Stephen M. Sullivan regularly represents health care organizations in a wide variety of regulatory, enforcement, and business matters. Stephen commonly advises and defends clients on matters involving state and federal false claims laws, anti-kickback laws, Stark laws, Medicare and Medicaid reimbursement laws, state and federal privacy laws, and laws regulating managed care organizations.
Stephen has extensive experience leading internal investigations and managing government disclosures of alleged misconduct for clients in the health care industry. Stephen also advises health care companies on complex strategic business challenges and opportunities, as well as a variety of business transactions, including mergers and acquisitions.
While Stephen’s work crosses all sectors of the health care industry, he has extensive experience counseling clients in managed care. Stephen advises managed care organizations doing business with federal health care programs, including Medicare Advantage Plans, Prescription Drug Plans, and Medicaid Plans, on matters involving sales and marketing practices, risk adjustment reimbursement, and other areas affecting such organizations.
- Defending a national managed care organization in a qui tam action concerning allegations of False Claims Act liability attributable to the risk adjustment practices of an in-home health assessment vendor contracted by our client
- Obtained dismissal with prejudice and without leave to amend on behalf of one of the nation’s largest health insurance companies in a qui tam action alleging claims under the federal and California False Claims statutes arising out of the submission of Medicare and Medicaid claims
- Obtained dismissal with prejudice on several claims and limited the remaining claims on behalf of one of the nation’s largest health insurance companies in a qui tam action alleging that doctors falsely diagnosed many patients with illnesses or illness-related complications, which resulted in the submission of false claims to Medicare for reimbursement
- Representing a national managed care organization in connection with state and federal investigations into individual health insurance cancellation practices
- Counseling a leading Medicare Advantage organization in connection with an internal investigation into alleged anti-kickback statute and false claims violations
- Representing a private equity fund in acquiring a dental practice management company
- Reviewing a national managed care organization’s compliance with Medicare Advantage regulations and related complex business challenges and opportunities
- Advising a dental practice management company in connection with an internal investigation into Medicaid billing practices
- Southwestern Law School, J.D.: summa cum laude; Southwestern University Law Review(2005-06); Moot Court Honors Program
- University of California at Santa Barbara, B.A., English and Dramatic Arts: highest honors
- Honorable Ron Parraguirre, Nevada State Supreme Court
- American Health Lawyers Association
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