Christopher Nathan Kanagawa

Senior Counsel
Norton Rose Fulbright US LLP

St. Louis
United States
T:+1 314 505 8824
St. Louis
United States
T:+1 314 505 8824
Christopher Nathan Kanagawa

Christopher Nathan Kanagawa


Related services and key industries


Christopher is a Senior Counsel whose practice involves health care transactional and compliance matters.  His health care legal experience includes counseling hospitals, physician groups and other health care companies in business and regulatory matters, including fraud and abuse compliance.  Specific areas of focus include the formation, development and operation of clinically integrated networks (CINs) and accountable care organizations (ACOs) that participate in the Next Generation ACO Model (NextGen ACO Model) and the Medicare Shared Savings Program (MSSP).  Christopher also frequently handles mergers and acquisitions of health care enterprises and structuring business transactions among health care providers to address the changing business and regulatory environment in health care.  In addition, he advises health care providers on compliance issues, including Stark voluntary self-disclosures and health care regulatory compliance matters.  He handles operating issues affecting both for-profit and tax-exempt health care providers, including hospitals, physician groups and group purchasing organizations (GPOs).

Christopher previously served as Regional Counsel for Tenet Healthcare Corporation's Missouri hospitals. His duties as Regional Counsel involved advising hospitals with respect to compliance issues and structuring relationships with referral sources to comply with federal and state laws.

Professional experience

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JD, University of Tulsa College of Law, 1998
BA, Mathematics, Minor, Computer Science, University of Tulsa, 1991

  • Illinois State Bar
  • Missouri State Bar

Christopher regularly advises health care clients, including large health care systems, specialty physician groups and other health care providers and suppliers on various corporate, contracting and regulatory matters, including the following:

  • Advising clients regarding the formation, development and operation of ACOs in connection with shared savings programs implemented by CMS, including the MSSP and the NextGen ACO Model
  • Advising clients with ongoing operational issues and questions concerning ACO governance, arrangements among ACO and ACO network providers and third-party payor contracting
  • Advising clients on corporate, contracting and regulatory issues relating to electronic health records (EHR) agreements, IT agreements and e-health initiatives
  • Advising clients with respect to voluntary self-disclosures and CMS' Stark Law Self-Referral Disclosure Protocol (SRDP)
  • Advising health care clients with respect to acquisitions, mergers and joint venture arrangements
  • Advising hospitals and physician groups in structuring comprehensive professional and management service line agreements

Christopher has spoken to various associations and professional groups on various health care topics, including the following:

  • Transactions: Professional Services Agreements and Co-Management Agreements
  • The Affordable Care Act and Heath Care Reform
  • Privacy, Security and Health Information Technology
  • Developing and Implementing a HIPAA Project Plan
  • American Health Lawyers Association
  • Missouri Bar Association