Carol advises health care, life sciences, and private equity clients on the regulatory requirements and business considerations related to health care transactions, including mergers, acquisitions, and divestitures; investments in health care companies; and financing transactions. Carol’s extensive health regulatory experience helps guide parties on due diligence, change of ownership issues, regulatory approvals, and related regulatory issues. In addition, she guides clients on compliance with physician self-referral and anti-kickback laws, and with beneficiary inducement and exclusion issues. She also represents clients in payor audits and False Claims Act investigations and proceedings.
Experience
Representative matters
Representative matters
Represents Webster Equity Partners, a health care-focused private equity fund, and its portfolio companies, on health care regulatory matters in connection with acquisitions, divestitures, and ongoing operations of its portfolio companies, including a multistate home care company, a national hospice company, several specialty physician and physiatrist practices, a leading provider of pediatric home care and therapy, a nuclear pharmacy company, a company serving medically underserved rural and other areas, a behavioral health company, and a national substance use disorder treatment company.
Represents a private-equity sponsored dental services organization on health care regulatory matters in affiliations with oral surgery and dental practices across the United States, as well as regulatory, privacy, and compliance matters.
Represents a national provider of substance use disorder treatment services on state licensure, compliance, Part 2, and HIPAA privacy matters, as well as state Medicaid audits and related alleged overpayments.
Represents Webster Equity Partners, a health care-focused private equity fund, and its portfolio companies, on health care regulatory matters in connection with acquisitions, divestitures, and ongoing operations of its portfolio companies, including a multistate home care company, a national hospice company, several specialty physician and physiatrist practices, a leading provider of pediatric home care and therapy, a nuclear pharmacy company, a company serving medically underserved rural and other areas, a behavioral health company, and a national substance use disorder treatment company.
Represents a private-equity sponsored dental services organization on health care regulatory matters in affiliations with oral surgery and dental practices across the United States, as well as regulatory, privacy, and compliance matters.
Represents a national provider of substance use disorder treatment services on state licensure, compliance, Part 2, and HIPAA privacy matters, as well as state Medicaid audits and related alleged overpayments.
Advises clients on HIPAA compliance, including responding to data breaches and HHS Office for Civil Rights inquiries and investigations.
Successfully resolved a significant commercial payor audit and overpayment demand for a behavioral health company for allegedly failing to follow the payor’s billing rules relating to patient financial responsibility and for lack of medical necessity.
Represents hospices, home health agencies, home infusion providers, behavioral health companies, durable medical equipment suppliers, and other post-acute providers on developing and implementing corporate compliance programs, including conducting internal reviews, responding to surveys and audits, and billing and coding compliance, including the requirements of the No Surprises Act.
Advised a private equity fund on its acquisition of a provider of behavioral therapy services, and its subsequent exit.
Represented Philips Healthcare in its acquisition of RespirTech, a manufacturer and supplier of airway clearance therapy devices for patients with cystic fibrosis and other respiratory conditions, and continues to advise on health care regulatory and compliance matters.
Counsels health care and life sciences companies on joint ventures, strategic alliances, and operational agreements.
Represented HCR ManorCare in a billion-dollar False Claims Act case in which, after years of investigation, the U.S. Department of Justice conceded defeat and dismissed the case. The government had alleged that HCR ManorCare delivered unnecessary therapy to patients covered under Medicare Part A in its skilled nursing facilities (U.S. ex rel. Ribik v. ManorCare Inc. et al. (E.D. VA)).
Successfully settled voluntary disclosures to the Department of Health and Human Services (HHS), Office of the Inspector General (OIG) on behalf of providers and suppliers on excluded individuals and billing matters.
Represents medical device companies on internal reorganizations, Medicare and Medicaid reimbursement matters, and compliance issues.
Recognitions
Selected through peer review for inclusion in The Best Lawyers in America© for Health Care Law, 2021-2026
- Listed as a Leading Lawyer in The Legal 500 US for Healthcare: Service Providers, 2013-2019
- Named a Life Sciences Star for Regulatory in the LMG Life Sciences Guide,2013-2021, and a Life Sciences Star for Healthcare Pricing & Reimbursement in the LMG Life Sciences Guide, 2022-2025
Credentials
Education
Education
- New York University School of Law, 1984, J.D.
- Harvard University, Radcliffe College, 1981, B.A., Phi Beta Kappa
Professional admissions & qualifications
Professional admissions & qualifications
- District of Columbia
Court admissions
Court admissions
- U.S. Court of Appeals - Seventh Circuit
- U.S. District Court - District of Columbia
Professional affiliations
Professional affiliations
- American Health Lawyers Association
- District of Columbia Bar Association
- Women’s Bar Association – past chair of the Health Law Forum
News
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Media mentions
Insights
Blogs
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