Katherine M. Sullivan
Katie Sullivan is an associate in the health care group, with an emphasis on representing clients in the health care and life sciences industries. Katie advises health care organizations including academic medical centers, integrated delivery systems, non-profit and for-profit health care systems, physician practices, insurers, and pharmaceutical and medical device companies on a variety of regulatory, reimbursement, professional licensing, compliance, and transactional matters. Katie also assists the firm’s private equity, public company, and strategic investor clients with due diligence matters for transactions involving health care companies.
Katie has represented health care systems and other providers in a variety of transactions, including strategic affiliations, joint ventures, mergers and acquisitions. She regularly advises pharmaceutical and medical device companies on compliance with health care fraud and abuse laws, including the Anti-Kickback Statute, the Stark Law, the False Claims Act, and state analogs. Katie represents clients in internal investigation matters and development of comprehensive internal compliance policies, procedures and training. Katie also advises clients on the fraud and abuse aspects of health care reimbursement matters, including recent CMS payment initiatives such as bundled payments (BPCI) and episode-based care initiatives, such as Comprehensive Care for Joint Replacement (CJR).
Katie regularly advises clients in the health care space, including providers, insurers, employers and academic institutions, as well as their business associates, on federal health care privacy and security issues, including HIPAA, as well as state health care privacy laws and data breach reporting requirements relating to medical records and personal information. She also routinely advises clients on business associate agreement requirements for both covered entities and business associates and their subcontractors.
As an associate, Katie was seconded to one of Boston’s academic medical centers to provide advice regarding health care privacy law compliance. Prior to joining the firm, Katie earned her Master of Public Health, with a concentration in health policy and management, from the Harvard School of Public Health. Before law school, Katie worked as a litigation paralegal for a Washington D.C. firm, focusing on primarily London-based insurance and reinsurance matters.
- Advised academic medical system on single-hospital membership substitution and realignment.
- Advised non-profit health care system on acquisition multi-hospital system.
- Advised integrated delivery system on implementation of Comprehensive Joint Replacement initiative, including development of provider gainsharing contracts and supporting documentation.
- Created revised compliance policies and procedures relating to sales, promotions, and educational use for medical device company.
- Advised medical device company on response to qui tam lawsuit and resulting government investigation.
- Advised academic medical center on update of HIPAA policies, procedures and related documents following enactment and implementation of HIPAA Omnibus Final Rule.
- Katherine M. Sullivan, “But Doctor, I Still Have Both Feet! Remedial Problems Faced by Victims of Medical Identity Theft,” 35 American Journal of Law & Medicine 647 (2009)
- Co-Presenter, “Shaping the Future: The Role of Payors in Value-Based Care” (June 19, 2017)
- Co-Presenter, “New Compliance Program Guidance from DOJ and OIG” (April 25, 2017)
- Co-Presenter, “Overpayments, Short Stays and Outpatient Reimbursement: Addressing Major Changes to CMS Rules in 2016,” Massachusetts Hospital Association (March 30, 2016)