Dentons LLP

Holley Thames Lutz

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Practice Areas

Concentrates her practice on Medicare/Medicaid compliance activities related to coverage, reimbursement and enforcement issues, primarily for hospitals (academic medical centers and community-based). Her practice involves proactive compliance counseling in this heavily regulated healthcare space, including the potential Medicare/Medicaid reimbursement impact of mergers and acquisitions, changes in hospital operations in terms of provider-based clinics vs. outreach clinics, graduate medical education program development and affiliations, expansion into post-acute care services, and the like. This extensive knowledge of Medicare/Medicaid regulations also leads to a robust practice in assessing (and navigating) potential hospital obligations under the Overpayment Rule. Aside from coverage/reimbursement issues, her practice involves regulatory compliance and defense of potential enforcement actions including but not limited responding to OIG investigations and draft reports, CMS Statements of Deficiencies and attendant OIG settlements for EMTALA violations, and providing Medicare/Medicaid regulatory specialty counsel in defending hospitals against FCA allegations. Finally, Ms. Lutz provides guidance and advice on Medicaid financing arrangements including provider-tax and supplemental payment models, including models rooted in Medicare/Medicaid Managed Care jurisdictions.