Overview

Managed care organizations and hospitals turn to attorney Chris Bennington to represent them in matters involving fraud and abuse, data privacy and security, regulatory compliance, clinical research, Medicaid managed care, and managed care and vendor contracting.

He has served as counsel to managed care organizations and hospitals before federal and state regulatory agencies, including the U.S. Department of Health and Human Services. Chris provides on-site training to clients and presents at health care law forums across the country on a wide assortment of regulatory and compliance matters, including the FCA, HIPAA, and the Health Information Technology for Economic and Clinical Health Act.

Focus Areas

Experience

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  • Conducted an assessment of a large physician practice’s existing HIPAA policies and procedures, later making recommendations and drafting revisions and additional policies. Chris trained the organization’s HIPAA privacy officer and formalized roles and responsibilities for the privacy officer, security officer, and HIPAA privacy and security committee.
  • Analyzed the applicability of the European Union’s General Data Protection Regulation (“GDPR”) to a health system’s research operations. Chris developed a GDPR-compliant standard operating procedure for the health system’s division that was determined to be a GDPR data processor.
  • Guided multiple hospitals and health systems through the Medicare appeals process for Recovery Audit Contractor (“RAC”) claim denials and overpayment determinations. Chris prepared the hospitals for RAC audits and managed appeals involving a wide array of billing issues through the Administrative Law Judge hearing process and Medicare Appeals Council when necessary.
  • Conducts annual assessments of health care organization compliance programs and assists in developing and implementing compliance programs for hospitals and managed care organizations. Health care organizations use annual compliance program evaluations to set improvement goals and correct any deficiencies. Chris also conducts compliance investigations for health care organizations when they want outside investigation rather than an investigations by their own compliance department.
  • Represented a managed care organization in its negotiation of a strategic, multistate alliance with another managed care organization and assisted in the drafting of the master alliance agreement and associated state-specific agreements. Chris also counseled the managed care organization on the various legal implications of the alliance.
  • Assumed responsibility for reviewing and negotiating nearly all of a large managed care organization’s vendor contracts. This rapidly growing managed care organization enters into dozens of new vendor contracts on a weekly basis, and Chris took responsibility for the legal reviews and negotiation of these contracts, allowing the client’s internal legal team to focus on other matters. Chris worked closely with the client’s compliance, vendor management, and operations staff. The contracts ranged from relatively low-value services agreements to complex, multimillion-dollar agreements impacting all of the client’s lines of business.
  • Drafted and filed an amicus brief on behalf of a managed care organization in an important FCA case pending before the U.S. Supreme Court. The issues before the Court were whether and how the so-called “implied false certification theory” can be a basis for liability under the FCA.
  • Reviews clinical trial agreements and related documents, including non-disclosure agreements and informed consent forms, for hospitals engaged in the conduct of clinical research. Chris advises hospital on critical provisions in clinical trial agreements, including subject injury, intellectual property, publication, and indemnification. Chris has also assisted clients with a variety of compliance issues related to clinical research, including the Common Rule, billing, the Sunshine Act, conflicts of interest, FDA regulations, and HIPAA.

Recognition

Credentials

Education

  • The Ohio State University Moritz College of Law (J.D., with honors, 2004)
  • Muskingum College (B.A., summa cum laude, 2001)

Bar Admissions

  • Ohio

Professional & Community Involvement

  • American Health Law Association
  • Health Care Compliance Association
  • Muskingum University Alumni Council
  • Society of Ohio Healthcare Attorneys

Events

Insights

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