Congress passed the Eliminating Kickbacks in Recovery Act (the Act) in 2018 to prevent “patient brokering” in treatment for substance abuse disorders. The Act imposes criminal penalties against anyone who
Continue Reading New Patient-Brokering Prohibitions Affect Treatment Facilities and Laboratories
Julie A. Sullivan
Julie A. Sullivan is a health care regulatory and compliance attorney concentrating her practice on state and federal health care fraud, waste and abuse guidance, reimbursement matters, as well as health privacy and security law. She represents health care providers and suppliers in complex regulatory and transactional matters, and routinely advises on issues such as corporate practice of medicine, fee splitting, licensure and certification issues including Medicare revocation, payment suspension and exclusion matters, and Medicare and Medicaid reimbursement disputes. Julie also structures mergers and acquisitions and value-based arrangements in the health care space to comply with the vast legal and regulatory requirements applicable to business deals in the health care industry, and leads regulatory due diligence and diligence remediation efforts in connection with such transactions in tandem with the corporate M&A teams at GT and other law firms.
Julie has deep experience in the intricate and involved processes associated with over-payment refund processes and self-disclosures. She routinely assists provider clients, including behavioral health providers, substance use disorder providers, hospitals and health systems, long-term care providers, dialysis providers, ambulatory surgery centers, and ancillary service providers with referral source relationship compliance issues and internal or government investigations into billing issues and the handling of such matters requiring refunds and/or self-disclosures to government-funded health care programs or regulatory agencies.