Team Member
Joined: 2021
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When health care providers need advice on health care compliance, regulatory, or Medicare and Medicaid reimbursement and fraud and abuse matters, they turn to attorney Shannon DeBra. She provides practical solutions designed to protect her clients’ interests. Shannon advises clients on compliance with the physician self-referral law (“Stark Law”) and the Anti-Kickback Statute (AKS). She also works with the firm's transaction attorneys to provide analysis and guidance on Stark Law and AKS matters when physician compensation and other potential compliance issues arise in the context of due diligence of a transaction. Shannon works with health care providers to conduct compliance and billing audits and internal investigations, and when an investigation finds potential violations of law, she advises on the best route to resolve the identified issue. As appropriate, she prepares overpayment refunds to be submitted to the Medicare administrative contractor (MAC) and Medicaid agency as well as voluntary disclosures to the U.S. Attorney’s Office, U.S. Department of Health and Human Services’ (HHS) Office of Inspector General (OIG), or Centers for Medicare & Medicaid Services. Clients rely on Shannon to help them implement corporate integrity agreements, to create new compliance policies and procedures, and to conduct compliance program effectiveness reviews and gap analyses to review existing compliance programs for consistency with OIG general compliance program guidance and industry segment-specific compliance program guidance and industry best practices. She has defended health care providers in sealed qui tam cases, including developing defense strategies and leading settlement discussions with the U.S. Department of Justice (DOJ). Additionally, Shannon advises on exclusion issues, provider-based status matters, and matters relating to beneficiary inducements. Shannon served as Chief Compliance Officer for a health system in Cincinnati from 2012 to 2013; as Senior Counsel in the Office of Counsel to the Inspector General (OCIG) of the U.S. Department of Health and Human Services (HHS) from 2003 to 2006; and as an Assistant General Counsel for the Commonwealth of Massachusetts, Division of Medical Assistance (the Massachusetts Medicaid Agency) from 1998 to 2003.