Anna M. Grizzle
With over 20 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), Unified 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)®. Having served as a member of the firm’s Executive Committee, Anna is looked to as a trusted leader among her peers.
Memberships
Health Care Compliance Association
American Health Law Association (AHLA)
American Bar Association — Women in White Collar Subcommittee
Representative Experience
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Representation of Addus HomeCare Corporation (Nasdaq: ADUS), the nation’s largest public provider of personal home care and support services, in its definitive agreement to acquire Queen City Hospice, LLC, and its affiliate Miracle City Hospice, LLC for a cash purchase price of $192.0 million
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Representation of Premise Health, the country’s largest direct health care provider and OMERS Private Equity portfolio company, in its acquisition of CareHere, another leading operator of wellness centers for self-funded organizations. The acquisition of CareHere, brings Premise Health’s revenue to approximately $1 billion annually and increases its geographic footprint to more than 850 centers across 45 states and Guam. The combination will allow Premise Health to deliver improved outcomes and enhance health care for employer populations.
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Representation of Southern Ear, Nose, and Throat and Allergy (SENTA) Partners, an ENT and allergy management services organization backed by Shore Capital Partners, in its affiliation with Atlanta Allergy & Asthma, the largest allergy practice in Georgia
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Representation of Southern Ear, Nose, and Throat and Allergy (SENTA) Partners, an ENT and allergy management services organization, in its affiliation with Piedmont Ear, Nose, Throat & Related Allergy, a medical and surgical ear, nose and throat practice based in Atlanta, Georgia
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Representation of a nationally-ranked academic medical center in its acquisition of a freestanding birthing center that emphasizes a family-centered, low-intervention approach to delivery for uncomplicated pregnancies
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Represented Addus HomeCare Corporation (Nasdaq: ADUS) in four strategic acquisitions and in its underwritten public offering of 2.3 million shares of common stock in 2019.
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Represented Western Dental Services, a portfolio company of New Mountain Capital, in its acquisition of Guardian Life Insurance Company’s Dental Service Organization
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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.
Publications
Upcoming Events
Past Events
Media Mentions & Firm News
Accolades
Chambers USA — Healthcare: Regulatory (2016-2020)
The Best Lawyers in America© — Health Care Law; Litigation: Health Care (2013-2021)
Best Lawyers® — Nashville Litigation: Health Care “Lawyer of the Year” (2017)
Nashville Business Journal “Best of the Bar” (2019)
Certified in Healthcare Compliance (CHC)®
Mid-South Super Lawyers (2018-2019); “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
"Market sources say Anna Grizzle is 'a real star and well thought of around the country, particularly in the regulatory space.' Clients find her to be 'highly responsive and effective.' She specializes in compliance issues, FCA litigation and regulatory matters in relation to transactions."
From Chambers USA 2020
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