Prior to coming to Foley Hoag, Tom served in a succession of high-level federal health care policy positions throughout the Administration of President George W. Bush. In 2008, he served as acting General Counsel of HHS; from 2005 – 2008, he served as health policy counselor to HHS Secretary Michael Leavitt. From 2001 – 2005, he was the chief legal officer of the Centers for Medicare & Medicaid Services.  While serving as acting General Counsel of HHS, Tom oversaw a staff of some 450 attorneys responsible for attesting to the legal sufficiency of every regulation and interpretive guidance published by the Department. In that role, he provided legal advice to Secretary Leavitt, along with the Administrator of CMS and Commissioner of the Food and Drug Administration. Tom played a key role in the implementation of every major health policy initiative enacted during his time at HHS, including the Medicare Prescription Drug Benefit (Medicare Part D) and the Medicare Advantage programs. He also chaired policy briefings on Medicare and Medicaid policy at HHS, the Office of Management and Budget, and the White House. 

Tom is a former commissioner of the Medicaid and CHIP Payment and Access Commission (MACPAC), an advisory body that provides policy advice to Congress and the states on the Medicaid and CHIP programs. He is one of the authors of the firm's Medicaid & the Law blog which highlights and explains current legal and policy issues in the Medicaid program. 
 
 
Prior to his service at HHS, Tom was regulatory counsel to the Massachusetts Hospital Association during the 1990s. Prior to that, he worked for members of the House of Representatives serving on the Committee on Appropriations and the Committee on Ways and Means. He is a member of the adjunct faculties of the George Washington University School of Law and the School of Public Health and Health Services, and Suffolk University School of Law. 
 
Tom also provides pro bono services on behalf of support organizations representing North Korean refugees living in the United States and Seoul, South Korea, and he has represented multiple individual North Korean refugees on immigration matters before the Department of Homeland Security, including before the United States Citizenship and Immigration Services.