With over 20 years of experience, Anna Grizzle helps healthcare clients address enforcement and compliance issues and respond to legal and regulatory violations. She regularly advises healthcare companies and providers on reimbursement, fraud and abuse, operations and transaction matters. With significant experience in defending against statistical sampling and extrapolation and claims denials in Medicare and Medicaid claims audits, Anna also has saved healthcare companies tens of millions of dollars in potential overpayment demands.
Representing national hospitals, health systems, hospices, home health agencies, ambulatory surgery centers, behavioral and substance abuse providers, and physician practices, Anna’s practice involves:
Anna’s leadership abilities and visionary judgment make her a go-to advisor in the healthcare sector. In addition, Anna is certified in healthcare compliance (CHC)®. Having served as a member of the firm’s Executive Committee, Anna is looked to as a trusted leader among her peers.
Health Care Compliance Association
American Health Law Association (AHLA)
American Bar Association — Women in White Collar Subcommittee
Successful defense of a national hospice provider against Centers for Medicare & Medicaid Services’ (CMS) determination that the provider failed to meet Hospice Quality Reporting Program (HQRP) requirements for Calendar Year 2021. This alleged non-compliance would have resulted in a 2% reduction in the provider’s annual payment update for Fiscal Year (FY) 2023. Through the HQRP reconsideration process, Bass Berry & Sims successfully demonstrated that CMS’ determination of non-compliance was erroneous because CMS’ inadvertent termination of the provider caused a systemic problem with the provider’s submission of requisite HQRP, Hospice Item Set data. At reconsideration, CMS reversed its initial determination of non-compliance and granted the provider the full FY 2023 annual payment update.
Successful defense of two agencies of a national hospice provider against Centers for Medicare & Medicaid Services’ (CMS) determination that the provider failed to meet Hospice Quality Reporting Program (HQRP) requirements for Calendar Year 2021. This alleged non-compliance by both agencies would have resulted in a 2% reduction in the provider’s annual payment update for Fiscal Year (FY) 2023. Through the HQRP reconsideration process, Bass Berry & Sims successfully demonstrated that, despite guidance to the contrary, CMS’ non-compliance determination erroneously included timeframes in which each provider was not responsible for submitting HQRP, Hospice Item Set data. When such inappropriate time periods were excluded from consideration, both providers clearly satisfied HQRP requirements. Therefore, CMS reversed its initial determination of non-compliance and granted the provider the full FY 2023 annual payment update.
Representation of Tennessee Oncology, PLLC, in an investigation of False Claims Act allegations arising from a qui tam case filed in the Middle District of Tennessee by a former hospital employee who alleged Tennessee Oncology provided radiation oncology treatment without appropriate supervision and prostate cancer treatment without complying with applicable documentation requirements. Following its investigation, the Department of Justice declined to intervene in the action, and the relator dismissed the case. Ferren v. HCA Health Services of Tennessee, et al. (M.D. Tenn.)
Representation of Agape Care Group, a leading hospice and palliative care provider in the Southeast, in it’s acquisition of Hospice of the Carolina Foothills, a hospice provider based in Forest City, North Carolina. Terms of the transaction were not disclosed.
Representation of Addus HomeCare Corporation (Nasdaq: ADUS), a provider of home care services, in its acquisition of JourneyCare, Inc, one of the largest hospice and palliative care providers in Illinois for $85,000,000.
Representation of Pharos Capital Group, LLC, a middle-market private equity firm based in Dallas and Nashville, in its acquisition of THEMA Health Services, a leading provider of hospice, skilled home health, and palliative care services throughout the state of Arizona. Terms of the transaction were not disclosed.
We successfully defended a national home healthcare provider in appealing an $18 million extrapolated overpayment resulting from a UPIC audit.
Representation of Pharos Capital’s post-acute care provider platform, Charter Health Care Group, in its acquisition of Genesis Hospice, a Texas-based hospice care provider. The addition of Genesis and Saints brings the number of Charter locations to 18 and marks the company’s fourth program in Texas.
Chambers USA — Healthcare: Regulatory (2016-2022)
The Best Lawyers in America© — Health Care Law; Litigation: Health Care (2013-2023)
Best Lawyers® — Nashville Litigation: Health Care “Lawyer of the Year” (2022, 2017)
Nashville Business Journal “Best of the Bar” (2019)
Certified in Healthcare Compliance (CHC)®
Mid-South Super Lawyers (2018-2022); “Rising Star” (2011-2012)
Nashville Business Journal “Health Care Hero” (2015)
Nashville Business Journal “Forty Under 40” (2012)