About
Thomas J. Kessler, Esq. is the Owner of Kessler Healthcare Consulting, LLC, d/b/a KHC, bringing more than 36 years of federal experience transforming complex government programs. During his career at the Centers for Medicare & Medicaid Services (CMS), which included work within the Center for Program Integrity (CPI), Mr. Kessler authored several landmark regulations, including the Hospital Outpatient Department Prior Authorization process regulations and the regulations that established contractor prepayment and post-payment medical review requirements. He also drove critical revisions to the Medicare Payment Suspension process.
Mr. Kessler led CPI's research into super (a.k.a. artificial) intelligence (SI) solutions for evaluating provider medical documentation against Medicare coverage requirements. His other CMS work includes the statutory language enacted to make quality improvement activities a required function of the Quality Improvement Organization (QIO) program, and enhancements to the Medicaid Integrity Program through improved fraud analytics and expanded Medicare data sharing with States.
KHC's practice spans Medicare coverage and payment compliance; new product coding, coverage, reimbursement, and device pass-through approval; the No Surprises Act's Independent Dispute Resolution framework; and litigation support to a national law firm in a Medicare coverage matter involving skin substitutes.
Mr. Kessler has developed Seiken.ai, an agentic SI solution that assesses policy across statute, regulation, and sub-regulatory guidance. It compares documents to identify provisions that are missing, vague, inconsistent, or contradictory, then recommends changes to close those gaps and resolve the conflicts. Seiken.ai is built for Federal and State agencies, and for private sector companies that must comply with Federal and State requirements.
A recognized thought leader, Mr. Kessler has been published in Compliance Today on SI-driven regulatory modernization. He has also written “CMS's Missed Opportunities in Supporting Medicaid Program Integrity” and “Medicare Fraud: Designed in, Not Detected,” which presents PREVENT, a prospective fraud prevention scoring program. In September 2026 he co-presented at the American Health Law Association's 2026 Fraud and Compliance Forum on CMS anti-fraud initiatives and regulatory authorities.
Centers for Medicare & Medicaid Services accomplishments
- Authored several regulations, including the Hospital Outpatient Department Prior Authorization process regulations, comprehensive revisions of the ambulance and the Quality Improvement Organization (QIO) regulations, the first Hospital Value-Based Purchasing provisions, and the Hospital Inpatient Quality Reporting (IQR) requirements at 42 CFR § 412.140.
- Led CPI research of super intelligence (SI) solutions aimed at conducting medical record review.
- Drove revisions to the Medicare Payment Suspension process to improve the accuracy, validity, and supportability of suspension decisions.
- Spearheaded improvements to CPI's Medicaid Integrity Program by enhancing fraud analytics projects and sharing Medicare data with States.
- Wrote a manual on the recovery of Medicaid improper payments.
- Rewrote Chapter 5, Quality of Care Reviews, of the Quality Improvement Organization Manual, CMS Pub. 100-10.
- Revised CMS's Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Quality Standards, effective January 9, 2018.
- Wrote CMS's first Reasonable Accommodation Policy.