Ann T.Hollenbeck

Partner

(T) 1.313.230.7960

Ann Hollenbeck is an experienced health care attorney who advises hospitals, physicians, and other providers on the implications of health care reform, human subjects research matters, and fraud and abuse. She advises academic medical centers and health systems on clinical affiliations and physician compensation. Ann also represents health care entities in transactional matters such as ancillary services arrangements, joint ventures, and physician-hospital relationships. She regularly advises health care entities regarding the negotiation of clinical trial-related agreements and related regulatory matters, including subject recruitment and informed consent.

Ann's recent experience includes advising on the structure of a value-based collaboration between specialty physicians and hospitals in response to health care reform initiatives, negotiating the acquisition of a specialty hospital, structuring a collaborative human subjects research consortium among community hospitals, and advising several hospitals on compliance issues arising from transactions and fraud and abuse allegations.

Ann previously served as assistant general counsel at the University of Michigan. She is a Fellow of the Michigan State Bar Foundation and a member of the American Health Lawyers Association and of the State Bar of Michigan (former chair, Health Law Section). Ann is a member of the community board of Ele's Place in Ann Arbor and the board of directors of Ann Arbor Symphony Orchestra (former president).

Ann has been quoted in publications, such as MedPage Today and Crain's Detroit Business, on hospital-related topics.

Experience

Nonprofit health system collaborates with research enterprise
Jones Day is representing a nonprofit health system in its clinical research collaboration and support agreement in conjunction with a specialty research enterprise.

Large digital health company grows operations across U.S.
Jones Day advised a large digital health company in expanding operations throughout multiple states in the U.S. and in responding to several state regulator inquiries regarding its operations.

Emerging digital health company expands operations to new telehealth services
Jones Day advised an emerging digital health company in expanding its telehealth product offerings to patients across the United States and in responding to several state regulator inquiries regarding its operations.

Nonprofit hospital enters co-management agreement with physician group for oncology service line
Jones Day represented a nonprofit health system in negotiating and drafting a co-management agreement with physician group for oncology services at one of its subsidiary hospital's inpatient facility and outpatient locations.

The following represents experience acquired prior to joining Jones Day:

Prepared provider gain sharing structure for CMS Comprehensive Care for Joint Replacement Model.

Structured clinical integrated network among physician groups and hospital in response to health care reform initiative.

Negotiated acquisition transaction for specialty hospital.

Structured collaborative human subjects research consortium among research institutions, hospitals and physicians.

Counseled hospitals on compliance issues arising with non-fair market value transactions, fraud/abuse, research, and physician matters.

Advised long-term care and home health provider on collaborative relationships with other providers in response to readmission penalties and related quality initiatives.

Evaluated fraud/abuse and Stark issues to structure successful hospital and physician joint venture and other arrangements for radiology, physical therapy, and outpatient surgery services.

Advised non-profit tax-exempt Board of Directors on TBOR2 (intermediate sanctions) protections offered by IRS for insider transactions and physician/executive compensation plans.

Advised medical school in educational affiliation arrangements and faculty compensation.

Led team in conducting audit of academic health care system’s physician compensation practice.

Drafted research, licensing, and joint venture agreements among health care institutions, medical researchers, and pharmaceutical companies.

Structured recruitment arrangement between hospital and physician group within confines of tax-exempt principles and fraud/abuse regulations.

Provided counseling as to the impact of the Medicare reimbursement rules for routine patient care costs in clinical trials.

Analyzed the application of federal and state fraud and abuse statutes to the financial relationships created by clinical trials.

Obtained favorable private letter ruling from IRS regarding unique activities of health care trade association.

Structured tailored physician incentive compensation plan at academic hospital.

Provided overviews of the various regulatory and accreditation standards that are applicable to potential conflicts of interest in Board of Directors’ governance and clinical research contexts.

Evaluated physician compensation relationships with drug company clinical trial sponsors in context of conflict of interest regulations.

Counseled health plan on formation and Michigan regulatory matters.

Additional Publications

  • April 2018Jones Day Talks Health Care & Life Sciences: False Claims and Private Equity, and Rideshare Apps Race into Patient Transportation
  • March 2018False Claims Act Alert: Federal Grant Reporting Serves as Basis for FCA Action
  • February 20182018 Budget Act Eases Stark Law Requirements, Increases AKS and CMP Penalties
  • February 2018Jones Day Talks Health Care & Life Sciences: Health Care's Eventful Start to 2018
  • December 2017Legislation, Lawsuit Cloud Future of 340B Program Payment Rate Reductions
  • July 2017FDA Establishes Electronic Privacy, Security, and Reliability Criteria for Clinical Trial Records

Publications Prior to Jones Day

February 2017

Advice for the Non-Healthcare Lawyer Representing Clients in Arrangements with Hospitals and Other Health Care Providers (February 2017) Michigan Bar Journal

August 2016

Representing Hospitals  and Health Systems Handbook (August 2016) Co-author American Health Lawyers Association (AHLA)

April 2016

Policy and Review:  The IRB's Imperative in Incidental Findings in Research (April 2016) Co-author American Health Lawyers Association (AHLA)

2014

Health Care Compliance Legal Issues Manual (2014) Co-author American Health Lawyers Association (AHLA)




Speaking Engagements

Speaking Engagements Prior to Jones Day

March 2017

Incidental Findings in Genomic Research: Ethics, Law and Practicality, Legal Issues Affecting Academic Medical Centers and Other Teaching Institutions, AHLA co-sponsored with National Association of College and University Attorneys (NACUA) and Association of American Medical Colleges (AAMC),

Baltimore, MD

April 2016

Hospital/Physician Relationships and the Law, Excellence in Governance Fellowship, Michigan Health and Hospital Association

Grand Rapids, MI

January 2015

Clinical Research Update - How Will New Developments Impact Your Institution?, Legal Issues Affecting Academic Medical Centers and Other Teaching Institutions, AHLA co-sponsored with National Association of College and University Attorneys (NACUA) and Association of American Medical Colleges (AAMC)

Washington, D.C.

October 2013

Tax Issues in Clinical Research, Tax Issues for Health Care Organizations Conference, American Health Lawyers Association

Washington, D.C.

January 2013

Research Collaborations between AMCs and Community Hospitals, Legal Issues Affecting Academic Health Centers and Other Teaching Institutions Conference, American Health Lawyers Association

Washington, D.C.


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