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, 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 and exclusion matters, Medicare and Medicaid reimbursement, and medical staffing. Julie also structures mergers and acquisitions in the health care space to comply with the vast legal and regulatory requirements applicable to business deals in the industry, and leads regulatory due diligence and diligence remediation efforts in connection with such transactions.
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 hospitals and health systems, mental health providers, long-term care providers, dialysis providers, and ambulatory surgery centers with referral source relationship compliance issues with 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. Julie also advises clients regarding corporate integrity agreements and other government-directed compliance initiatives.
Julie utilizes her prior in-house counsel experience to serve her clients’ business objectives while appropriately managing their legal risk in the heavily regulated health care environment. She also devotes time to a variety of pro bono projects.
- The Stark Law, physician self-referrals, and false claims
- General fraud and abuse counseling on anti-kickback statutes, false claims acts, and related federal and state statutes and regulations
- Medicare and Medicaid enrollment, participation and compliance
- Fee-splitting and patient brokering
- The Centers for Medicare and Medicaid Services’ (CMS) Self-Referral Disclosure Protocol (SRDP)
- The Office of Inspector General’s Self-Disclosure Protocol
- Medicaid disclosure and refund requirements
- HIPAA and HITECH, and related state privacy and security laws
- Substance use disorder and mental health privacy and confidentiality laws
- Minor privacy and confidentiality laws