Profile
Julie A. Sullivan is a health care regulatory and compliance attorney concentrating her practice on state and federal health care fraud, waste and abuse guidance, reimbursement matters, as well as health privacy and security law. She represents health care providers and suppliers in complex regulatory and transactional matters, and routinely advises on issues such as corporate practice of medicine, fee splitting, licensure and certification issues including Medicare revocation, payment suspension and exclusion matters, and Medicare and Medicaid reimbursement disputes. Julie also structures mergers and acquisitions and value-based care arrangements in the health care space to comply with the vast legal and regulatory requirements applicable to these arrangements, and leads regulatory due diligence and diligence remediation efforts in connection with such transactions in tandem with the corporate M&A teams at GT and other law firms.
Julie routinely assists provider clients, including behavioral health providers, physician groups, federally qualified health centers (FQHCs), hospitals and health systems, long-term care providers, and other health care service providers and suppliers with referral source relationship compliance issues and internal or government investigations into billing issues and the handling of such matters requiring refunds and/or self-disclosures to government-funded health care programs or regulatory agencies.
As a certified professional coder (CPC), Julie assists clients with billing and coding guidance, billing audit support/defense and appeals. Julie also works closely with GT’s white-collar teams on health care fraud investigations involving billing and coding matters (as well as other fraud and abuse issues). Julie also advises clients regarding corporate integrity agreements, CMS compliance plans, and other government-directed compliance initiatives.
Julie also spearheads GT’s quarterly Behavioral Health Law Ledger, a publication tailored to serve the unique legal needs and interest of behavioral health providers, and routinely speaks at conferences and podcasts on behavioral health legal and regulatory matters.
Concentrations
- Behavioral health law
- General fraud and abuse counseling on anti-kickback statutes, beneficiary inducement prohibitions, false claims acts, and related federal and state statutes and regulations
- Medicare and Medicaid enrollment, revocation/billing suspensions, changes of ownership, participation, and compliance matters
- Fee-splitting and patient brokering
- The Stark Law and related state physician self-referrals laws and financial interest disclosure obligations
- Government self-disclosure processes, including the Centers for Medicare and Medicaid Services’ (CMS) Self-Referral Disclosure Protocol (SRDP), the Office of Inspector General’s Self-Disclosure Protocol, and Colorado Medicaid’s disclosure and refund processes
- HIPAA and HITECH, and related state privacy and security laws
- Substance use disorder and mental health privacy and confidentiality laws (42 CFR Part 2 and state equivalents)
- Minor privacy and confidentiality laws
- Medical billing and coding requirements
Capabilities
Experience
- Represents several Colorado Medicaid regional accountable entities (Medicaid managed care entities) with operational, litigation, investigative, and transactional matters, including provider contracting and state contracting matters.
- Represents several behavioral health providers, including but not limited to community mental health centers (CMHCs) and psychiatric hospitals, across all mental health services and ASAM levels of care in general healthcare matters, including licensure, survey response, reimbursement, government investigations, self-disclosures, provider contracting, compliance program matters.
- Represents several physician practices and FQHCs as outside general counsel.
- Represented Blue Wolf Capital Partners, LLC in its acquisition of Fox Rehabilitation, one of the largest providers of geriatric outpatient therapy services in the country.
- Represented Madison River Capital in its acquisition of Senior Care Therapy, a leading provider of patient-centered psychology and mental health services to the geriatric population in sub-acute, long-term care, and assisted living communities.
- Represented New Mountain Capital in its sale of Alteon Health, a leading provider of outsourced healthcare practice management services to emergency departments, hospitalist programs, and hospital-based urgent care centers.
- Represented an affiliate of Centre Partners in connection with its acquisition of PSYBAR L.L.C. and Gary L. Fischler & Associates LLC, regional providers of behavioral health assessments and independent medical evaluations for employers and insurers.
- Represented H.I.G. Growth Partners in its acquisition of Sage Hospital, a leading provider of primary and palliative care services in the southwest.
- Represented an affiliate of H.I.G. Growth Partners in connection with its acquisition of Livi Medical Services, PLLC and Phoenician Hospice, PLLC, regional providers of family medicine and hospice services.
- Represented Blue Wolf Capital Partners, LLC in connection with its acquisition of RHA Health Services, a leading provider of community-based health services focused on individuals with intellectual and developmental disabilities, behavioral health needs and substance use challenges.
- Assistant General Counsel and Deputy HIPAA Privacy Officer, DaVita Inc., 2011-2014
- Adjunct Professor, Chicago-Kent College of Law, Illinois Institute of Technology, 2017-2019
Recognition & Leadership
- Listed, The Best Lawyers in America, Health Care Law, 2021-2025
- Listed, 5280 The Denver Magazine, "Top Lawyers," Health, 2025
- Team Member, a U.S. News - Best Lawyers® "Best Law Firms," "Law Firm of the Year" in Information Technology Law, 2024
- Member, American Health Law Association, 2006-Present
- Member, Colorado Bar Association, 2011-2022
- Board of Directors, Every Child Pediatrics (formerly Rocky Mountain Youth Clinics), 2014-2023
- Board of Directors, Colorado Lawyers Committee, 2015-2018
Credentials
- M.P.H., University of Illinois, 2007
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J.D., with high honors, Chicago-Kent College of Law, Illinois Institute of Technology, 2006
- Order of the Coif
- Member, Chicago-Kent Law Review
- Member, Seventh Circuit Review
- B.A., University of Wisconsin-Madison, 2002
- Hon. William J. Bauer, U.S. Court of Appeals for the Seventh Circuit, 2007-2008
- Colorado
- Illinois