December 23, 2021

Volume XI, Number 357

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Kathleen Snow Sutton

Kathleen Sutton’s practice focuses on an array of health care regulatory and business matters. She has experience representing academic medical centers, hospitals, ambulatory surgery centers, senior living communities, medical groups, and other health care providers, advising on transactional and regulatory matters, including:

  • Strategic planning to achieve business goals while navigating the complex interplay of federal and state laws that affect providers.
  • Developing and reviewing business arrangements and policies and procedures to ensure compliance with fraud and abuse laws (including the False Claims Act, Stark Law and Anti-Kickback Statute); corporate practice of medicine and fee-splitting restrictions; facility and professional licensing requirements; and Medicare and Medicaid enrollment and reimbursement rules.
  • Advising on the development and operation of clinically integrated networks (CINs) and accountable care organizations (ACOs), including Medicare Shared Savings Program (MSSP) ACOs. 
  • Navigating hospital licensing, enrollment, and reimbursement issues, including rural hospital reimbursement strategies.
  • Advising on ownership and governance matters for physician organizations.
  • Assisting with mergers, acquisitions, and the development and implementation of other strategic relationships.

Prior to practicing law, Kathleen worked with health care organizations on business development and strategic initiatives. During law school, she worked in-house with different organizations in the health care industry, including the U.S. Department of Health and Human Services, large health care service and medical device companies, and a nonprofit hospital. After law school, Kathleen served as a judicial clerk for Chief Justice Nancy Rice on the Colorado Supreme Court.

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Articles in the National Law Review database by Kathleen Snow Sutton