Sarah is a trial-tested False Claims Act lawyer and strategic compliance counselor to life sciences and health care companies. She defends her clients in high-stakes FCA investigations and litigation, from persuading the Department of Justice to decline intervention to taking cases through trial and appeal, and designs business-aligned compliance programs that withstand operational realities and regulatory scrutiny. Her perspective is informed by an 18-month secondment inside a life sciences company, where she built a compliance program from the ground up, and by a pioneering practice that integrates forensic data analytics to surface risk and critical evidence within enterprise data. These capabilities have driven favorable outcomes in both internal inquiries and bet-the-company disputes. Indeed, Sarah has earned industry nominations and awards recognizing her skill.
Experience
Representative matters
Representative matters
Assisted a large, multi-office physician group 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 through a two-week federal trial and appeal.
Represented a specialty heart hospital in a False Claims Act lawsuit 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 and obtained extremely favorable settlement of all allegations.
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.
False Claims Act and Compliance Matters
Assisted a large, multi-office physician group 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 through a two-week federal trial and appeal.
Represented a specialty heart hospital in a False Claims Act lawsuit 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 and obtained extremely favorable settlement of all allegations.
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 tested 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 Electronic Medical Records (EMR) services in an internal investigation into potential overpayments related to inadequate documentation of services provided to patients.
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 inaugural needs assessment related to engagement of health care professionals for performance of consulting services.
Advised numerous life sciences companies regarding the development of both external and internal patient assistance programs to obtain prior authorization for surgical procedures utilizing the companies’ devices.
Oversaw multi-disciplinary team advising large non-profit health care system regarding numerous efforts to commercialize health care products, leading a team providing guidance on anti-corruption, digital health, privacy, intellectual property, contract, and litigation concerns.
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.
Reproductive Health Care Matters
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 laws impacting access to reproductive health care.
Advised investment fund regarding impact of state laws regulating access to reproductive health care on assisted reproductive medicine such as in vitro fertilization.
Advised and represented national medical society advocating for release of delayed state report regarding maternal health data.
Advised nonprofit organization regarding state and federal laws governing access to health care clinics.
Represented over 50 organizations and business professionals in amicus brief filed before the Texas Supreme Court related to the impact of reproductive health laws on Texas businesses, economy, and the provision of maternal and other health care.
Represented two nationwide business organizations and several high-profile companies in amicus brief filed before the U.S. Supreme Court related to impact of state reproductive health laws on businesses, the economy, and the provision of maternal and other health care services.
Recognitions
- Selected through peer review for inclusion in The Best Lawyers in America© for Health Care Law, 2024-2025
- Ranked in Chambers USA for Texas Healthcare, 2021-2025
- Shortlisted by The American Lawyer Industry Awards for "Young Lawyer of the Year – Beyond Practice”, 2024
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 Bar Association – Health Law Section, Family Law Section, Assisted Reproductive Technologies Committee
- American Health Lawyers Association
- American Society for Reproductive Medicine, Legal Professional Group
- Dallas Bar Association
- Dallas Women's Lawyers Association
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