Thomas W. Coons

Baker, Donelson, Bearman, Caldwell & Berkowitz PC

$ $$$

Light Street 100
Baltimore 21202 MD US

Thomas Coons represents a broad range of health care providers and practitioners, and focuses his practice on Medicare and Medicaid payment issues. Mr. Coons has a long history of counseling and litigating on behalf of hospital systems, academic medical centers, community hospitals, and other health care entities regarding Medicare payment, coverage, and compliance.

He is a national authority on a variety of issues, including Medicare’s provider-based rules, payments for graduate medical education, Medicare’s nursing and allied health rules, and Medicare’s teaching physician rules, as well as other issues that hospitals frequently face.

Mr. Coons is a former member of the board of directors of the American Health Lawyers Association (AHLA), is the past chair of that organization’s Medicare and Medicaid Payment Institute, and is a Fellow of the organization. He is a frequent speaker at conferences on Medicare payment and compliance issues.

Before entering private practice, Mr. Coons served as senior attorney in the Office of the General Counsel at the Department of Health and Human Services where he handled major controversies involving reimbursement and coverage under the Medicare program.

Prior to that, Mr. Coons was in private practice where he was engaged in civil and white collar criminal matters, including the representation of a major Watergate figure.


  • Georgetown University Law Center, J.D.
  • University of Tennessee, B.S.


  • Maryland
  • Virginia
  • Court of Appeals of Maryland
  • Court of Appeals of the District of Columbia
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. Supreme Court

Representative Matters:

  • In settlement with government, recovered more than $60 million for hospitals seeking additional Medicare DSH payments.
  • Represented a large private health system in successful litigation case against CMS involving whether off-campus location satisfied Medicare’s provider-based rules.
  • Guided hundreds of hospitals and their counsel through Medicare’s rules related to site neutrality payments, space sharing arrangements, co-mingling of personnel and other survey, certification, and provider-based issues.
  • Successfully obtained a reversal of CMS sanctions on behalf of a hospital following a survey of the hospital arising from a patient’s death.

Professional Memberships:

  • Member – American Bar Association
  • Member – American Health Lawyers Association (AHLA)
  • Member – District of Columbia Bar Association


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Light Street 100
Baltimore 21202 MD US
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