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Anna  M.  Grizzle
Member
Nashville
P:(615) 742-7732
F:(615) 742-2741

Education
University of Alabama - J.D., 1998
Mississippi State University - B.A., 1994

Court Admissions
U.S. Court of Appeals Sixth Circuit, 2001
U.S. District Court, Eastern District of Tennessee, 2002
U.S. District Court, Middle District of Tennessee, 2000
Alabama and U.S. District Court, Northern and Middle Districts of Alabama, 1998

Bar Admissions
Tennessee, 2000
Alabama, 1998

Memberships
Health Care Compliance Association
American Health Lawyers Association

Honors & Distinctions
Listed in: Mid-South Super Lawyers "Rising Star"
Nashville Business Journal's "Forty Under 40," 2012
Order of the Coif
Developmental editor, Alabama Law Review, 1997-1998

Publications
"CMS Issues Hospital Outpatient and ASC Payment Final Rule for 2012," (co-authored with Krista Cooper and Philip Berg) HCCA Compliance Today (May 2012)
"Don't Let Regulatory Issues Derail a Healthcare Deal," (co-authored with Claire Miley) Executive Counsel (December 2011/January 2012)
"Are We Having Fun Yet? CMS Posts New 855 Enrollment Applications," (co-authored with Claire Miley and Seth Killingbeck) HCCA Compliance Today (November 2011)
"What is Still Protected? Supreme Court of Tennessee Decisions Impact Scope of Peer Review Privilege," (co-authored with Taylor Phillips) MedStaff News (May 2011)
"CMS Shifts From 'Pay and Chase' to Proactive Fraud Prevention," (co-authored with Krista Cooper) HCCA Compliance Today (May 2011)
"ZPICs: Medicare Audits Expand" (co-authored with Lynn Keaton-Cockrell), AAPC Coding Edge (September 2010)
"OIG Issues Updated Fraud Alert for Telemarketing by DME Suppliers," HCCA Compliance Today (June 2010)
"Medicaid Integrity Contractors: The Next Audit Initiative" (co-authored with Seth Killingbeck) HCCA Compliance Today (March 2010)
"ZPICs: Medicare and Medicaid Billing Practices Under the Microscope," Health Care Fraud Report (February 24, 2010)
"Zone Program Integrity Contractors (ZPICs) -- Coming to a Provider Near You," HCCA Compliance Today (July 2009)
"Preparing for a Medicare Audit by a Program Safeguard Contractor," HCCA Compliance Today (August 2008)



Anna Grizzle is a member of the firm’s Healthcare Industry Practice Group area where she focuses her practice exclusively on representing healthcare providers and companies in operational and compliance matters, investigations, and litigation.

Healthcare
  • Government enforcement and compliance: Anna provides advice on enforcement and compliance issues to healthcare clients in various industry sectors, including hospitals and health systems, ambulatory surgery centers, clinical laboratories, physician and physician practices, hospices, and durable medical equipment suppliers. Anna develops and implements compliance programs based on the elements considered necessary for a comprehensive compliance program by the Federal Sentencing Guidelines and Office of Inspector General's Compliance Program Guidance. She has extensive experience in the following areas:
    • Drafting and revising compliance program documents, including Codes of Conduct, policies and procedures, forms, and job descriptions;
    • Developing and presenting compliance training programs to Boards of Directors, officers, and clinical and administrative staff;
    • Developing and reviewing policies, procedures, and audit checklists for risk areas in anticipation of government investigations or inquiries; and
    • Conducting internal investigations, including coordinating the hiring of outside statistical, coding or billing experts, and providing advice on the reporting and repayment of overpayments, as appropriate.

Anna routinely represents clients in responding to and, if necessary, appealing the results of payor claims audits, including those performed by Recovery Audit Contractors (RACs), Program Safeguard Contractors (PSCs) n/k/a Zone Program Integrity Contractors (ZPICs) and Medicaid Integrity Contractors (MICs). On those occasions where the audit results are referred to law enforcement, Anna assists clients in resolving any issues with enforcement authorities.

  • Contracting, regulatory and operational matters: Anna provides counsel on healthcare operations and compliance matters, such as fraud and abuse, reimbursement, patient care, quality, and risk management issues. Anna has extensive experience advising clients on medical staff credentialing and peer review matters, including drafting medical staff bylaws, conducting medical staff investigations and hearings, and responding to records requests and subpoenas.

Compliance and Government Investigations
  • Healthcare Fraud and Abuse: Anna represents hospitals and health systems, ambulatory surgery centers, clinical laboratories, physician and physician practices, hospice, and durable medical equipment suppliers in connection with internal investigations and responding to governmental inquiries regarding potential regulatory, compliance and clinical issues. She has handled matters involving investigations conducted by the Office of Inspector General, United States Department of Justice, the Centers for Disease Control and Prevention, state Attorney Generals’ offices, and state regulatory agencies.

Healthcare Litigation

Anna also has significant experience in defending healthcare clients in medical malpractice actions and commercial litigation.

Presentations
Anna is a frequent speaker on healthcare compliance and regulatory matters. Her recent presentations include:
  • Co-Presenter, "Aggressive False Claims Actions, Medical Necessity Determinations and Individual Liability Charges," ACI's Advanced Forum on Healthcare Provider Disputes and Litigation (July 30, 2012)
  • Presenter, "When a Contractor Audit Turns into Criminal Prosecution: Learn How to Keep from Being Targeted," RAC University (May 24, 2012)
  • Co-Presenter, "Federal Sanctions and Individual Liability for Non-Compliant Organizations," 2012 Health Care Compliance Association (HCCA) Annual Compliance Institute (April 30, 2012) 
  • Presenter, "Defending Against Statistical Sampling and Extrapolation," 2012 Health Care Compliance Association (HCCA) Annual Compliance Institute (April 30, 2012) 
  • Presenter, "Claims Audits and Appeals," 2012 Compliance 360 Customer Conference (March 27, 2012) 
  • Co-Presenter, "Medicare Audit and Appeals: Practical Advice on Preparing for and Responding to RAC, ZPIC, and MAC Audits," 2012 American Health Lawyers Association (AHLA) Physicians and Physicians Organizations Institute (February 8-9, 2012) 
  • Co-Presenter, "Hot Topics in Healthcare Compliance," Middle Tennessee Networking Group for Compliance and Ethics Professionals (December 7, 2011) 
  • Co-Presenter, "Pay and Chase No More: The Government’s Proactive Initiatives to Combat Healthcare Fraud," Western District of Tennessee Health Care Fraud Task Force (November 9, 2011) 
  • "Annual Medicare Update," Nashville Medical Group Management Association (November 7, 2011) 
  • Co-Presenter, "Beyond the RACs: MACs and ZPICs Coming to a Practice Near You," Health Care Compliance Association (HCCA) Physician Practice Clinic Compliance Conference (October 16, 2011) 
  • Co-Presenter, "Ethical Considerations in a Healthcare Investigation - Protecting the Company's Interests," Nashville Council of Health Care Attorneys (September 27, 2011) 
  • "CMS' Plan for Proactive Fraud Prevention," Child Health Corporation of America (CHCA) Compliance Forum (September 23, 2011) 
  • Co-Presenter, "Pointers and Pitfalls in Gaining Physician Buy-in to a Compliance Program," Health Care Compliance Association (HCCA) South Central Regional Annual Conference (November 12, 2010) 
  • "Annual Medicare Update," Nashville Medical Group Management Association (November 9, 2010) 
  • "What To Do When The Government Comes Knocking," Dental Group Practice Association Annual Meeting (October 8, 2010) 
  • Co-Presenter, "MIC, ZPIC, MAC or RAC: The Auditors May Soon Attack," Tennessee Bar Association Annual Health Law Forum (October 7, 2010) 
  • "Tennessee Hospitals and Health Reform: 10 Themes in 20 Minutes," Tennessee Hospital Association Grassroots Meetings (September 2010) 
  • Co-Presenter, "Sampling for Medicare and Medicaid Audits," Strafford Publications Teleconference (July 30, 2009 and July 14, 2010) 
  • Co-Presenter, "Compliance Impact of the Patient Protection and Affordable Care Act," Tennessee Hospital Association (June 8, 2010) 
  • Co-Presenter, "RACs, MICs, PSCs/ZPICs & MFCUs," American Academy of Professional Coders (AAPC) 2010 National Conference (June 7, 2010) 
  • "Medicaid Integrity Contractor Audits -- Update," Child Health Corporation of America (CHCA) Health Information Management Forum (March 23, 2010) 
  • "The Changing Face of Compliance: Navigating the Post-Reform Compliance Environment," Keynote Address, Vanderbilt University Medical Center Compliance Week 2010 (May 6, 2010) 
  • "RAC Update (RACs, ZPICs and MICs): What Should Keep You Up at Night?" 2010 Brim Healthcare Trustee & Physician Conference (April 23, 2010)