Health Law is our business.


Andrea L. Impicciche

Hall, Render, Killian, Heath & Lyman, P.C.
500 N. Meridian Street
Suite 400
Indianapolis, IN 46204-1293

Phone: (317) 977-1578
Fax: (317) 633-4878
vCard: Download vCard


Andrea Impicciche focuses her practice on corporate transactional law and health care law. She counsels clients on a variety of health care related issues, including hospital/physician joint ventures, fraud and abuse, the Stark Law, regulatory and corporate compliance, physician contracting, hospital mergers and acquisitions, transactions with academic medical centers, physician-owned hospitals and other corporate counsel matters. Ms. Impicciche represents a broad array of health care providers, including hospitals, health systems and physician-owned hospitals. Ms. Impicciche has significant experience advising clients on the acquisition of medical practices and physician/hospital joint ventures and hospital/health system consolidation through mergers and acquisitions and/or restructuring. 

Ms. Impicciche’s physician alignment experience includes the representation of hospitals, health systems and physician practices in a broad range of physician-alignment transactions, including assisting clients with physician practice acquisitions, physician practice leasing arrangements, management and co-management arrangements and other alignment and integration strategies. In the course of this work, Ms. Impicciche assists clients with identifying numerous legal issues across a broad spectrum of practice areas and coordinating resolution of such issues. 

Ms. Impicciche has assisted hospitals and health system clients with the acquisition of other hospitals or health systems through membership substitution or otherwise, as well as assisting target hospitals through the process of affiliating with larger health systems. In the course of this work, Ms. Impicciche has assisted clients through the legal due diligence process, as well as negotiation of affiliation agreements and operational transition processes. A member of Physician Hospitals of America, which offers support and advocacy to the physician-owned hospital industry, Ms. Impicciche advises physician-owned hospitals on a broad array of matters specific to physician-owned hospitals and compliance with the Stark Law’s Whole Hospital Exception. In the course of this work, Ms. Impicciche assists clients with growth and consolidation strategies, compliance with the Stark Law and filing applications with CMS, requesting an exception to the expansion prohibition.

Ms. Impicciche received her undergraduate degree from DePauw University and graduated from Indiana University Robert H. McKinney School of Law in Indianapolis where she completed the Health Law Concentration. Ms. Impicciche has written several articles on the impact of health care reform on for-profit, physician-owned hospitals and other matters concerning her practice. In addition, Ms. Impicciche regularly speaks to audiences on health care matters she encounters in her practice and tweets about health care laws and news. 

Preparatory Education

  • DePauw University, B.S. - 2003

Legal Education

  • Indiana University Robert H. McKinney School of Law, J.D., Health Law Concentration - 2006

Admitted to Bar

  • Indiana - 2007
  • U.S. District Court, Northern and Southern Districts of Indiana - 2007


  • Physician Hospitals of America
  • American Health Lawyers Association
  • Young Professionals Council of the American Health Lawyers Association (2011 & 2012)
  • American Bar Association
  • Indiana Bar Association
  • Indianapolis Bar Association; Health Section Committee, Chair (2010)


  • Listed as a “Rising Star” in the "Top Healthcare Transaction Lawyers of 2014," published by the Ambulatory M&A Advisor


Failure to Be "Primarily Engaged" in Patient Care Puts Hospitals' Medicare Provider Agreements at Risk


Physician-Owned Hospital Performance May Provide Support for Lifting Expansion Moratorium


CMS Finalizes Proposed Rule Regarding Physician-Owned Hospital Advertising Requirements and Methodology Used to Calculate Physician Investment Levels


Texas Hospitals Seek Declaratory Judgment Against HHS to Halt Physician-Owned Hospital Expansion


House Budget Bill Targets New Off-Campus Hospital Departments

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Study: Physician-Owned Hospitals Score Similarly on Patient Population, Costs and Quality Metrics


OIG Issues Report Addressing Ownership Overlap Between Physician-Owned Hospitals and Physician-Owned Distributors


Several Modifications Underway for Physician-Owned Hospitals


Health Subcommittee Holds Hearing on Physician-Owned Hospital Expansion Moratorium


CMS Rolls Out Voluntary Physician-Owned Hospital Self-Referral Disclosure Protocol


CMS Issues Advisory Opinion Analyzing Baseline Physician Ownership Percentages


CMS Delays Reporting Requirement for Physician-Owned Hospitals


CMS Issues Amended Final Rule Impacting Physician-Owned Hospital Expansion Requests


CMS Approves First Physician-Owned Hospital Expansion Request


The IOM Recommends That the Current GME Reimbursement System Is Overhauled - Are You Prepared to Weather the Storm?


CMS Receives Comments to Proposed Rule Affecting Physician-Owned Hospital Expansion Exception


CMS Issues Proposed Rule Affecting Physician-Owned Hospital Expansion Requests


Urgent Reminder to Physician-Owned Hospitals: Action Required by March 1, 2014


Physician-Owned Hospitals: Addition of Unlicensed Observation Beds Does Not Increase the Hospital's Number of Licensed Beds


Annual Reporting Requirement for Physician-Owned Hospitals - DEADLINE EXTENDED TO MARCH 1, 2014


New Guidance for Annual Reporting Requirement for Physician-Owned Hospitals: First Annual Report Due December 1, 2013


The Joint Commission Seeks Comments on Primary Care Medical Home Certification Process for Hospitals


Federal Mandate for No-Cost Women's Contraceptive Services Continues to Receive Scrutiny


Much Ado About Nothing ... or Much Ado About Something? Obama Administration Rescinds Provider Conscience Rules




IRS Releases CPE Training Materials on "Good Governance" for Tax Exempt Organizations


SCHIP Reauthorization Signed Into Law Without Prohibition on Physician Ownership in Hospitals


IRS Releases Revised Instructions to Redesigned Form 990


2008 Form 990 Instructions Expected To Be Released Mid-August 2008


IRS Issues New Governance Guidelines To Reflect Reporting Required By New IRS Form 990


IRS Releases Draft Instructions for Revised Form 990


IRS Releases Final Form 990


Senate Finance Committee Holds Roundtable on Committee Minority Staff Discussion Draft Regarding Potential Reforms For Nonprofit Hospitals


IRS Releases Revised Draft Form 990 For Public Comment

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