Douglas A. Grimm

Partner and Health Care Practice Co-Leader

Douglas leads ArentFox Schiff’s nationally recognized Health Care practice, directing a team of more than 70 attorneys across the United States. His clients include health care providers, investors, and life sciences companies.

Douglas Grimm Portrait

Douglas maintains a national practice advising health care providers and investment firms on the full spectrum of regulatory, transactional, and litigation challenges. He frequently serves as outside general counsel to his clients, providing comprehensive guidance across their business and legal needs rather than handling only discrete matters. His experience in both the health care industry and his clients’ operations enables him to anticipate issues, identify opportunities, and deliver practical counsel. Clients rely on him not only for high-stakes transactions, regulatory advice, and government enforcement defense, but also for day-to-day legal guidance that keeps their organizations compliant, efficient, and well-positioned for growth.

Prior to practicing law, Douglas served as Chief Executive Officer of multiple acute and long-term care hospitals, giving him an operator’s perspective that few attorneys possess. He remains actively involved in health care administration as a Fellow of the American College of Healthcare Executives (FACHE). He has been ranked by The Legal 500 and The Best Lawyers in America and writes and speaks frequently on current issues affecting the health care industry, including AI, regulatory enforcement trends, and reimbursement.

He represents health systems, investment firms, physician groups, specialty providers, and medical device companies on regulatory, transactional, and litigation matters. His practice encompasses AI and information technology; physician-hospital alignment; financing initiatives, including venture capital and private equity investments; Medicare and third-party payor reimbursement counseling and appeals; and 340B statute compliance. He also counsels clients on compliance with the False Claims Act, Anti-Kickback Statute, and Stark Law. 

Representative Engagements

Douglas’s recent client engagements include:

  • Advised a multi-billion-dollar global retail company in establishing clinical laboratories across the United States.
  • Advised an acute care hospital chain regarding establishment of a national network of ambulatory surgery centers.
  • Represented hospitals, specialty providers, and physician groups in Medicare and Medicaid payment disputes involving RACs, UPICs, and ALJs.
  • Successfully defended a national specialty provider before the Department of Justice, FBI, the Centers for Medicare and Medicaid Services, and the Office of Inspector General in a False Claims Act, Anti-Kickback Statute, and Stark Law investigation resulting in no adverse findings against the provider.
  • Advised and defended 340B covered entities in connection with HRSA compliance audits and pharmaceutical company discount disputes.
  • Represented an investor-owned chain of nursing homes in its sale to a nonprofit community health system.
  • Advised multiple national telehealth providers on reimbursement and regulatory compliance matters.
  • Represented a chain of specialty surgical hospitals before the Department of Justice in a proceeding charging a hospital contractor with criminal fraud and money laundering, with no adverse consequences to the hospital. 
  • Advised a community health system on a $180 million acquisition of multiple ambulatory surgery centers.
  • Represented an integrated community health system before the Office for Civil Rights in a HIPAA breach proceeding involving the medical records of more than 100,000 patients, with no adverse consequences to the health system.
  • Advised a large academic medical center on the development and implementation of compliance programs across all departments.

Professional Activities

  • Member, Health Policy and Management Executive Council, Harvard School of Public Health
  • Fellow, American College of Healthcare Executives
  • Member, Advisory Board of the Center for Telehealth and e-Health Law
  • Member, American Health Lawyers Association
  • Member, Healthcare Financial Management Association
  • Member, Health Care Compliance Association

Publications, Presentations & Recognitions

Douglas’s recent articles and speaking engagements include:

Artificial Intelligence (AI)

340B

Compliance/Fraud and Abuse

Medicare Reimbursement

Digital Health & Telemedicine

  • “CMS Innovation Center Unveils ACCESS Model to Expand Technology-Supported Care for Chronic Disease,” Health Care Counsel, December 23, 2025
  • “Telehealth Staffing and Administrative Services Gain Favorable Advisory Opinion From OIG,” Health Care Counsel, June 27, 2025
  • Speaker, “Compliance for Telehealth Providers,” PCC Telehealth Summit of South Carolina, December 5, 2023
  • Speaker, “Understanding the Differences to Advance Policy: RPM/RTM is not Telehealth or Chronic Care Management,” CTeL Remote Patient Monitoring Summit, October 20, 2022
  • Co-Speaker, “Telehealth Reimbursement and Public Policy,” CTeL Digital Health Summit, June 9, 2021
  • Moderator, “The State of Telehealth Today: Practical Realities, Public Policy, and the Law,” ArentFox Schiff Webinar, April 28, 2021
  • Co-Speaker, “Remote Patient Monitoring: The New Rule, Scenarios, and Pitfalls to Avoid,” CTeL Digital Health Virtual Summit, December 3, 2020

Transactions/Corporate

HIPAA/Privacy

Research

In The News

Douglas is regularly quoted by industry publications and news outlets.

Life Beyond the Law

A dual citizen of the United States and United Kingdom, Douglas spends his time with his wife, Milena, and their family. A former member of numerous bands, Douglas is passionate about music of all kinds and has released six solo albums of guitar and electronic music.

Insights

Awards

Legal 500 US 2026 Recommended Lawyer