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Cody Keetch

(he/him/his)

Associate

[email protected]

+1.212.692.6760

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Cody focuses his practice on health care matters. He dedicates a large portion of his practice to complex health care industry transactions, including mergers and acquisitions, joint ventures, and affiliations, for health care providers and investors across the United States. His recent health care industry merger and acquisition experience includes transactions for a Fortune 250 company, a nephrology practice group, and providers of radiology services.

In addition to his transactional practice, Cody provides counsel to non-profit organizations on matters related to formation and corporate governance and advises digital health companies on general business and corporate matters, including day-to-day corporate governance, corporate compliance, contracting, and HIPAA compliance. He also advises digital health companies on regulatory matters related to telehealth and the corporate practice of medicine.

Cody is actively involved in pro bono matters and regularly advises non-profit organizations on corporate governance matters and matters related to obtaining tax-exempt status.

Prior to joining Mintz, Cody was an associate at a Long Island, New York–based boutique law firm that serves the health care industry, where he handled transactional and corporate matters.

While attending law school, Cody had a number of internships and externships focusing on legal issues affecting the health care sector, including with the American Cancer Society, the Centers for Disease Control and Prevention, and the Health Care Bureau of the New York State Attorney General’s Office.

Cody participated in the Transactional Law Certificate Program at Emory University School of Law.

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New York Proposes Expansion of Disclosure Requirements for Material Health Care Transactions

February 14, 2025 | Blog | By Pamela Polevoy, Cody Keetch, Jean D. Mancheno

Governor Kathy Hochul released the proposed Fiscal Year 2026 New York State Executive Budget on January 21, 2025 (FY 26 Executive Budget). The FY 26 Executive Budget contains an amendment to Article 45-A of New York’s Public Health Law (hereinafter, the Disclosure of Material Transactions Law), which has been in effect since August 1, 2023. The law currently requires parties to a “material transaction” to provide 30 days pre-closing as well as post-closing notice to the New York State Department of Health (DOH). Since the law has taken effect, DOH has received notice of 9 material transactions, the details of which are listed on its website. If enacted, the amendment will change the reporting parties’ notice requirement, extend waiting periods, and increase DOH’s oversight of material health care transactions.

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New York City's Health Care Price Transparency Law Takes Effect

February 29, 2024 | Blog | By Jean D. Mancheno, Cody Keetch

In summer of 2023, New York City Mayor Eric Adams signed Intro. 844-A (Local Law 844-A) and amended the New York City Charter. Local Law 844-A directs Mayor Adams to establish an Office of Healthcare Accountability that will serve to increase health care price transparency in New York City. Though health care price transparency laws have been enacted at the state level across the nation, New York City has become the first municipality in the nation to implement a price transparency law. Indeed, New York City Councilmember Julie Menin, who sponsored Local Law 844-A, emphasized “the positive impact of price transparency measures in other states, and it’s time for New York City to curb excessive health care prices” alongside other states during the bill’s signing ceremony. The law took effect on February 18, 2024.

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New York State Prepares to Regulate Hospital Cybersecurity Programs

November 28, 2023 | Blog | By Sophia Temis, Cody Keetch, Jean D. Mancheno

On November 13, 2023, Governor Kathy Hochul announced plans to regulate cybersecurity for New York general hospitals regulated under Article 28 of the Public Health Law. As proposed, the regulations will provide an additional level of security for hospitals, which have been increasingly targeted for cybersecurity scams and breaches. The proposed regulations would be additive to those requirements of the federal Health Insurance Portability and Accountability Act (HIPAA), which already includes a variety of requirements meant to safeguard Protected Health Information (PHI). Accompanying the proposed regulations, a $500 million dollar fund has been appropriated under Governor Hochul’s FY24 budget to assist hospitals in complying with the proposed cybersecurity regulations. The funds will be made available through a Health Care Technology Capital program, which will be established by the New York State Department of Health (DOH).

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New York Joins Other States with Health Care Transaction Review Laws

May 11, 2023 | Blog | By Jean D. Mancheno, Cody Keetch, Pamela Polevoy

On May 3, 2023, New York joined Connecticut, Delaware, Massachusetts, Nevada, New Jersey, Oregon, Rhode Island, Washington, and California in enacting legislation that increases oversight over certain health care transactions. Governor Kathy Hochul signed the Fiscal Year 2024 New York State Executive Budget (FY 24 Executive Budget) into law which enacted the final version of Article 45-A of the New York Public Health Law (PHL) titled “Disclosure of Material Transactions.” The law takes effect on August 1, 2023.

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On April 25, 2023, the Senate Health, Education, Labor, and Pensions Committee Chairman Bernie Sanders and Ranking Member Bill Cassidy introduced a package of legislation aimed at lowering prescription drug prices. The package includes four bills, each proposing changes that would address a different piece of the pharmaceutical supply chain. This post focuses on the Pharmacy Benefit Manager Reform Act (PBM Reform Act), which proposes to increase oversight of entities providing pharmacy benefit manager (PBM) services to group health plans and health insurance issuers (i.e., employer-based health insurance coverage).

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Health Care Deal Structures: What Will the Deal Look Like?

February 15, 2023 | Blog | By Pamela Polevoy, Deborah Daccord, Cody Keetch

Deal structure is the foundation of a health care transaction. This post offers practical tips and hypothetical case studies for laying the groundwork for a successful health care transaction.

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In this post, we summarize the reforms under Article 28 of the New York Public Health Law and changes to general hospital and nursing home staffing laws and discuss what these changes mean for both. 

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Effective October 1, 2022, Connecticut adopted the Interstate Medical Licensure Compact (IMLC) and the Psychology Interjurisdictional Compact (PSYPACT). As of the date of this post, Connecticut joins 38 other states who have adopted the IMLC and 34 other states that have adopted the PSYPACT. This blog post provides an overview of the IMLC and PSYPACT and analyzes its impact in Connecticut. 

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Publications

*Reprinted with permission from the New York State Bar Association © 2023.

**Reprinted with permission from the New York State Bar Association © 2024.

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