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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We successfully defended a national home healthcare provider in appealing an $18 million extrapolated overpayment resulting from a UPIC audit.
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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.
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Representation of Humana Innovation Enterprises Inc. (affiliated with Humana Inc.) in its minority joint venture investment in Summit Medical Group, East Tennessee’s largest primary care organization.
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Representation of Grant Avenue Capital, a healthcare-focused middle-market private equity firm, in its acquisition of Hearts for Hospice, LLC a full-service Utah hospice and home health agency, and Abode Healthcare, Inc., a home health care provider.
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Pharos Capital’s Charter Health Care Group Acquires Physmed Home Health Care and Serene Care HospiceRead More
Representation of Pharos Capital’s post-acute care provider platform, Charter Health Care Group, in its acquisition of sister companies Physmed Home Health Care and Serene Care Hospice. Physmed Home Health specializes in geriatric care, delivering traditional home health nursing and therapy services, as well as social work and dietician services. Serene Care Hospice provides in-home end-of-life care with services including nursing care, spiritual care and bereavement support. Terms of the transaction were not disclosed.
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We represented Grant Avenue Capital, a healthcare-focused middle-market private equity firm, in its acquisition of Valeo Home Health and Hospice, a provider of in-home rehabilitation and end of life care.
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Representation of Complete Health Partners, a Pharos Capital Group primary care platform based in Jacksonville, Florida, in its acquisitions of two Birmingham, AL primary care practices, Northside Medical Associates and Adamsville Family Medicine
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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 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 Ear, Nose, Throat and Allergy Associates of South Georgia, an ENT and allergy practice in Valdosta, Georgia.
Publications
Upcoming Events
Past Events
Media Mentions & Firm News
Accolades
Chambers USA — Healthcare: Regulatory (2016-2021)
The Best Lawyers in America© — Health Care Law; Litigation: Health Care (2013-2022)
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 (2018-2020); “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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