Health Law group partner Danielle Tangorre recently appeared on the American Health Law Association’s Speaking of Health Law podcast in an episode titled “Pathology Under the Microscope: Fraud and Abuse and What Attorneys Need to Know,” on March 17, 2026. In the episode, Danielle and other guests discussed the arrangements that pathology groups rely on—hospital professional service agreements, TC/PC structures, and transactions—and why the Department of Justice and Office of the Inspector General regulators are zeroing in on such arrangements.

“With a lot of pathology agreements, I think some of them are really old—hospitals and these pathology groups just have really old contracts that were not as defined,” said Danielle when describing the pain points that hospital and pathology group are facing with outdated agreements that lack nuance and specificity. “So, when hospitals and pathology groups are now renegotiating, it’s also trying to memorialize what is the expectation and really outlining what are the services, what’s included, and what should be paid and how that fair market value is determined.”

While discussing TC/PC structures/transactions, Danielle highlights how certain provisions, specifically the “commercial reasonable point” of the “safe harbor for personal services and management” under the Anti-Kickback Statute, are often overlooked because “everyone talks about fair market value and they think it kind of ends there” while failing to think of “that next prong of…what is the reason for it.”

To listen to the podcast, click here.