Dan has substantial experience in the health care, life sciences and pharmaceutical industries, advising clients on compliance with federal, state and international privacy and data security laws.

As a member of the firm’s global privacy and cybersecurity practice, Dan assists clients with matters involving the collection, use and disclosure of sensitive personal information. His practice focuses on compliance with federal, state and international laws regarding the use of personal data, health information and genetic data, as it pertains to HIPAA, the CCPA and numerous other state privacy laws. Dan also has experience advising clients on the processing of personal data under the EU General Data Protection Regulation (GDPR), particularly focusing on special categories of personal data, such as genetic and health data, and navigating international transfers of personal data under the GDPR.

Dan has experience working in-house, in private practice, and in the public sector. Prior to joining the firm, he served as in-house privacy counsel to a leading pharmaceutical company where he implemented and monitored a comprehensive data privacy compliance program. Before entering private practice he clerked for the Honorable Juan R. Torruella of the United States Court of Appeals for the First Circuit.

Relevant Experience

• Advises clients in the health care, pharmaceutical and life science industries on the regulation of clinical trials, including compliance with the Common Rule, as well as federal drug and medical device regulations.
• Advises clients on health and information technology, including the HITECH Act, FDA rules on software as a medical device, integration of apps in clinical decision making and direct-to-consumer communication of medical information, establishment and operation of research databases of genetic and medical information, and anonymization of protected health information.
• Advises clients on compliance with federal and state healthcare regulations, including the Stark law, the Anti-Kickback Statute, obtaining and maintaining federal tax-exempt status, nonprofit governance, the corporate practice of medicine prohibition, and rules governing the formation and operation of accountable care organizations.
• Advises clients on the licensure and operation of clinical laboratories, including compliance with CLIA and state regulatory frameworks.
• Advises large academic medical centers and other Covered Entities on compliance with the HIPAA Privacy Rule, including the use and disclosure of PHI for treatment, payment and healthcare operations.
• Advises clients on digital health, including telemedicine, electronic medical records and software as a medical device.

Bar Admissions

Education
PhD, Health Policy, University of Michigan School of Public Health, 2015JD, University of Michigan Law School, magna cum laude; Order of the Coif, 2013MA, Bioethics, Case Western Reserve University, 2006BA, with honors in Neuroscience, Oberlin College, 2005

• Temporal Stability of Receptiveness to Clinical Research on Alzheimer’s Disease, Alzheimer Disease and Associated Disorders
• Tax-Exempt Hospitals and Community Benefit: New Directions in Policy and Practice, Annual Review of Public Health
• Evaluating Hospitals’ Provision of Community Benefit: An Argument for an Outcome-Based Approach to Nonprofit Hospital Tax Exemption, American Journal of Public Health
• Making All the Children Above Average: Ethical and Regulatory Concerns for Pediatricians in Pediatric Enhancement Research, Clinical Pediatrics
• When Trade Law Meets Public Health Evidence: The World Trade Organization and Clove Cigarettes, Tobacco Control