Sarah approaches solving her clients’ issues with business savvy and an understanding of, and ability to drive, their strategic business objectives. She regularly works alongside in-house lawyers, risk-control stakeholders, and operational professionals to design impactful solutions that both effectively mitigate risk and function in harmony with business operations. Sarah’s insight into her clients’ experience is informed by her 18-month secondment to a life sciences company, during which she was responsible for designing and implementing a compliance program from scratch.
Experience
Representative matters
Representative matters
Assisted a large physician group with numerous locations in responding to a Civil Investigative Demand from the United States Department of Justice (DOJ), and successfully persuaded the DOJ to decline intervention in the related False Claims Act qui tam matter brought by a former employee. The investigation related to the group’s practice of conducting Medicare annual wellness visits, billing for “incident to” services, provider enrollments in Medicare, and potential overpayments. Following declination, continued to represent the practice in ongoing civil litigation with the relator.
Represented a specialty heart hospital in a False Claims Act lawsuit filed in Arkansas alleging fraudulent documentation and billing of higher-paying diagnoses of major complications or comorbidities for Medicare patients; fraudulent billing for assistant surgeon services that were not performed; and terminating the relator in retaliation. After successfully persuading the DOJ to decline intervention, continued to represent the hospital in ongoing civil litigation with the relator.
Represented a large health care system in Texas in multiple major matters including (1) securing appellate affirmation of a dismissal of a $61.8 million False Claims Act matter, a result the U.S. Supreme Court subsequently declined to overturn; and (2) obtaining a favorable settlement for less than 2% of the overall potential liability for the client and two of its joint venture/physician-owned heart hospitals in a False Claims Act whistleblower case brought by two leading heart surgeons in a "bet the company" case, which could have had profound ramifications for all physician-owned hospitals nationwide.
Assisted a large physician group with numerous locations in responding to a Civil Investigative Demand from the United States Department of Justice (DOJ), and successfully persuaded the DOJ to decline intervention in the related False Claims Act qui tam matter brought by a former employee. The investigation related to the group’s practice of conducting Medicare annual wellness visits, billing for “incident to” services, provider enrollments in Medicare, and potential overpayments. Following declination, continued to represent the practice in ongoing civil litigation with the relator.
Represented a specialty heart hospital in a False Claims Act lawsuit filed in Arkansas alleging fraudulent documentation and billing of higher-paying diagnoses of major complications or comorbidities for Medicare patients; fraudulent billing for assistant surgeon services that were not performed; and terminating the relator in retaliation. After successfully persuading the DOJ to decline intervention, continued to represent the hospital in ongoing civil litigation with the relator.
Represented a large health care system in Texas in multiple major matters including (1) securing appellate affirmation of a dismissal of a $61.8 million False Claims Act matter, a result the U.S. Supreme Court subsequently declined to overturn; and (2) obtaining a favorable settlement for less than 2% of the overall potential liability for the client and two of its joint venture/physician-owned heart hospitals in a False Claims Act whistleblower case brought by two leading heart surgeons in a "bet the company" case, which could have had profound ramifications for all physician-owned hospitals nationwide.
Represented a medical device manufacturer in a False Claims Act case of first impression that tests the legal permissibility of a “surgeon locator” function on the company’s website, which are ubiquitous within the health care industry.
Represented a large health care system in Texas in a False Claims Act whistleblower lawsuit filed by a physician, alleging a kickback scheme between the hospital, a physician, and a third defendant, a medical device manufacturer. Following summary judgment briefing, the relator agreed to dismiss all of his claims, with prejudice, in exchange for the defendants' agreement to waive their right to seek sanctions and attorneys' fees.
Represented a large provider of EMR services in an internal investigation into potential overpayments related to inadequate documentation of services provided to patients.
In response to the U.S. Supreme Court's decision in Dobbs v. Jackson Women’s Health Org., 142 S. Ct. 2228 (2022), advised many of the nation's largest retail pharmacies, health care systems, and nonprofit organizations regarding the complex and overlapping landscape of anti-abortion laws impacting access to reproductive health care.
Sought and obtained numerous favorable advisory opinions from both CMS and OIG on behalf of numerous health care entities relating to programs implicating the Physician Self-Referral Law ("Stark Law") and Anti-Kickback Statute.
Led multi-billion-dollar medical device company through needs assessment related to engagement of health care professionals for performance of consulting services.
Regularly advises life sciences companies of all sizes regarding evaluation and management of risks associated with commercial arrangements, engagement of health care professional, business ventures, marketing plans, pricing proposals, and commercialization of new products.
Recognitions
- Selected through peer review for inclusion in The Best Lawyers in America© for Health Care Law, 2024-2025
- Named a “Rising Star” in the LMG Life Science Guide for White Collar/Govt. Investigations, 2023 – 2025
- Recipient of Reed Smith's Sean Halpin Honorable Mention for Outstanding Pro Bono Service, 2023
Credentials
Education
Education
- University of Virginia School of Law, 2011, J.D., Order of the Coif
- Bucknell University, 2008, B.A., magna cum laude
Professional admissions & qualifications
Professional admissions & qualifications
- District of Columbia
- Texas
- Virginia
Professional affiliations
Professional affiliations
- American Health Lawyers Association
- Dallas Bar Association
- Dallas Women's Lawyers Association
- Dallas Association of Young Lawyers
News
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Media mentions
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Insights
Blogs
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Events
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