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With a strong background in reimbursement and Medicaid supplemental payment programs, Baxter represents healthcare providers in regulatory, compliance, and litigation matters.

After starting his legal career in general civil litigation, Baxter began helping healthcare providers recover systematic underpayments from managed care organizations. His practice gradually shifted into assisting health systems and other providers with ways to cover the shortfall on the cost of treating Medicaid and uninsured patients. Working with hospitals throughout Texas, Louisiana, and other states, he assisted in the development and implementation of Medicaid supplemental payment programs, fostering collaborations between private healthcare systems and public entities to create new reimbursement opportunities through various government payment programs. This work required a deep dive into the full spectrum of healthcare regulatory and compliance law as Baxter resolved questions regarding the legal framework for various payment systems, physician contracting, medical staff operations, corporate entities, taxation, and insurance coverage, giving him a firm understanding of the regulatory structure governing the medical sphere.

Today, Baxter has a national practice with a Texas focus and divides his time between healthcare regulatory counsel, litigation, and assistance with reimbursement systems, including regulatory oversight of payments through audits, government inquiries, and administrative reviews. The opportunity to support health systems in their mission of patient care, and addressing challenges that allow providers to continue treating underserved communities, is the most rewarding part of his work.

Clients value Baxter’s positive personality and the partnerships he builds over time. Baxter aims to provide clients with the maximum results through the minimum of costs: his goal is always to solve clients’ problems in the most straightforward way possible so they can focus on their healthcare mission.




Thomson Reuters' Texas Super Lawyers, Rising Star, Healthcare, 2014-2019


  • J.D., University of Texas School of Law
  • B.A., University of Georgia
    • summa cum laude
    • Phi Beta Kappa


  • Texas
  • U.S. District Court, Western District of Texas
  • U.S. District Court, Eastern District of Texas
  • U.S. District Court, Northern District of Texas
  • U.S. District Court, Southern District of Texas
  • U.S. Court of Appeals, Fifth Circuit

Professional Memberships and Certifications

  • American Bar Association
  • American Health Law Association
  • Austin Bar Association
  • Represented institutional healthcare providers in regulatory, compliance, and transactional matters.
  • Advised hospitals and governmental entities in the development, implementation, and operation of governmental payment programs, largely related to reimbursement for the uncompensated costs of treating indigent patients and implementing quality improvements for the broader patient population.
  • Represented Texas hospitals related to their participation in state and local indigent care programs, the 1115 Medicaid Transformation Waiver, and associated Uncompensated Care (UC) and Delivery System Reform Incentive Payment (DSRIP) programs.
  • Advised numerous hospitals on Medicaid Disproportionate Share Hospital (DSH) funding qualification, compliance, ongoing reporting, audits, and appeals.
  • Assisted Texas hospital providers with the operation of the Uniform Hospital Rate Increase Program (UHRIP).
  • Advised Texas hospitals on the Comprehensive Hospital Increase Reimbursement Program (CHIRP) including its quality components; Baxter also counseled providers in various other states on the development and implementation of various other Medicaid managed care rate enhancement programs.
  • Provided counsel to health systems participating in various directed payment programs such as the Rural Access to Primary and Preventative Services Program (RAPPS) and the Texas Incentives for Physicians and Professional Services (TIPPS).
  • Assisted providers with regulatory oversight of their payments through audits, government inquiries, and administrative reviews in various tribunals around the country.
  • Worked with healthcare providers and governmental entities in several states to address concerns regarding the financing of Medicaid payments through intergovernmental transfers (IGTs) and provider fees, such as the local provider participation funds (LPPFs) in Texas.
  • Represented hospitals in arbitration and litigation for the recovery of systemic underpayments from managed care organizations.
  • Structured, developed, and assisted hospitals, working with Medicaid managed care organizations and state Medicaid agencies, to implement and operate programs to incentivize delivery system reforms and quality-driven improvement of health and outcomes.
  • Drafted contracts for hospitals and physician groups, with specific experience addressing the concerns implicated by the Stark Act and Anti-Kickback laws.
  • Addressed hospitals' substantive challenges presented by the investigation of purported false claims and other whistleblower actions.
  • Provided counsel through the due diligence process of hospital acquisition with respect to hospital reimbursement and audit risks.
  • Developed hospital policies and procedures, medical staff bylaws, and charity care policies.
  • Formed and maintained non-profit entities related to the provision of healthcare services.
  • Acted in the capacity of an outside general counsel for multiple rural hospitals.
  • Counseled physician groups regarding their corporate, transactional, and regulatory concerns including compensation, real estate transactions, and contract negotiations.
Outside the Office

As a father of five—from a teenager down to pre-school twins—Baxter devotes most of his free time to his family. On the weekends, you can usually find him attending (sometimes trying to coach) one of his children’s sporting events or facing his greatest challenge as an attorney: mediating disputes between his kids.

Baxter is a rabid fan of the Georgia Bulldogs and was fortunate to attend their January 10, 2022 college football national championship victory over the Alabama Crimson Tide in Indianapolis. He is a serious poker player who participates annually in the World Series of Poker, with a level of success necessitating his continued devotion to the practice of law. Living in central Texas, Baxter also enjoys barbecuing and learning more about the art of grilling.