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Alexander Justiss


Alex focuses his practice on health care operations, regulatory compliance, transactions, and procurements. This practice includes:

Operations and Regulatory Compliance
  • Advising on day-to-day regulatory and operational compliance for local, national, system, stand-alone, rural, and pediatric hospitals.
  • Analyzing compensation and remuneration arrangements for compliance with the Civil Monetary Penalties Law, Stark Law, federal and state anti-kickback statutes, and related referral restrictions.
  • Conducting internal investigations related to sentinel events and reportable incidents, as well as drafting or revising policies and disclosures.
  • Appealing adverse payor reimbursement decisions, including denials by the Medicaid Utilization Management Program (MUMP), requests for reconsideration, prior authorization denials, cost report adjustments, and compliance with the Medicaid Fairness Act.
  • Guiding all steps related to qualifying, obtaining, and maintaining healthcare licensure for facilities and providers.
  • Assisting with responses to inquiries and investigations by health care regulators, including the Centers for Medicare and Medicaid, the Office of the Inspector General, the Office of the Medicaid Inspector General, and state attorneys general.
  • Drafting core and ancillary agreements for the acquisition and sale of hospitals, physician practices, ambulatory surgery centers and other health care facilities.
  • Structuring joint venture arrangements between various providers across multiple service areas, including cardiovascular, pulmonary, ambulatory surgery, imaging, reference laboratory, and others.
  • Developing agreements, policies, and documents to structure physician and mid-level provider employment, independent contractor, and services arrangements.
  • Drafting business organization and corporate governance documents for for-profit and non-profit corporations, limited liability companies, partnerships, joint venture entities, and professional associations.
  • Managing and conducting due diligence for transactions with multiple jurisdictional and regulatory compliance components.
Government Procurements
  • Drafting and managing responses to complex State procurements, requests for proposals, and requests for information.
  • Challenging adverse procurement decisions through administrative appeals and litigation.
  • Structuring communications and disclosures to meet regulatory compliance.