Corporate Compliance

We help clients in the health care and global business sectors meet their corporate compliance needs.

Our team of experienced lawyers regularly represents clients in connection with their compliance obligations. While many of our clients—such as hospitals, practitioners, health systems, and payment entities—are in the health care industry, we also assist clients with global business interests.

For companies that supply management and administrative services to health care providers, we assist with everything from Medicare, Medicaid, and private insurance billing and payment issues to managed care contracting. We help clients maintain day-to-day operational compliance by keeping them up to date on Stark Law developments as well as changes in Medicare coverage and billing rules and other requirements. Clients—including hospitals and hospital systems that employ physicians as well as national provider chains, physician groups, and billing companies—frequently call on us to design compliance programs. We also represent a large group of unrelated hospitals that have formed a cooperative hospital service organization to allow shared efforts in many areas, including compliance programs for physicians.

Additionally, we assist clients that do business globally with compliance requirements arising from the Foreign Corrupt Practices Act, the UK Bribery Act, economic and trade sanctions administered by the Office of Foreign Assets Control, the United States Federal Sentencing Guidelines, and other sources. For these clients, we establish comprehensive compliance programs that satisfy the full range of governmental regulatory requirements, including anti-corruption policies and procedures; risk assessment; compliance training; and other elements required by the Department of Justice, the Securities and Exchange Commission, the Office of Foreign Assets Control, and other regulatory agencies. Our experience in the prosecution and defense of corporate criminal and regulatory matters gives us keen insight into how compliance systems should be created to minimize the potential for enforcement action and sanction imposition.

Our Clients

  • Hospitals
  • Nursing facilities
  • Ambulatory surgical centers
  • Freestanding diagnostic and therapeutic facilities
  • Practitioners and their practice entities
  • Health systems
  • Health care provider networks and other joint venture organizations
  • Payment entities
  • Companies that provide management and other administrative services to health care providers
  • Cooperative hospital service organizations
  • Companies with global business interests

Our Services

  • Representation of clients with corporate compliance obligations and needs
  • Assistance in designing compliance systems and programs
  • Representation of health care providers facing government audits and commercial payor audits
  • Counsel on FCPA and other compliance programs
  • Assistance with Medicare, Medicaid, and private insurance billing and payment issues, including administrative appeals
  • Advice on facility operation issues, including EMTALA, HIPAA, and advance directives
  • Counsel on compliance programs consistent with guidance from the HHS Office of Inspector General and other regulatory agencies
  • Counsel and defense related to fraud and abuse self-referral (Stark Law), fee splitting, and false claims issues
  • Assistance with licensure, accreditation, certification, and certificate of need issues
  • Assistance with managed care contracting
  • Advice on self-funded plans
  • Assistance with physician and ancillary provider credentialing, compensation, discipline, and related issues
  • Preparation of compliance training materials and seminar presentations concerning compliance developments
  • Assistance with designing corporate compliance systems