Hayley Coley

Associate
Norton Rose Fulbright US LLP

Hayley Coley

Hayley Coley

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Biography

Hayley Coley (née White) focuses her practice on healthcare, with broad experience working on regulatory, transactional, compliance, reimbursement and litigation matters. She has experience assisting clients with a variety of healthcare regulatory questions and regularly assists with the necessary due diligence associated with transactions, compliance with state and federal fraud and abuse laws and compliance with the accreditation requirements of the Accreditation Council for Graduate Medical Education (ACGME).

Hayley joined Norton Rose Fulbright in 2019.


Professional experience

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JD, cum laude, Antonin Scalia Law School at George Mason University, 2019
BA, magna cum laude, Political Science, Religion minor, Dickinson College, 2015

During law school, Hayley was a member of the Civil Rights Law Journal and completed internships with the American Health Lawyers Association, the Department of Veterans Affairs, Office of General Counsel, Health Care Group, and summered at Norton Rose Fulbright in its healthcare group. During Hayley's time at Dickinson College, she was an intern at the US Department of Justice, Criminal Division, Office of International Affairs and she wrote a seminar paper on International Extraditions from the United States. 

  • District of Columbia Bar
  • Counsel clients on Medicare and Medicaid reimbursement, regulatory and compliance matters.
  • Advise health systems and other health and life science providers on the regulatory change of ownership implications of acquiring certain individual hospitals and other providers and assist with the necessary health regulatory due diligence associated with these transactions.
  • Assist academic medical centers in graduate medical education (GME) work involving institutional accreditation with the Accreditation Council for Graduate Medical Education (ACGME) and assist in these institutions’ oversight and supervision of their GME residency and fellowship programs.
  • Assist health plans with internal regulatory and compliance advice.
  • Assist hospitals in responding to civil investigative demands and accompanying compliance and litigation counsel.
  • Thompson Reuters 2023 Washington, DC Rising Star in Health Care
  • Co-author, "CMS clarifies Medicare Advantage organizations' use of AI and algorithms in coverage decisions," Norton Rose Fulbright Client Alert, February 2024
  • Co-author, "HHS and CMS to issue series of EMTALA guidance notices applicable to hospitals and patients," Norton Rose Fulbright Client Alert, February 2024
  • Author, "More Transparency, But Will It Lower Drug Prices?" American Bar Association, February 28, 2024
  • Co-author, “The No Surprises Act: New FAQs and IDR portal reopening,” Norton Rose Fulbright Client Alert, October 18, 2023
  • Co-author, “What you need to know: Medicare CY 2023 PFS and OPPS and ASC final rules,” Norton Rose Fulbright Client Alert, November 29, 2022
  • Co-author, “HHS OIG examines telehealth fraud in Medicare during the pandemic,” Norton Rose Fulbright Client Alert, September 15, 2022
  • Co-author, “CMS issues clarifying EMTALA memorandum in the wake of Dobbs,” Norton Rose Fulbright Client Alert, July 15, 2022
  • Co-author, “US Supreme Court decisions stay OSHA ETS, uphold CMS vaccine mandate,” Norton Rose Fulbright Client Alert, January 14, 2022
  • Co-author, "CMS Publishes Final Guidance for Hospital Co-location with Other Hospitals or Healthcare Facilities," Norton Rose Fulbright Health Law Pulse, November 16, 2021
  • Co-author, "CMS issues proposed rule repealing Medicare pending new "reasonable and necessary" definition and HHS issues proposed rule implementing provisions of the No Surprises Act," Norton Rose Fulbright Health Law Pulse, September 20, 2021
  • Co-author, "CMS issues 2022 OPPS proposed rule," Norton Rose Fulbright Health Law Pulse, July 22, 2021
  • Co-author, "ACA Survives '[T]hird Installment in [U.S. Supreme Court's] epic Affordable Care Act [T]rilogy,'" Norton Rose Fulbright Health Law Pulse, June 17, 2021
  • Co-author, "HHS Issues Final Rule Requiring Retrospective Review of Regulations," Norton Rose Fulbright Health Law Pulse, January 11, 2021
  • Co-author, "COVID-19 Update: Healthcare provisions (Including Medicare GME Revisions) in the Consolidated Appropriations Act, 2021," Norton Rose Fulbright Health Law Pulse, January 4, 2021
  • Author, "Hospital price transparency and litigation update," Norton Rose Fulbright Health Law Check-Up, December 2020
  • Co-author, "A deeper dive into the new Stark Law and AKS Final Rules," Norton Rose Fulbright Health Law Check-Up, December 2020
  • Co-author, "D.C. Circuit Upholds CMS Price Transparency Rule," Norton Rose Fulbright Health Law Pulse, December 29, 2020
  • Co-author, "Congress Passes Surprise Medical Bill Legislation," Norton Rose Fulbright Health Law Pulse, December 22, 2020
  • Co-author, "CMS releases special alert on monitoring hospital compliance with price transparency requirements," Norton Rose Fulbright Health Law Pulse, December 21, 2020
  • Co-author, "CMS releases proposed interoperability rule to improve prior authorizations and the electronic exchange of healthcare data," Norton Rose Fulbright Health Law Pulse, December 14, 2020
  • Co-author, "COVID-19 Update: CMS Releases Fourth COVID-19 Interim Final Rule with Comment Period," Norton Rose Fulbright Health Law Pulse, November 4, 2020
  • Co-author, "COVID-19 Update: HHS Renews COVID-19 Public Health Emergency Declaration," Norton Rose Fulbright Health Law Pulse, October 12, 2020
  • Co-author, "CMS Withdraws Proposed Medicaid Fiscal Accountability Rule," Norton Rose Fulbright Health Law Pulse, September 15, 2020
  • Co-author, "CMS Publishes Proposed Rule on Medicare Coverage for Innovative Technologies," Norton Rose Fulbright Health Law Pulse, September 4, 2020
  • Co-author, "CMS Issues FY 2021 IPPS and LTCH PPS Final Rule," Norton Rose Fulbright Health Law Pulse, September 4, 2020
  • Co-author, "COVID-19 Update: CMS Updates Conditions of Participation for Hospitals and CAHs to Require COVID-19 Reporting," Norton Rose Fulbright Health Law Pulse, August 28, 2020
  • Co-author, "HHS Issues Proposed Rule on Good Guidance Practices," Norton Rose Fulbright Health Law Pulse, August 25, 2020
  • Co-author, "CMS Publishes CY 2021 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule," Norton Rose Fulbright Health Law Pulse, August 7, 2020
  • Co-author, "CMS publishes FY 2021 Skilled Nursing Facility, Inpatient Psychiatric Hospital, and Hospice Medicare Payment final rules," Norton Rose Fulbright Health Law Pulse, August 4, 2020
  • Co-author, "President Trump unveils executive orders on lowering drug prices," Norton Rose Fulbright Health Law Pulse, July 30, 2020
  • Co-author, "Court of Appeals Upholds HHS Site-Neutral Payment Cuts to Off-Campus Provider Based Departments," Norton Rose Fulbright Health Law Pulse, July 20, 2020
  • Co-author, "COVID-19 Update: CMS releases guide encouraging patients to seek in-person healthcare," Norton Rose Fulbright Health Law Pulse, June 11, 2020
  • Co-author, "COVID-19 Update: HRSA holds a webinar on its COVID-19 Uninsured Program Portal," Norton Rose Fulbright Health Law Pulse, April 30, 2020
  • Co-author, "COVID-19 Update: Senate Committee Announces "Aggressive Oversight" of Small Business Paycheck Protection Program loans," Norton Rose Fulbright Health Law Pulse, April 23, 2020
  • Co-author, "COVID-19 Update: Behavioral healthcare regulatory changes and considerations during the COVID-19 outbreak," Norton Rose Fulbright Health Law Pulse, April 17, 2020
  • Co-author, "COVID-19 Update: CMS releases additional guidance to states on how the FFCRA and CARES Act provisions apply to Medicaid and CHIP," Norton Rose Fulbright Health Law Pulse, April 14, 2020
  • Co-author, "COVID-19 Update: CDC publishes criteria for when healthcare professionals with confirmed and suspected COVID-19 can return to work" Norton Rose Fulbright Health Law Pulse, March 25, 2020
  • Co-author, "COVID-19 Update: CMS issues guidance to all PACE Organizations to implement policies and procedures to prevent the spread of COVID-19," Norton Rose Fulbright Health Law Pulse, March 19, 2020
  • Co-author, "COVID-19 Update: Trump administration expands access to telehealth services for Medicare beneficiaries to combat COVID-19," Norton Rose Fulbright Health Law Pulse, March 17, 2020
  • Co-author, "COVID-19 Update: CMS Issues Wide Ranging Blanket Waivers to Assist Providers," Norton Rose Fulbright Health Law Pulse, March 31, 2020
  • Co-author, "U.S. Fifth Circuit Court of Appeals affirms the ACA's individual mandate penalty is unconstitutional and remands the case to the lower court to examine severability," Norton Rose Fulbright Health Law Pulse, December 19, 2019
  • Co-author, "CMS Publishes CY 2020 OPPS & ASC Price Transparency Requirements Final Rule and Transparency in Coverage Proposed Rule," Norton Rose Fulbright Health Law Pulse, November 20, 2019
  • Co-author, "CMS Proposes Major Changes in Medicaid Fiscal Accountability Rule," Norton Rose Fulbright Health Law Pulse, November 20, 2019
  • Co-author, "CMS Releases Final Rule on CY 2020 Physician Fee Schedule Updates and Implements Opioid Use Disorder Treatment Programs," Norton Rose Fulbright Health Law Pulse, November 12, 2019
  • Co-author, "CMS Issues Final Rule Implementing CY 2020 Home Health Prospective Payment System Updates, Other Policy Changes for Home Health Agencies, and Payment Policies for CY 2021 Home Health Infusion Therapy Services Benefit," Norton Rose Fulbright Health Law Pulse, November 4, 2019
  • Co-author, "Republican Study Committee Releases Affordable Care Act Replacement plan," Norton Rose Fulbright Health Law Pulse, October 25, 2019
  • Co-author, "CMS requests comments on the use of new technologies in the Medicare and Medicaid programs," Norton Rose Fulbright Health Law Pulse, October 24, 2019
  • Co-author, "CMS and OIG release sweeping proposals to modernize Stark Law and AKS regulations," Norton Rose Fulbright Health Law Pulse, October 16, 2019
  • Co-author, "US regulators to align key health care regulations with transformation to value-based care system; CMS and OIG propose major overhaul of Stark Law and AKS regulations," Norton Rose Fulbright Health Law Pulse, October 16, 2019
  • Co-author, "President Trump signs executive order to make changes to Medicare Advantage," Norton Rose Fulbright Health Law Pulse, October 8, 2019
  • "Addressing Demands for Medically Futile Measures: Objective and Subjective Policy Standards," AHLA Journal of Health & Life Sciences Law, February 2018
  • Speaker, "Healthcare in the crosshairs: What's next? Healthcare after the 2020 election and California v. Texas," Norton Rose Fulbright Webinar, November 12, 2020
  • American Health Lawyers Association
    • Networking Group Leader, Early Career Professionals Council (ECPC), 2020 - Present
    • Law Student Volunteer, Children's Hospital Affinity Group, 2018 - 2019
  • American Bar Association, Health Law Section
    • Young Lawyer Representative, Payment and Reimbursement Interest Group, July 2022 - Present
    • Young Lawyer Representative, ADR & Conflict Management in Healthcare Task Force, 2019 - July 2022
    • Law Student Volunteer, Healthcare Facility Operations Group, 2018 - 2019