Carrie Valiant

Overview

Health Care Industry Access Initiative

Carrie Valiant founded and is President of the Health Care Industry Access Initiative, a non-profit organization dedicated to promoting collaborative action across the health care industry to improve access to health care coverage and services in the United States.

The Initiative is based on the premise that much can be done by the health care industry to ensure that all Americans have access to both health care coverage and health care services. Many Americans don't realize that they qualify for already-existing government programs or can afford health care coverage on their own. Many Americans who have health care coverage do not know how to access the health care services available to them.

Existing public and private funding for health care access is "siloed" within specific disease states or industry segments and remains fragmented and uncoordinated. The Initiative links access projects focused on particular health care industry segments. The Initiative also promotes local access projects, develops and distributes best practices, creates and implements innovative, collaborative models and sponsors networking events focused on collaborative action across all segments of the health care industry.

Membership is by invitation and is open to senior executives across the health care industry. Corporate sponsorships opportunities are available.

Focus Areas

Experience

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Currently represents a major teaching hospital system in the Northeast in several False Claims Act matters regarding the hospital system’s relationships with, and supervision and billing of services rendered by, its teaching physicians. Carrie and her team are conducting an internal investigation, providing strategic analysis regarding applicable federal health care program regulatory requirements, and developing strategies to respond to the government inquiry in a meaningful way.
Currently represents several Medicare managed care organizations with respect to analysis and structure of provider investment in health plans under the Anti-Kickback Statute and its safe harbors for investment interests and value-based activities.
Served as lead fraud and abuse strategic counsel in the False Claims Act qui tam case S. ex rel. Villafane v. Solinger (W.D. Ky. 2006), a case of first impression with respect to the Stark Law’s academic medical center exception. The federal district court held that an academic medical center was protected from anti-kickback liability by meeting the Stark Law academic medical center exception.
Represented a Midwest hospital with respect to a qui tam action that included over 20 discrete areas of alleged violations of the Stark Law and Anti-Kickback Statute. The representation included an internal investigation as well as extensive advocacy based on deep regulatory knowledge that was successful in narrowing considerably the scope of government interest and allowing the case to be settled. Following settlement with the government, Carrie’s preparation of her own affidavit detailing extensively the relator’s interference in the internal investigation of the qui tam allegations was key to obtaining partial summary judgment of the relator’s retaliation claim.
Represented a national hospital chain in a False Claims Act qui tam action involving its affiliated group purchasing organization’s activities that resulted in DOJ declining to pursue the case.
Represented a pharmaceutical distributor in its establishment of an affiliated group purchasing organization eligible for Anti-Kickback Statute safe harbor protection for administrative fees paid by its pharmaceutical manufacturer vendors.
Represented a hospital/health system regarding the termination from the Medicare program of its affiliated physician office laboratory, which served as the hospital’s inpatient and outpatient laboratory. The representation required the development of a comprehensive plan of correction; strategic, high-level CMS communications that ultimately reversed the CMS Regional Office’s final termination decision; and a potential litigation strategy that ultimately proved unnecessary to implement in light of CMS’s reversal.

Recognition

The Best Lawyers in America^©: Health Care Law (2006 to 2025)
Chambers USA: America’s Leading Lawyers for Business: District of Columbia—Healthcare, "Leader in Their Field" (2007 to 2024)
Washington, DC, Super Lawyers: Health Care (2007 to 2011, 2013 to 2024)
The Legal 500 United States: Health Insurers and Healthcare: Service Providers (2016)
Nightingale's Healthcare News: Outstanding Healthcare Fraud and Compliance Lawyers (2004, 2009)
The National Law Journal: One of "40 Health Care Lawyers Who Have Made Their Mark" in White Collar Crime (1997)

Credentials

Education

The George Washington University Law School (J.D., with honors, 1983)
State University of New York at Buffalo (B.A., magna cum laude, 1977)
- Phi Beta Kappa