Biography

Anjali Downs’ commanding knowledge of the False Claims Act, Anti-Kickback Statute, and Stark Law safeguards health care clients’ products, services, and ensures operational success. Clients, which range from the full spectrum of providers to device manufacturers and ambulatory centers, depend on Anjali’s in-depth understanding of the fraud and abuse laws and what triggers government authorities to take exception. Whether ensuring a tech company’s innovation launches smoothly or facilitating innovative arrangements among and between referral sources or defending health systems against whistleblower claims, Anjali has the skills and experience necessary to effectively handle the diverse legal needs of her clients.

During investigations, Anjali is particularly effective in persuading government regulators on issues where official guidance is scant and/or evolving, such as in substance use disorder treatment. Her skillful, novel defenses inform regulators and have reduced the threat of program exclusion, costly settlements, and other steep penalties. Anjali credits her training in public health community education with developing her empathetic style—just one reason behind the long-term relationships clients build with her.

As regulatory counsel, which is greatly enhanced by a strong defensive game, Anjali aligns clients’ risk tolerance with commercial opportunities to create a path forward. As value-based care expands, Anjali is preparing clients to meet related challenges on fraud and abuse laws and the interactions by and between health care referral sources.

Experience

  • Negotiated a settlement for a financially distressed pain management company and ambulatory surgery center to bring a five-year government investigation to closure.  Working at the request of the primary lenders, Anjali structured an ability-to-pay settlement with written cold comfort that opened up the possibility of a transaction whereby the secured lender could become majority owner of the company. 
  • Represented a provider in a fraud inquiry by a private insurer serving as a third-party administrator/contractor for a state Medicaid program. By developing a strategy focused on the ambiguity of guidance by the insurer and by focusing on the proactive actions of the provider, Anjali was able to structure a settlement that was significantly reduced from the insurer’s initial settlement demand.
  • Advised a multistate oncology services network in its implementation of its Corporate Integrity Agreement.
  • Developed a comprehensive compliance plan for a company utilizing artificial intelligence in billing and coding.
  • Counseled a national non-traditional health care company as it navigated the fraud and abuse regulatory scheme to become a provider in the health care delivery system.
  • Conducted an internal investigation and prepared a self-disclosure on behalf of a substance use disorder provider related to lack of documentation for services provided.
  • Served as an Independent Review Organization (IRO) reviewing Focus Arrangements for a hospital system during a five-year Corporate Integrity Agreement.
Education
  • University of Maryland School of Law (J.D., cum laude, 2008)
    • Article Editor, Journal of health Care Law and Policy
  • University of Maryland (M.P.H., 2002)
  • University of Maryland (B.A., 1999)
Bar Admissions
  • District of Columbia
  • Maryland
Recognition
  • Chambers USA: America’s Leading Lawyers for Business: District of Columbia—Healthcare (2021)