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Thomas A. Gustafson, PhD

Thomas A. Gustafson, Ph.D.

Senior Policy Advisor*

Thomas Gustafson, PhD, concentrates on Medicare reimbursement and related issues and on health policy generally.

Dr. Gustafson began his distinguished 30-year career at the United States Department of Health and Human Services (HHS) in 1976. He joined the HHS as an economist concentrating on retirement and welfare issues, and, in 1985, he moved to the Health Care Financing Administration, now the Centers for Medicare & Medicaid Services, where he held several executive posts responsible for Medicare and Medicaid legislation, strategic planning, research and demonstrations, and development and implementation of regulations.

In 2003, Dr. Gustafson was named Deputy Director of the Center for Medicare Management (CMM), which coordinated the fee-for-service portion of the Medicare program and set payment rates for more than a million providers. At CMM, Dr. Gustafson supervised coding and payment policies affecting approximately US$300 billion in Medicare spending on hospitals, physicians, nursing facilities, home health agencies, and other providers. He led the development and introduction of the hospital outpatient prospective payment system and oversaw major improvements in Medicare’s other payment policies and systems. He oversaw a sweeping reform, intended to improve accountability and efficiency, of Medicare’s administrative structure for paying claims. From 2006-2007, he served as Acting Director of the CMM.

Since joining the firm, Dr. Gustafson has advised health-care providers, device and pharmaceutical manufacturers, and trade associations on a wide array of issue areas, including: laboratory coverage, coding and payment; launch and reimbursement issues for pharmaceutical products; physician, outpatient hospital and end-stage renal disease reimbursement systems; and accountable care organizations.


US Presidential Rank Award (2000, 2004)



  • B.A., Williams College, 1969, magna cum laude
  • Ph.D., Economics, Yale University, 1982


  • *Not admitted to the practice of law

Government & Military Service

  • Deputy Director, Center for Medicare Management, Centers for Medicare & Medicaid Services
  • Director, Hospital & Ambulatory Policy Group, Centers for Medicare & Medicaid Services
  • Deputy Director, Office of Research and Demonstrations, Centers for Medicare & Medicaid Services
  • Deputy Director, Office of Legislation, Centers for Medicare & Medicaid Services


  • Member, American Economic Association
  • Member, American Health Lawyers Association
  • Member, National Academy for Social Insurance