Ms. Bohl advises hospitals, health care systems, and providers in compliance and regulatory issues with particular emphasis on fraud and abuse matters as well as recently implemented Medicare payment models. Drawing on her experience in the federal government, she counsels clients on actual and potential compliance concerns that arise on a day-to-day basis as well as offers assistance navigating more serious concerns that require a more extensive plan of action to address. With the changes to Medicare reimbursement under the Quality Payment Program (QPP), Ms. Bohl advises clients participating in both Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs).
Ms. Bohl assists clients with analysis of issues involving the Stark physician self-referral statute, the anti-kickback statute, and Medicare payment policy. She advises clients on arrangements among health care providers, internal compliance issues, communication with the federal government related to compliance issues – including the submission and resolution of voluntary disclosures to the OIG and CMS self-disclosure protocols when necessary. She provides guidance on the legal aspects of health systems operations and drafts and implements compliance programs and policies.
New issues for clients to consider continue to arise as CMS continues to develop new payment systems and bundled payment programs. Participation in the Quality Payment Program presents new concerns and sometimes requires new strategies for success. As part of the Bundled Payment Team at Baker Donelson, Kristin assists clients to decipher the path forward in compliance with program rules as well as applicable fraud and abuse limitations.
Prior to entering private practice, she served as the Technical Advisor in the Division of Technical Payment Policy at the Centers for Medicare & Medicaid Services (CMS) where she worked on Stark law policy. During her tenure at CMS, she was part of the team that developed and implemented aspects of the Stark law, including the CMS Voluntary Self-Referral Disclosure Protocol. Her work also included the analysis and resolution of self-disclosures submitted pursuant to the protocol.
Ms. Bohl also provided technical assistance in the development of waivers of the Stark law for various Accountable Care Organizations (ACO) models, including the Medicare Shared Savings Program (MSSP) and other payment initiatives within CMS’ Center for Medicare & Medicaid Innovation.
Ms. Bohl also brings experience from the provider’s perspective. She was a registered nurse who, before attending law school, worked at Johns Hopkins Hospital and Memorial Sloan Kettering Cancer Center.