Christina A. Hughes

Christina Hughes focuses her practice on healthcare compliance, particularly as related to fraud and abuse matters and Medicare coverage requirements.

Christina understands the complex business and regulatory environment in which her clients operate, and prides herself on working with each client to identify their particular needs, determine the best approach to solving a problem, and implement solutions and processes to streamline activities and avoid issues in the future.

Christina’s representation of hospitals and hospital systems, home health providers, physicians, O&P suppliers, pharmacies, and diagnostic and other health services providers includes:

• Providing advice on compliance with the Stark law, the anti-kickback statute, and the federal False Claims Act, including self-disclosures to CMS and the OIG and voluntary refunds
• Analyzing and creating Stark law compliant contracts
• Providing counsel and legal assistance with Medicare claim denials and appeals, as well as other issues related to reimbursement
• Counseling on compliance with Medicare coverage requirements for both hospital services and DME and O&P supplies

Christina’s early career experience provided unique insight and knowledge that has been of significant benefit in her current practice. During law school, Christina was employed by the Office of Counsel to the Inspector General for the Department of Health and Human Services. In this capacity, she gained first-hand knowledge of OIG self-disclosure protocols and the advisory opinion process, and also developed an understanding of the government’s view of certain anti-kickback and False Claims Act issues.

Christina also served as a legal intern with the Civil Fraud section of the U.S. Department of Justice, furthering the experiences she had at HHS, and in addition, learning about investigative techniques used by DOJ when dealing with healthcare fraud. Finally, Christina was a Health Policy Fellow with the National Academy for State Health Policy, which provided her with a special understanding of the Medicaid program and Medicaid reform, and also offered an insight into the policy needs and concerns of healthcare providers and their patient populations.

Additionally, she has:

• Represented a large inpatient rehabilitation facility in challenging individual claim denials and extrapolated overpayment; obtained reversal of the majority of individual denials and drastic reduction in overpayment amount
• Successfully represented O&P supplier in Administrative Law Judge hearings on multiple claim denials stemming from a criminal healthcare fraud investigation; obtained reversal of all denials
• Provided physician education on Medicare coverage requirements for inpatient rehabilitation facility care to staff of multi-facility safety net hospital system
• Drafted Stark-compliant recruitment and employment agreements for large academic medical center with affiliated physician practice
• Assisted with voluntary refund to Medicare program on misbilled infusion supplies
• Assisted with inpatient rehabilitation facility self-audit for past compliance with Medicare requirements; assisted with extrapolated voluntary refund to Medicare of identified overpayments
• Drafted self-disclosures to CMS and OIG for integrated multi-hospital health systems related to financial relationships with physicians
• Assisted with development of legislative and policy changes to be recommended to Congress and CMS regarding audit practices and procedures utilized by Medicare contractors, with some recommendations successfully included in Congressional legislation
• Assisted with managing and responding to OIG audit of large academic medical center
• Provided ongoing counseling and support to Medicare re: coverage and reimbursement rule for a wide range of health services