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, 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 Work

  • 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


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
The Affordable Care Act in the Trump Administration
Medical Software and the 21st Century Cures Act
Stark Law Updates in 2017 Medicare Physician Fee Schedule Final Rule
CMS Overhauls Regulatory Requirements for Long-Term Care Facilities
CMS Proposes Significant Revisions to Stark Law
Vital Signs: Proposed Framework for Regulating Health IT Products Issued
Physician Payment Sunshine Reporting Dawns in 2013
Final HIPAA Rule Will Regulate Business Associates, Change HIPAA Breach Notification Obligations
Physician Payment Sunshine Act: Proposed Rule Leaves Big Questions Unanswered
Co-author of section of State by State Guide to Managed Care (Aspen Publishing)
Co-author of The Brave New World of Privacy for Health Plans and HMOs (published in HMOs and Health Plans)
Major Changes to HIPAA Security and Privacy Rules Enacted in Economic Stimulus Package, Health Lawyers News, Vol. 13, Number 6
RAC Audits: Are you Prepared?
The Economic Recovery Act: Now the Hard Work Begins
CMS Shifts Direction On Final Diagnostic Test Markup Rule
CMS Finalizes 2009 Physician Fee Schedule Rule
CMS Publishes New Stark Rules: Per Click Leases To Be Banned, “Stand in The Shoes” Modified

News & Press Mentions

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

Events & Speaking Engagements

Digital Health Conference
Dorsey 4D Symposium
Dorsey 4D Symposium: Devices, Diagnostics, Drug & Digital Health
The Economic Recovery Act: Now the Hard Work Begins
BIO West 2005
Emerging Growth Company Conference

Industries & Practices

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

Professional & Civic

Professional Achievements

  • Certified Information Privacy Professional (CIPP-US)
  • Member, American Health Lawyers 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©, 2017-2019
Ross C. D'Emanuele