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Drawing on more than a decade of experience litigating on behalf of the U.S. Department of Health and Human Services (HHS), Office of the General Counsel for the Centers for Medicare & Medicaid Services (CMS) Division, Andrew Tsui represents healthcare providers, suppliers, and laboratories in complex, government-facing investigations, appeals, and direct litigation. Andrew also provides regulatory and compliance counsel to healthcare and life sciences companies requiring an insider’s view to the federal framework. He regularly counsels Medicare Advantage plans, ACOs, and other downstream entities in the insurance markets, and he works closely with durable medical equipment, pharmaceutical/biopharmaceutical, and medical device manufacturers that must pivot from FDA approval to payment and reimbursement. 

Andrew’s recent work includes advising early-stage start-up companies in digital and AI-enhanced healthcare technologies. From formulating reimbursement and revenue models to refining coding and coverage approaches, Andrew’s deep experience with alternative payment models, new technology payment adjustments, and the future of value-based care meets founders where they are. An authoritative voice in the industry, Andrew is a frequent speaker at healthcare conferences around the country. 

Andrew obtained his law degree from the University of North Carolina School of Law and his Master’s of Public Health from the UNC Gillings School of Global Public Health. He graduated with high honors from Wesleyan University in Middletown, CT.


  • Medicare/APA litigation
  • Cost-Sharing Reduction (CSR) Payments, Risk Adjustment under the Affordable Care Act
  • Emergency physician payments
  • Accountable Care Organizations (ACOs), Bundled Payments for Care Improvement (BPCI/BPCI-Advanced) Initiatives, and other CMS CMMI Alternative Payment Models
  • Medicaid State Plan Amendments (SPAs) and Prior Authorizations
  • Inpatient and Outpatient Prospective Payment Systems (IPPS/OPPS) and Disproportionate Share Hospital (DSH) payment adjustments
  • Medicare bad debt reimbursement
  • Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) coding disputes
  • Home health and hospice payments and appeals
  • Medicare Part B Cost Plans
  • Breakthrough Devices
  • New Technology Add-on Payments (NTAP)
  • ESRD PPS Transitional Add-on Payment Adjustment for New and Innovative Equipment and Supplies (TPNIES)
  • COVID-19 Provider Relief Fund (PRF)



  • Litigation Attorney, U.S. Department of Health and Human Services, Office of the General Counsel, CMS Division, 2008-2019
  • Special Assistant U.S. Attorney, U.S. District Court for the District of Columbia
  • Policy Analyst, CMS Center for Medicare & Medicaid Innovation (CMMI), 2012-2013
  • Adjunct Professor of Health Law, NYU Wagner Graduate School of Public Service

Recognition & Leadership

  • Listed, The Legal 500 United States, Industry Focus > Healthcare: Service Providers, 2022-2023     
  • Team Member, a Law360 "Product Liability Practice Group of the Year," 2021
  • Member, UNC Board of Visitors, 2023-Present


  • J.D., University of North Carolina School of Law
  • M.P.H., University of North Carolina, Gillings School of Global Public Health
  • B.A., with high honors, Wesleyan University
  • District of Columbia
  • New York
  • U.S. District Court for the District of Columbia
  • Supreme Court of the United States