Sarah Dohan is an associate practicing in the firm’s health care group. She provides regulatory, enforcement, compliance, and transactional advice to a range of health care organizations and entities, including hospitals, health systems, pharmaceutical and medical device companies, pharmacies, durable medical equipment suppliers, and health plans.
Sarah’s practice focuses on advising clients on regulatory compliance issues and assisting with internal and governmental investigations, particularly as related to reimbursement under federal health care programs and federal and state health care fraud and abuse laws, including the Stark Law, the Anti-Kickback Statute and the False Claims Act. She also works with clients on the development and implementation of corporate integrity agreements (CIAs), compliance programs, health care trainings, and health care policies and procedures.
Sarah maintains an active pro bono practice, regularly working with Ropes & Gray’s medical-legal partnership to advise on education law issues.
Experience
- Counsels clients on complex regulatory issues, including those related to the Stark Law, Anti-Kickback Statute, False Claims Act, Civil Monetary Penalties Law, Medicare and Medicaid participation and reimbursement requirements, corporate practice of medicine, and HIPAA.
- Defends health care companies subject to health care fraud investigations by federal and state enforcement agencies and to False Claims Act litigation.
- Conducts internal investigations pursuant to both whistleblower and other compliance concerns.
- Advises clients on internal audits and, if necessary, preparation and negotiation of self-disclosures to federal and state agencies and of voluntary repayments to Medicare Administrative Contractors.
- Advises clients on compliance risk assessments, programs, and policies.
- Advises pharmaceutical companies regarding federal drug price reporting requirements under the Medicaid Drug Rebate Program, 340B Drug Pricing Program, and the Inflation Reduction Act.
- Counsels academic medical centers, higher education institutions, pharmaceutical companies, and biotechnology firms regarding allegations of research misconduct and other issues relating to the integrity or reliability of scientific data.
- Advises academic medical centers, higher education institutions, pharmaceutical companies, and biotechnology firms on regulatory and compliance issues relating to clinical research.
- Advises on regulatory considerations and risk management for transactions by health care entities and investors in the health care industry.