Anna M. Grizzle
With over fifteen years of experience, Anna helps healthcare clients address enforcement and compliance issues and respond to legal and regulatory violations. 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. She also advises healthcare companies on regulatory and compliance matters, including transactions involving mergers, acquisitions, joint ventures and dispositions.
Representing national hospitals, health systems, hospices, ambulatory surgery centers and a variety of other healthcare providers, laboratories and DMEPOS suppliers from many industry sectors, Anna’s practice involves:
- Government Enforcement & Compliance – Developing and implementing 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, including:
- 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.
- Conducting internal investigations, including coordinating the hiring of outside statistical, coding or billing experts.
- Providing advice on the reporting and repayment of overpayments, as appropriate, including representing clients in self-disclosures, including disclosures made through self-referral (Stark) and OIG disclosure protocols.
- Representing clients in responding to and, if necessary, appealing the results of payor claims audits, including those performed by Recovery Auditors f/k/a Recovery Audit Contractors (RACs), Program Safeguard Contractors (PSCs) n/k/a Zone Program Integrity Contractors (ZPICs), Uniform Program Integrity Contractors (UPICs), Medicaid Integrity Contractors (MICs) and State Medicaid Agencies.
- Assisting clients in resolving any issues with enforcement authorities, if audit results are referred to law enforcement.
- Healthcare Fraud & Abuse – Representing clients in connection with False Claims Act litigation, self-disclosures, internal investigations and responding to governmental inquiries regarding potential regulatory, compliance and clinical issues, 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.
- Contracting, Regulatory & Operational Matters – Counseling on healthcare operations and compliance, such as fraud and abuse, reimbursement, patient care, quality, and risk management issues, with 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.
- Mergers & Acquisitions – Advising a variety of national healthcare companies in mergers and other business combinations, as well as providing analysis on the regulatory and operational implications of potential transactions.
- Healthcare Disputes – Defending clients in medical malpractice actions and commercial litigation.
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)®. She is also among the most trusted leaders of Bass, Berry & Sims, serving on the firm’s Executive Committee.
Memberships
Health Care Compliance Association
American Health Lawyers Association (AHLA)
American Bar Association — Women in White Collar Subcommittee
Representative Experience
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Successfully defended a number of clients across industry sectors, including hospitals, physician practices, hospices, home health agencies and DMEPOS suppliers, in appealing audit results where statistical sampling was used to calculate to extrapolated overpayment demands.
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Currently serve as outside counsel for one of the largest national hospice providers, handling audit response issues and appealing unfavorable audit results, which has resulted in overturning millions of dollars in overpayment demands.
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Currently serve as outside counsel for a publicly traded senior living in responding to home health and hospice audits.
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Represented Addus HomeCare Corporation in its acquisition of Ambercare for $40 million.
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Represented Pharos Capital Group in its acquisition of Horizon Oncology
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Representation of hospice provider in intervened FCA action pending in Eastern District of Tennessee based on allegations that hospice services provided not medically necessary
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Represented Pharos Capital Group, LLC in its acquisition of an adolescent residential treatment center
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Represented Modern HC Holdings, Inc. in its sale to The Kroger Company
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Represented Pharos Capital Group in its new dermatology platform investment as well as its first add-on acquisition
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Successfully defended a home health agency in appealing a $9.3 million extrapolated overpayment resulting from a ZPIC audit
Publications
Past Events
Media Mentions & Firm News
Accolades
Chambers USA — Healthcare (2016-2018)
Best Lawyers in America® — Health Care Law; Litigation: Health Care (2013-2019)
Best Lawyers in America® — Nashville Litigation: Health Care “Lawyer of the Year” (2017)
Certified in Healthcare Compliance (CHC)®
Mid-South Super Lawyers (2018); “Rising Star” (2011-2012)
Nashville Business Journal “Health Care Hero” (2015)
Nashville Business Journal “Forty Under 40” (2012)
Education
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University of Alabama School of Law - J.D., 1998
Order of the Coif
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Mississippi State University - B.A., 1994
Admissions
- Tennessee, 2000
- Alabama, 1998
- U.S. District Court, Eastern District of Tennessee, 2002
- U.S. Court of Appeals Sixth Circuit, 2001
- U.S. District Court, Middle District of Tennessee, 2000
- U.S. District Court, Middle District of Alabama, 1998
- U.S. District Court, Northern District of Alabama, 1998
Chambers USA
"Anna Grizzle is described by clients as 'fantastic' when it comes to healthcare regulatory issues. Her practice also involves representing clients in connection with the full range of enforcement and compliance matters, including the regulatory aspects of corporate transactions"
From Chambers USA 2018