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Kristin Bohl blends her experience as a healthcare attorney in private practice and government service with first-hand knowledge of care delivery as a registered nurse. Kristin advises hospitals, health systems and other provider organizations on compliance and regulatory issues and fraud and abuse matters, with a focus on the wide range of Medicare payment models. Before she entered private practice, Kristin was the Technical Advisor in the Division of Technical Payment Policy at the Centers for Medicare & Medicaid Services (CMS), where she concentrated on Stark Law matters. She was part of a team that developed the CMS Voluntary Self-Referral Disclosure Protocol and provided technical assistance in the creation of Stark Law waivers for Accountable Care Organization (ACO) models and other payment initiatives of the Center for Medicare and Medicaid Innovation within CMS.
In addition to Stark, Kristin advises healthcare companies on the Anti-Kickback Statute (AKS) and Medicare payment policy. She guides her clients on Medicare reimbursement changes under the Quality Payment Program (QPP) in both the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). Kristin counsels her clients on the strategies that enable their organizations to achieve their business goals while remaining in compliance with changing regulations and mitigating fraud liability.
After leaving CMS, Kristin worked in private practice with two national law firms. Before attending law school, she worked as a registered nurse at two major academic medical centers, Johns Hopkins Hospital in Baltimore and Memorial Sloan Kettering Hospital in New York.
Memberships
American Health Law Association (AHLA) — Hospitals and Health Systems Practice Group Leadership Development Program, Editorial Board; Mentoring Program; Public Interest Contributor
American Bar Association — Health Law Section
Maryland State Bar Association
Anne Arundel Bar Association
District of Columbia Bar Association
Memberships
American Health Law Association (AHLA) — Hospitals and Health Systems Practice Group Leadership Development Program, Editorial Board; Mentoring Program; Public Interest Contributor
Representation of United Musculoskeletal Partners in its acquisition of Pinnacle Surgical Orthopedics, a surgical center offering first-class treatment from orthopedic surgeons, physical therapists, and professional support staff. Terms of the transaction were not disclosed.
Representation of Prairie Capital’s portfolio company Family Allergy & Asthma, an allergy medical practice headquartered in Louisville, KY, in its Physician Practice Management transaction with Asthma and Allergy Associates of Florida, an allergy and asthma medical practice in Flordia. Terms of the transaction were not disclosed.
“Extensive Changes to the Physician Self-Referral Law and Anti-Kickback Statute Increase Innovation and Remove Administrative Burden,” (co-author) AHLA Weekly (November 2020)
“CMS Issues Physician Self-Referral Law Blanket Waivers Under Section 1135,” (co-author) Westlaw Journal (May 6, 2020)
“Proposed Changes to the Stark Law, Anti-Kickback Statute,” (co-author) Physicians Practice (October 2019)
“Extensive Changes to the Stark and Anti-Kickback Statute Regulations Are Designed to Remove Barriers to Innovation and Create Clarity,” (co-author) AHLA Weekly (October 2019)
“The Nation’s Largest Health Care Fraud Takedown in History,” (co-author) AHLA’s Fraud and Abuse Practice Group Bulletin (July 2018)
“Best Practices Handbook for Advising Client on Fraud and Abuse Issues,” (co-author) AHLA publication, 1st Edition (2018)
“The Evolving Quality Payment Program: Updates for Year Two,” (co-author) AHLA RAP Sheet (March 2018)
“CMS Reshapes the Playing Field for Innovative Payment Models,” (co-author) ABA’s Health eSource, Vol. 14 No. 6 (February 2018)
“The False Claims Act – What to Expect,” (co-author) AHLA Weekly (April 2017)
Presentations
“Be Prepared: How the Proposed Stark and Anti-Kickback Regulations Impact Hospitals,” Nashville Council of Health Care Attorneys (November 2019)
“Proposed Rules to Stark Law and Anti-Kickback Statute: What the Future Holds,” Developments and Trends in Health Care Law 2019, Cumberland School of Law and Health Law Section of the Alabama State Bar (September 2019)
“You Need to Worry About the Stupid Things,” Healthcare Financial Management Association, Maryland Chapter 2018 Spring Conference (March 2018)
“MACRA: Review of Proposed Changes to MIPS and Advanced APMs for 2018,” AHLA webinar for the Regulation, Accreditation, and Payment Practice Group (August 2017)
“The Quality Payment Program: What It Is and Why You Should Care,” ABA Health Law Section 2017 Physicians Legal Issues Conference (June 2017)
“The Stark Law: What Has Changed, What Remains the Same, and What Might Come Next,” ABA Health Law Section 2017 Physicians Legal Issues Conference (June 2017)
“Effective Peer Review as Your Best Defense to Fraud and Abuse,” Annual Meeting, American Health Law Association (2014)
“Practitioner’s Toolkit for Addressing ‘Technical Violations of the Stark Law,” AHLA Hospital and Health Systems Law Institute (2013)