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.
As a certified professional coder (CPC), Julie assists clients with billing and coding guidance, billing audit support/defense and appeals. Julie also works closely with GT’s white-collar teams on health care fraud investigations involving billing and coding matters (as well as other fraud and abuse issues). Julie also advises clients regarding corporate integrity agreements, CMS compliance plans, 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 leverages her advanced degree in public health to assist clients in planning and execution of disaster preparedness plans for public health crises. Julie also serves as a pro-bono coordinator for the firm and devotes significant time to a variety of pro bono projects.
- The Stark Law and related physician self-referrals laws and financial interest disclosure obligations
- General fraud and abuse counseling on anti-kickback statutes, beneficiary inducement prohibitions, false claims acts, and related federal and state statutes and regulations
- Medicare and Medicaid enrollment, changes of ownership, 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
- Medical billing and coding requirements