Page Smith provides healthcare regulatory counsel as it relates to compliance, operational and transactional matters.
Page earned her law degree from the University of Kentucky College of Law, an M.P.H. in health policy from Emory University Rollins School of Public Health, and a B.S. in biology and minor in poverty and human capability studies from Washington and Lee University.
American Health Law Association (AHLA)
We successfully defended a regional hospice in a responding to an audit conducted by the Office of Audit Services of the Health and Human Services’ Office of Inspector General (OIG-OAS) and appealing the results recommended in the OIG-OAS final report. Our representation resulted in a reduction of the original overpayment in the OIG-OAS final report from $7.3 million to $79,000 on appeal.
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.
Lead counsel to West Tennessee Healthcare in obtaining a Certificate of Need (CON) to convert its existing hospital-based outpatient surgery center to a freestanding multi-specialty surgery center that will provide state-of-the art services
Lead counsel to a Memphis-based children’s research hospital in obtaining a Certificate of Need (CON) to initiate home health services
Lead counsel to Acadia Healthcare Company, Inc. in its efforts to obtain a Certificate of Need (CON) to open a state-of-the-art opioid treatment program (OTP) facility in suburban Nashville, Tennessee
Lead counsel to Acadia Healthcare Company, Inc. in its efforts to obtain a Certificate of Need (CON) to open a state-of-the-art opioid treatment program (OTP) facility in Cleveland, Tennessee
Representation of BRC Recovery in its recapitalization with private investment firms, Veronis Suhler Stevenson (VSS) and NewSpring Health Capital
Represented Consonance Capital Partners in the recapitalization of Orsini Pharmaceutical Services, LLC
Publication:
Kentucky Law Journal — Managing Editor
CALI Excellence Awards in Conflict of Laws, Complex Litigation Seminar, Family Law, Healthcare Organizations & Finance, Legal Research & Writing, and Secured Transactions.
University of Kentucky College of Law 1L Legal Writing Competition — Best Appellant Brief