R. Barrett Richards is a partner at Farrow-Gillespie Heath Wilmoth LLP and he brings a wealth of experience in health care transactions, operations, and compliance. Barrett is Board Certified in Tax Law, Health Law, and Estate Planning & Probate Law, Texas Board of Legal Specialization. He is an author and speaker regarding health law and tax law topics and had been recognized by Best Lawyers in America – Health Care (2016 – 2020); Martindale Hubble AV Preeminent Peer Review Rating; and Who’s Who in Health Care, Dallas Business Journal, October 2014.

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Practice Areas

Health Law   

• Broad and deep experience in complex taxable and tax-exempt health care start-ups, mergers, acquisitions, dispositions, joint ventures, and operations including hospital systems, individual hospitals, ambulatory surgery centers, specialty hospitals, home health providers, nursing homes, Texas non-profit health (5.01(a)) organizations, holding companies, foundations, and related organizations.

• Private placement syndication of interests in hospitals, ambulatory surgery centers, private equity funds, special purpose entities, and similar ventures.  Representation of borrowers in taxable and tax-exempt financings.

• Experience handling commercial real estate transactions in conjunction with mergers and acquisitions including purchases, sales, REIT transactions, ground leases, master leases, and subleases.

• Counseling regarding laws and regulations affecting health care providers and employers including the effects of, and compliance with, federal and state anti-kickback laws, the Stark self-referral limitations, HIPAA and the Texas Medical Records Privacy Act, the False Claims Act, and other federal and state health care laws.

​Taxation & Business:   

• Advising individuals, businesses, and business owners regarding federal and state tax issues and operational strategies including income taxation, ad valorem taxes, sales and use taxes, excise taxes, and U. S. taxation of offshore entities.

• Handling organization, tax structuring, mergers, sales, and acquisitions of middle market business organizations including corporations, partnerships, limited liability companies, and combinations of entities.

• Representation of tax-exempt entities regarding tax and operational issues, tax exemptions, organizational structures, and permissible control mechanisms.

• Providing advice to boards of for-profit, non-profit, and governmental organizations concerning fiduciary and ethical obligations and best practices.

​Estates & Trusts:  

• Estate planning, trust development and administration, asset protection, generation-skipping transfers, and related representation for high net worth and high-income individuals, public charities, and private foundations.

• Life insurance planning and structuring; creation and representation of life insurance trusts and trustees.

• Development and implementation of coordinated charitable giving strategies, charitable remainder trusts, and private foundations.

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Professional Certifications & Associations

• Board Certified, Health Law, Tax Law, and Estate Planning & Probate Law, Texas Board of Legal Specialization

• Health Care MBA and PhD Advisory Board, Robbins Healthcare Institute, Baylor University, Waco, Texas, 2004 – present

• State of Texas Business Organizations Code Committee, 2013 – present

• Dallas Bar Association; Health Law (Chair, 2004), Tax Law, and Probate, Trust, & Estates Sections

• State Bar of Texas Committee on Third Party Opinions and Opinion Letter Accord (1992)

• State Bar of Texas; Health Law, Tax Law, and Real Estate, Probate, & Trust Law Sections

• American Bar Association; Health Law, Tax Law, Real Property, Trust & Estate Law, and Business Law Sections

• American Health Lawyers Association

• Healthcare Financial Management Association

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Education

       Baylor University - B.A., 1972

       Baylor University School of Law - J.D., 1973 - Baylor Law Review, 1971 – 1973

       Southern Methodist University School of Law - LL.M., Taxation, 1974

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Bar Admissions

• State Bar of Texas

• United States Tax Court

• U.S. District Court, Northern District of Texas

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Practice Experience​

      Farrow-Gillespie Heath Wilmoth LLP - Partner, 2025 to present

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      R. Barrett Richards PC, Dallas, Texas - Principal, 2020 to 2025

     

      Frost Brown Todd LLC, Dallas, Texas - Member, 2016 – 2020

      

      Bell Nunnally & Martin LLP, Dallas, Texas - Partner, 2012 – 2016

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Representative Publications and Presentations:​

“What Were They Thinking?  The Current State of Healthcare Fraud and Abuse Enforcement,” Healthcare Financial Management Association, Texas Annual Meeting; Austin, Texas, April 23, 2018

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“Risk Adjustment Coding and Clinical Documentation Improvement Programs for Medicare Advantage and MACRA Quality and Cost Performance Measures,” Joint Presentation with Ellis Knight, MD, the Coker Group; American Health Lawyers Association Institute on Medicare and Medicaid Payment Issues, Baltimore, Maryland, March 23, 2018

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“Fraud and Abuse is Alive and Well, Is It Coming to a Hospital Near You? – Dealing with Anti-Kickback, Stark, and Related Risks under MACRA, MIPS, and APMs,” Texas Association for Healthcare Financial Administration, Parkland Hospital, Dallas, Texas, July 28, 2017

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“The Drive to Consolidate Healthcare Providers; Understanding It, Coping with It, and Benefiting from It,” Frost Brown Todd Healthcare Forum, June 27, 2017

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“Thriving Under the New MIPS and APM Payment Systems Implemented by MACRA,” Healthcare Financial Management Association, South Texas Annual Institute, San Antonio, Texas, May 22, 2017

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“Taxation of Healthcare Mergers and Acquisitions,” Summer Healthcare Institute, American University School of Law, Washington, DC, June 25, 2016

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“The Near-Term Future of Health Care Mergers and Acquisitions,” Panel Presentation to the Association for Corporate Growth, Mid-South Capital Connection; Nashville, Tennessee, June 23, 2016

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Experience Overview

• Represented a national tax-exempt health system in the $40 million acquisition of home health and hospice agencies across the Southwest United States

• Represented for-profit, physician owned hospital in the process of withdrawal from a failing multi-hospital group

• Represented the physician venturers in a joint venture with a major non-profit hospital group to establish one of the last legally authorized physician-owned hospitals to continue to participate in federal payment programs under the ACA revised Stark law and regulations

• Represented the participants in the formation and obtaining tax-exemption of a hospital corporation and the subsequent acquisition by that entity of a free-standing hospital in an underserved urban area from a major, national, for-profit hospital chain

• Represented the lead hospital in the establishment of a free-standing home health agency owned, funded, and operated by three unrelated tax-exempt hospital entities

• Represented a multi-hospital group in the establishment of a self-insurance trust and pool for tort and general liability claims

• Represented a hospital participant in a multi-hospital advance refunding and refinancing under a $74,800,000 tax-exempt pooled bond program

• Represented a tax-exempt hospital organization in an affiliation arrangement with a major, regional medical center school of pharmacy

• Represented a dental management group in the establishment, organization, and operation of a multi-state dental management company

• Represented a regional Southwest hospital in the successful defense against expulsion from Medicare for alleged EMTALA violations