Overview

When health care providers need advice on health care compliance, regulatory, or Medicare and Medicaid fraud and abuse matters, they turn to attorney Shannon DeBra. She provides practical solutions designed to protect her clients’ interests.

Shannon advises clients on compliance with the physician self-referral (“Stark”) law and the Anti-Kickback Statute (AKS). She also works with the firm's transaction attorneys to provide analysis and guidance on Stark and AKS matters when physician compensation and other potential compliance issues arise in the context of due diligence of a transaction.

When an investigation finds potential violations of law, Shannon works with health care providers to conduct compliance audits and internal investigations and prepares voluntary disclosures to the U.S. Attorney’s Office, U.S. Department of Health and Human Services’ (HHS) Office of Inspector General (OIG), or Centers for Medicare & Medicaid Services.

Clients rely on Shannon to help them implement corporate integrity agreements, to create new compliance policies and procedures, and to conduct compliance program effectiveness reviews and gap analyses to review existing compliance programs for consistency with OIG provider compliance program guidance and industry best practices. She has defended health care providers in sealed qui tam cases, including developing defense strategies and leading settlement discussions with the U.S. Department of Justice (DOJ). Additionally, Shannon advises on exclusion issues, provider-based status matters, and matters relating to beneficiary inducements.

Shannon served as Chief Compliance Officer for a health system in Cincinnati from 2012 to 2013; as Senior Counsel in the Office of Counsel to the Inspector General (OCIG) of the U.S. Department of Health and Human Services (HHS) from 2003 to 2006; and as an Assistant General Counsel for the Commonwealth of Massachusetts, Division of Medical Assistance (the Massachusetts Medicaid Agency) from 1998 to 2003.

Focus Areas

Experience

  • Assisted a health system in transitioning a hospital campus into a specialty services orthopedic-only center, which required engaging physicians on the center’s medical staff in quality improvement and cost reduction efforts.
  • Provided 24/7 support to a health system responding to the COVID-19 pandemic. Shannon advised the system on federal and state regulations, including waivers issued as a result of the public health emergency declaration. She also advised on staffing, compensation, quality, and patient care issues, as well as expanding telehealth abilities and related reimbursement issues.
  • Resolved civil cases under the False Claims Act (FCA) as Senior Counsel in the HHS OCIG. In the same post, Shannon also worked with DOJ to investigate and resolve FCA cases; investigated, developed, and negotiated resolution of civil monetary penalty cases; and reviewed legal sufficiency of proposals for provider exclusion under the federal health care programs.
  • Negotiated clinical trial documents on behalf of a nonprofit health system.
  • Defended a hospital and health system in a qui tam lawsuit filed by an employed physician. The lawsuit alleged that the system submitted false claims to Medicare and Medicaid by billing for services that did not comply with the applicable National Coverage Determination. The suit was ultimately settled and dismissed.
  • Assisted a nonprofit hospice provider in successfully challenging revocation of its Medicare enrollment and termination of its Medicare provider agreement.
  • Represented a county hospital that became affiliated with a large health care system, obtaining all regulatory approvals, overseeing self-disclosure of potential Stark issues.
  • Advised a health system on fraud and abuse considerations in developing a budget for clinical trials.
  • Advised a health system on fraud and abuse considerations related to a non-employed physician as the principal investigator for a clinical trial.
  • Advises clients on the appropriate parameters and available exceptions for programs that may implicate the Beneficiary Inducement prohibition under the civil monetary penalty law.
  • Conducts annual assessments of health care organization compliance programs and assists in the development and implementation of compliance programs for hospitals and other health care providers. Health care organizations use annual compliance program evaluations to set annual improvement goals and correct any identified gaps.
  • Performs compliance investigations on behalf of health care organizations when the organizations determine that an outside investigation is preferable to an investigation conducted internally by the organization’s compliance department.

Recognition

Credentials

Education

  • University of Massachusetts (M.B.A., 2003)
  • Boston University School of Law (J.D., 1998)
  • Boston University (B.A., summa cum laude, 1995)

Bar Admissions

  • Massachusetts
  • Ohio

Court Admissions

  • U.S. District Court, Southern District of Ohio

Professional & Community Involvement

  • American Health Law Association
  • Child Focus, Inc., Board of Directors
  • Health Care Compliance Association

Events

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