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:
- 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 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 physician self-referral (Stark) and Health and Human Services’ Office of Inspector General (HHS-OIG) disclosure protocols.
- Representing clients in responding to and, if necessary, appealing the results of payor claims audits and payment suspensions arising from 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, and audits conducted by the HHS-OIG Office of Audit Services (OIG-OAS).
- Assisting clients in resolving any issues with enforcement authorities, if audit results are referred to law enforcement, and addressing potential revocation of billing rights and other administrative actions.
- 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 OIG, United States Department of Justice, the Centers for Disease Control and Prevention, state Attorney Generals’ offices, and state regulatory agencies.
- EMTALA Matters – Representing hospitals in various matters related to the Emergency Medical Treatment and Labor Act (EMTALA), including:
- Assisting in responding to Statements of Deficiencies, including immediate jeopardy findings, and preparing Plans of Correction to address the cited deficiencies.
- Representing hospitals in EMTALA reviews conducted by Quality Improvement Organizations (QIOs), including preparation of written submissions and meeting presentations.
- Successfully representing before HHS-OIG in resolving allegations of potential EMTALA violations without the assessment of civil monetary penalties or other sanctions.
- 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 conducting medical staff investigations and hearings, and responding to records requests and subpoenas.
- Transactions – Providing advice on regulatory issues and operational implications in healthcare acquisitions, mergers, joint ventures and other business combinations.
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.
