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Bobby R. Sanders

Bobby Sanders is an associate with Gjerset & Lorenz, LLP, where his practice centers on advising health care providers in a wide variety of Medicaid reimbursement, regulatory, and policy matters. His in-depth knowledge of the link between operations and payment methods, evolving federal policy, and state budget economics enables him to provide tailored legal advice and strategic guidance to the health care provider community. In his practice, Mr. Sanders has:

  • Advised hospitals in all phases of Medicaid reimbursement programs, including designing state-directed payment programs and Upper Payment Limit (UPL) programs, constructing frameworks for identifying nonfederal share sources, preparing complex revenue and cost models to inform financial planning, projecting the effect of operational changes on program qualification and funding determinations, and assessing post-payment audit risk and appeal opportunities.
  • Represented hospitals in all stages of Medicaid managed care state-directed payment programs, including collaborating with state Medicaid agencies and independent actuaries to develop average commercial rate demonstrations, designing program parameters related to eligible provider classes and uniform dollar and percentage increase arrangements, modeling the transitional impact of pass-through payment phasedowns, and evaluating cost-benefit strategies related to performance benchmarking.
  • Counseled hospitals on an assortment of topics related to the Medicaid Disproportionate Share Hospital (DSH) program, including the relationship between federally mandated minimum qualification criteria and state-specific qualification thresholds, federal allotment reductions under the Affordable Care Act, the interaction between Medicare cost reporting and the hospital-specific limit calculation, the allocative impact of IMD spending limits, exceptions to certain conditions of participation, and changes to the Medicaid shortfall calculation under the Consolidated Appropriations Act, 2021.
  • Prepared recommendations for hospitals and state Medicaid agencies related to UPL programs, including the impact of shifting from retrospective- to prospective-based demonstrations, distinctions among hospital ownership categories, the use of cost centers and all-payer data versus Medicare-specific data for computing cost-to-charge ratios, formulas governing cost, payment, and per-diem demonstrations, and innovative payment allocation systems.
  • Provided support to hospitals, state legislatures, and associations on issues pertaining to health care-related taxes, including the development of statistical demonstrations for attaining broad-based and uniform tax waivers, the application of federal standards to determine whether generally applicable taxes constitute health care-related taxes under the Social Security Act, financial modeling related to health care-related taxes imposed as a percentage of revenue and flat taxes, and compliance considerations related to federal safe harbor thresholds for indirect hold-harmless determinations.
  • Advised hospitals on numerous issues related to participation in Uncompensated Care (UC) programs authorized under 1115 Waivers, including collaborating with state Medicaid agencies to develop quantitative evidence for UC pool resizing events, implementing modifications to financial assistance and uninsured discount policies, quantifying the impact of interrelated revenue streams on payment caps, preparing advocacy materials and financial modeling for regulatory and policy proposals, and developing logic for interim and federal audit reporting.


  • University of Southern California Gould School of Law, J.D., 2016
    • President, Health Law Society
  • California Polytechnic State University, San Luis Obispo, B.S., 2013

Professional Affiliations

  • Member, Administrative Law Section of the Austin Bar Association
  • Member, Administrative Law and Health Law Sections of the State Bar of Texas