Dhara SatijaDharaSatija

Managing Director, Life Sciences & Healthcare Consulting Group

dharasatija@paulhastings.com

Boston+1 617 912 1616

Dhara Satija is a managing director in the Life Sciences and Healthcare Consulting Group and healthcare consulting leader, based in the firm's Boston office. Dhara has over 17 years of consulting experience serving healthcare and life sciences clients on topics ranging from strategy and operations to regulatory and corporate compliance, risk management, due diligence, corporate governance, payer contracting and operations, and investigation and litigation support.

In particular, Dhara has led projects related to development and implementation of compliance, risk and governance programs; design and delivery of compliance audits, investigations, and corrective action plans; support for provider self-disclosures/voluntary refunds; government-initiated audits; litigation support services; and Corporate Integrity Agreement (CIA) requirements.

Dhara provides advisory services and is not a licensed attorney.

EDUCATION de

University of Massachusetts, Amherst, B.B.A., 2008

HEALTHCARE

Assisted several healthcare organizations (e.g., hospitals, health systems, pharmacies, physician practices) with compliance program effectiveness/maturity assessments, compliance risk assessments, Enterprise Risk Assessment (ERA) and Enterprise Risk Management (ERM)
Led various engagements such as the development of annual compliance work plan and risk-based monitoring and auditing plans, including the design and implementation of compliance dashboards and analytics to identify opportunities and noncompliance.
Completed several compliance assessments and reviews for hospital inpatient/outpatient, professional, pharmacy, home health, hospice, inpatient and outpatient claims for psychiatry, clinical trial, wound care, hyperbaric oxygen therapy and others; performed medical record documentation review and related billing data analysis to identify areas of focus and potential noncompliance to relevant regulatory guidelines.
Led merger and acquisition (M&A) due diligence projects for physician practices and health systems, including assessment of compliance program, and coding, billing and documentation practices via sample testing, interviews and review of processes and controls to assess compliance with government payer guidelines; focus areas including, general hospital and professional billing, payor contracting and compliance, skilled nursing facility, home health, hospice and clinical research.
Led a number of internal investigations for large national healthcare providers that resulted in voluntary refunds/self-disclosure protocol to Medicare (Part A and B claims) and state Medicaid programs, and commercial health plans using statistical sampling.
Executed multiple Centers for Medicare and Medicaid Services (CMS) six-year look-back and voluntary refund retrospective reviews for large healthcare providers; applied statistical sampling methodology for sample selection, financial error calculation and related extrapolations to determine repayment/refund amounts; assessed compliance with Medicare conditions of payment and participation.
Completed required remediation activities to address identified gaps (e.g., training, process enhancements, controls testing, etc.).
Managed a number of clinical research/clinical trial billing compliance engagements at various healthcare systems in response to regulatory inquiries and as part of risk assessments or in collaboration with internal audit.
Participated in the development and support of management- and board-level compliance committees and related processes.

LIFE SCIENCES

Assisted various life science companies with the design and implementation compliance program and risk assessments, including the design and development of risk-based monitoring and auditing plans, in response to internal reviews and/or external investigation by the Department of Justice.
Participated in the global assessment of the anti-bribery and anti-corruption compliance program for a medical device company in connection with an ongoing investigation by the Department of Justice.
Developed and implemented policies and procedures, compliance controls, training and monitoring plans to meet commercial Pharma and Medical Device compliance standards and Corporate Integrity Agreement (CIA) requirements.
Developed and delivered compliance training for clinical and non-clinical members of various healthcare and life science organizations focused on compliance requirements in connection with CIA, compliance program, federal healthcare program requirements, Anti-Kickback Statute, False Claims Act, conflict of interest, fraud, waste and abuse, and the Stark Law.
Led compliance program effectiveness assessment for a large medical device company focusing on areas of Global Trade Compliance, Anti-Corruption Compliance, Data Privacy, Government Contracts, and Healthcare Compliance; activities included inventory and evaluation of the current state, identification of gaps and improvement opportunities, development of a corporate compliance report for board and senior leadership, and development of roadmap/compliance work plan to support implementation of recommended enhancements.
Coordinated commercial compliance assessment activities across six different countries for a large multinational life sciences company; developed an audit plan and detailed assessment programs including review of the current state processes, evaluation of policies and procedures, and design and effectiveness of controls across several commercial compliance areas including, interactions with healthcare professionals, advisory boards, market access, market research, brand spend management, grants, etc.
Conducted an assessment of the processes related to tracking and collection of healthcare providers and healthcare organizations spend, including direct remuneration, third-party payments, in-kind transfers of value, etc. for compliance with federal and state transparency reporting requirements.
Assisted a pharmaceutical company in developing and implementing compliance program enhancements in preparation for a corporate integrity agreement with HHS OIG.

"Check-Up and Diagnosis: The Ongoing Scrutiny of Private Equity Healthcare Investments", Westlaw Today, Co-Author
MAY 30, 2025
"Increasing Healthcare Scrutiny: California Updates Its Review Rules Regarding Healthcare Transactions," Healthcare Business Today
September 2023
Consolidating Healthcare: New York is the Latest State to Review Healthcare Transactions
May 2023
"MAC Hospice Audits Find High Error Rate; OIG Also Reports Problems," COSMOS Report on Medicare Compliance, Volume 31, Number 9
MAY 14, 2022
"Modernizing Compliance Programs: How High Are You Regulatory Risks?," COSMOS Report on Medicare Compliance, Volume 30, Number 20
MAY 24, 2021
"With More Demands on Compliance, It Needs to be ‘Agile,’ Experts Say," COSMOS Report on Medicare Compliance, Volume 30, Number 20
MAY 24, 2021

Chapter President
Massachusetts-Rhode Island Chapter of the Healthcare Financial Management Association (2025)
Member
Board of Directors, Massachusetts-Rhode Island Chapter of the Healthcare Financial Management Association

“The Future of Healthcare – Steering Through Change in a New Administration,” IPMI Healthcare Law & Compliance Institute, New Orleans, LA, Co-Speaker
FEBRUARY 24, 2025
“What Healthcare Providers Need to Know about the $2.8 Billion Settlement in the BCBS Antitrust Litigation,” HFMA MA-RI Chapter Compliance Webinar, Moderator
JANUARY 21, 2025

"Investigations Governance: Compliance Role and Expectations," HFMA-NEHIA Joint Compliance and Internal Audit Conference, Mystic, CT, Moderator
DECEMBER 5, 2024
“BCBS Antitrust Litigation Settlement: What Healthcare Providers Need to Know,” Paul Hastings Webinar, Moderator
OCTOBER 31, 2024
"Healthcare Compliance and Privacy Roundtable," HFMA MA-RI New to Healthcare Conference, Somerville, MA, Co-Speaker
OCTOBER 25, 2024
"Post-Acquisition Integration: The Real Focus and Challenge for Compliance," HFMA-NEHIA Joint Compliance and Internal Audit Conference, Mystic, CT, Co-Speaker
NOVEMBER 30, 2023
"Healthcare Compliance Roundtable," HFMA MA-RI New to Healthcare Conference, Somerville, MA, Co-Speaker
OCTOBER 13, 2023
“Compliance and Revenue Cycle Collaboration,” HFMA MA-RI Chapter Compliance Webinar, Moderator
JULY 27, 2023
“Hospital at Home Program In Brief” HFMA MA-RI Annual Virtual Revenue Cycle Conference, Moderator
MAY 11, 2023
“M&A Due Diligence Journey: The Real Focus and Challenge for Compliance,” AHLA Fraud and Compliance Forum, Baltimore, MD, Co-Speaker Sept. 27-28,
2023
"ESG in Healthcare," HFMA-NEHIA Joint Compliance and Internal Audit Conference, Mystic, CT, Moderator
DECEMBER 1, 2022
"Corporate Integrity Agreement Trends and Considerations for Compliance," HFMA-NEHIA Joint Compliance and Internal Audit Conference, Mystic, CT, Co-Speaker
NOVEMBER 30, 2022
"Healthcare Compliance and Privacy Roundtable," HFMA MA-RI New to Healthcare Conference, Somerville, MA, Co-Speaker
OCTOBER 28, 2022
“When Crossing the Line Is a Good Thing: The Role of Compliance and Collaboration in the Three Lines Model,” SCCE Compliance Auditing & Monitoring Virtual Conference, Co-Speaker
SEPTEMBER 20, 2022
“Overview of the No Surprise Act from the Provider Perspective,” HFMA MA-RI Chapter Compliance Webinar, Moderator
JULY 21, 2022
“Compliance Needs Project Management, Too!,” HCCA 26th Annual Compliance Institute, Phoenix, AZ, Co-Speaker
MARCH 29, 2022
“One Goal, Two Teams: How to Align to Help Manage Risk and Perform Audits, HCCA 26th Annual Compliance Institute, Phoenix, AZ, Co-Speaker
MARCH 29, 2022
“One goal, two teams – How to align to manage risk and perform audits,” HFMA-NEHIA Joint Compliance and Internal Audit Conference, Mystic, CT, Co-Speaker
DECEMBER 2, 2021
“Compliance Needs Project Management, Too!,” HCCA Boston Regional Healthcare Compliance Conference, Co-Speaker
SEPTEMBER 10, 2021
“Project Management in Compliance Programs,” HCCA Boston Regional Healthcare Compliance Conference, Boston, MA, Co-Speaker
SEPTEMBER 10, 2021
“At the Intersection of Operations and Compliance,” The Wall Street Risk & Compliance Journal
September 2021
“Relationships Are Critical to Compliance, Says AdventHealth Leader,” The Wall Street Risk & Compliance Journal
August 2021
“Gateway Health CCO Touts Collaborative Compliance,” The Wall Street Risk & Compliance Journal
July 2021
“With More Demands on Compliance, It Needs to be ‘Agile,’ Experts Say,” Report on Medicare Compliance, Health Care Compliance Association
May 2021
“Compliance Program Transformation: Opportunities, Strategies, and Creative Approaches,” HCCA 25th Annual Virtual Compliance Institute, Co-Speaker
APRIL 22, 2021
“Telehealth and Hot Topics in Compliance,” HFMA MA-RI Chapter Compliance Webinar, Moderator
APRIL 9, 2021
“How Innovative Staffing Can Improve Compliance,” The Wall Street Risk & Compliance Journal
February 2021
“Revenue Cycle Compliance Leading Practices,” HFMA MA-RI 24th Annual Virtual Revenue Cycle Conference, Co-Speaker
JANUARY 14, 2021
“Health Care Compliance Agenda: Relieve the Pressure,” The Wall Street Risk & Compliance Journal
November 2020
“COVID-19 | Latest Regulatory Updates and Implications,” Health Care Financial Management Association Massachusetts-Rhode Island Chapter Blog
May 2020
“Financial Relief for CARES Act, FEMA and other COVID-19 Programs and Reporting Considerations,” Health Care Financial Management Association Massachusetts-Rhode Island Chapter Blog
April 2020
“OIG Focus Areas,” Deloitte & Touche LLP and Foley & Larder LLP Compliance and Privacy Officer Roundtable, Co-speaker
November 2017
“All RACs Get OK to Audit Medical Necessity of Inpatient Psych; Keep Eye on Certifications,” Report on Medicare Compliance, Health Care Compliance Association
October 2017
“Retail Health & Wellness – Innovation, convergence, and healthier consumers,” Deloitte Publication
October 2016
“New Approaches to Addressing and Defending Medical Necessity Denials,” Health Care Financial Management Association Advisor Magazine
March 2016
“Anticipating Medical Necessity Denials, New Approaches to Defending Medical Necessity Denials,” Deloitte & Touche LLP Industry Webinar, Co-speaker
October 2015
“Clinical Trial Billing Compliance,” HFMA New Jersey Chapter Compliance Meeting, Speaker
May 2015
“Planning and Executing Enterprise-Wide Compliance Risk Assessments in Health Care Organizations,” Health Care Compliance Association Compliance Today Magazine
April 2015
“Proceeding with caution: Third-party service vendors and compliance,” Health Care Compliance Association Compliance Today Magazine
October 2014

Life Sciences & Healthcare

Life Sciences & Healthcare

Life Sciences & Healthcare Consulting Group

Life Sciences & Healthcare Consulting Group