Corp., a national network of health system-based specialty pharmacies.
  • Represented hospital system in defending Department of Justice allegations of billing fraud, resulting in no claims or action taken.
  • Represents providers in billing, anti-kickback, and Stark investigations and self-disclosure submissions.
  • Developed and updated corporate compliance programs for numerous health care providers and medical device manufacturers.
  • Represent wide variety of Covered Entities and Business Associates in OCR investigations arising from data breaches.
  • Represented multi-specialty physician group in development and operation of a joint-venture hospital.
  • Represented national chain pharmacy in renegotiation of drug wholesaler contract.
  • Represent wide variety of Covered Entities and Business Associates in developing privacy and security compliance programs.

News & Resources


CMS Issues Interim Final Rule to Enforce COVID-19 Reporting Requirements
False Claims Act Exposure for Beneficiaries of the Public Health and Social Services Emergency Relief Fund: Mitigating Risks of Ambiguous Terms & Conditions
CMS Expands Emergency Declaration Blanket Waivers for Health Care Providers
Privacy of Substance Use Disorder Records and The CARES Act: Steps Toward Harmonizing Part 2 Privacy Laws with HIPAA
HHS Releases Notices of $30 Billion to Healthcare Providers and Suppliers
Medicare Payment Rules Changed to Allow Broad Use of Remote Communications Technology
New CMS COVID-19 Blanket Waivers for Health Care Providers
Financial Relief for Medicare Participating Providers & Suppliers – A COVID-Prompted CMS Announcement
CARES Act Summary of Provisions that Support America’s Health Care System
Clinical Trials During the COVID-19 Pandemic
Medicare Telehealth Payment Expanded to Help Address the COVID-19 Public Health Emergency
First EKRA Enforcement Announced
Hospital Price Transparency Rule Finalized; Health Plan Transparency Rule Proposed
Sweeping Proposals Issued By CMS To Revise Stark Law Regulations
Sweeping Proposals Issued By OIG To Make Changes To The Anti-Kickback Statute Safe Harbors And Add An Exception To The Civil Monetary Penalty Law Governing Beneficiary Inducements
Reimbursement for Remote Patient Monitoring Services in 2019
Drug Rebates Threatened Under Proposed Anti-kickback Rule
Calls for Modernizing the Stark Law Continue; CMS Seeks Public Input on Stark Law Reforms
Significant Changes in Healthcare Laws Enacted Through the Bipartisan Budget Act of 2018: Stark, Civil and Criminal Penalties, Telehealth, ACOs and More
Stark Law Reform a Focus of Recent Regulatory and Legislative Initiatives; 2018 DHS Code List and CPI-U Updates
The Latest State Law Addressing the Opioid Crisis: New Regulations Prohibit New Jersey Prescribers Accepting Payments from Drug Manufacturers
VA Proposed Rule Would Expand Telemedicine and Override State Licensure Barriers
FDA Requests Painkiller Removed From the Market
CMS Proposes Affordable Care Act Exchange, Individual, and Small Group Insurance Market Changes

News & Press Mentions

Dorsey Partner Ross D'Emanuele Discusses Healthcare Price Transparency
Dorsey Partner Ross D'Emanuele Discusses Healthcare Price Transparency Rules
54 Dorsey Lawyers in Minneapolis Selected for Inclusion in The Best Lawyers in America 2019 and 2019 Lawyers of the Year
51 Dorsey Lawyers in Minneapolis Selected for Inclusion in The Best Lawyers in America 2018 and 2018 Lawyers of the Year
Dorsey Partner Ross D'Emanuele Discusses Healthcare Cybersecurity
48 Dorsey Lawyers in Minneapolis and Fargo Selected for Inclusion in The Best Lawyers in America 2017 and 2017 Lawyers of the Year
Dorsey Represents Underwriters in Tactile Medical IPO
Dorsey Partner Ross D'Emanuele Discusses How Healthcare Changes Impact Privacy
Dorsey Partner Ross D'Emanuele Discusses Health Care Data Security
Dorsey Partner Ross D’Emanuele Remarks on High Court's Medicaid Rates Decision
Dorsey Represents Tekmira Pharmaceuticals on OnCore Biopharma Merger Agreement
Dorsey Partner Ross D'Emanuele Comments on How Health Care Rulings will Affect Insurance Programs
Dorsey Consulted for Perspective on EHRs
How the New CMS Stark Rules Affect You

Industries & Practices

  • Cybersecurity, Privacy & Social Media
  • Dorsey Health Strategies
  • Healthcare
  • Healthcare Transactions & Regulations
  • Mergers & Acquisitions
  • Technology

Professional & Civic

Professional Achievements

  • Certified Information Privacy Professional (CIPP-US)
  • Member, American Health Law Association (AHLA)
  • Member, Board of Directors, Courage Kenny Foundation, 2015-2018


  • Listed as a "Rising Star" by Minnesota Super Lawyers, 2002, 2004, 2006
  • Listed in The Best Lawyers in America©, 2017-2021
  • Named a Best Lawyers® Lawyer of the Year, Healthcare Law, 2020
Ross C. D'Emanuele