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 Board 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.

Representative matters include:

• Representation of a multi-specialty physician practice in a PSC audit appeal, reducing the $1.6 million overpayment demand to $0;
• Successful defense of a specialty practice clinic investigated by a U.S. Attorney’s Office of possible violations of the False Claims Act resulting in declination to pursue action and reduction of overpayment demand in the administrative appeals process from $1.8 million to $0; and
• Dismissal at reconsideration of the use of statistical sampling and extrapolation in a PSC audit involving a long-term care provider


• 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.

• Healthcare Fraud and Abuse: Anna represents hospital 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.

• Co-Presenter, "Pointers and Pitfalls in Gaining Physician Buy-in to a Compliance Program," Health Care Compliance Association (HCCA) South Central Regional Annual Conference (upcoming 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)
• Co-Presenter, "Disruptive Physician Behavior: Career Threatening or a Chance for Collegial Intervention?," 2010 American Health Lawyers Association (AHLA) Physicians and Physicians Organizations Institute (February 24-25, 2010)
• "ZPIC Audits: Steps You Can Take to Minimize the Risk," Compliance 360 (February 18, 2010)
• "Beyond the RACs: MACs, MICs, and ZPICs Threaten Your Revenue — Learn How to Prepare for Other Government Contractors," RACMonitor.com (December 16, 2009 and January 13, 2010)
• "Medicaid Integrity Contractors," Child Health Corporation of America (CHCA) Corporate Compliance Forum (September 14, 2009)
• "RAC, MIC, PSC/ZPIC and MFCU Claims Audits - What Should Keep you up at Night," Compliance 360 Webinar (March 31, 2009)
• Co-Presenter, "Benchmarking Tools for Compliance Programs," Health Care Compliance Association (HCCA) South Central Regional Annual Conference (November 7, 2008)
• Co-Presenter, "Payback Is Hell: Medicare Audits and Appeals," Tennessee Bar Association 20th Annual Health Law Forum (October 16, 2008)