Chair, Health Care
CONTACT INFORMATION
215.564.8539 dgrimm@stradley.com Download V-Card		Office(s): Philadelphia, PA

Douglas Grimm’s practice focuses on the general representation of health care systems, with an emphasis on regulatory counseling in the areas of compliance planning, government investigations, health information privacy and security, health information technology, peer review/medical staff and certificates of need, development of new service lines, licensure and provider enrollment, and insurance issues. His clients also include physician group practices, ambulatory surgical centers, skilled nursing facilities, diagnostic imaging centers, health maintenance organizations and home health agencies.

Prior to entering law practice, Mr. Grimm served as Chief Operating Officer of multiple acute-care hospitals throughout the United States. He remains active as a Fellow of the American College of Healthcare Executives (FACHE), the premier certification in health care management. This unique background enables Mr. Grimm to provide legal counsel with a practical, pragmatic perspective gained from a decade of experience as a health care executive. Accordingly, he is uniquely positioned to offer health care clients advice that assists them in gaining strategic advantage while managing risk.

Mr. Grimm regularly represents clients before the Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) in the defense of Stark, anti-kickback and civil False Claims Act proceedings, as well as handling self-disclosure processes as appropriate. He also represents clients before the Office for Civil Rights regarding issues arising from the Health Insurance Portability and Accountability Act (HIPAA).

Mr. Grimm also maintains a particular focus on advising health systems and hospitals on corporate and structuring issues applicable to physician integration strategies, including recruitment, practice acquisition and employment.

Mr. Grimm is a frequent author and lecturer on current issues facing health care providers and payors, including trends in fraud and abuse enforcement, HIPAA compliance and health information technology. He is a member of the Board of Directors of St. Catherine Laboure Medical Clinic in Philadelphia, and serves as the Chair of its Operations Subcommittee.

In addition to his law degree, Mr. Grimm holds Masters’ Degrees in Health Law and Healthcare Administration. While in law school, Mr. Grimm served as Editor-in-Chief of the South Texas Law Review.

Recent representative engagements include:

Compliance and Fraud & Abuse 

• advised a large academic medical center on the development and implementation of compliance plans and related procedures based on CMS and OIG regulations, federal law, applicable state statutes and regulations, and The Joint Commission requirements
  
  
• represented a community-based integrated health system in a qui tam case involving parallel Stark and anti-kickback investigations by CMS and OIG of medical necessity issues; handled self-disclosure and other communications with federal and state authorities
  
  
• represented a specialty surgical hospital during Department of Justice investigation of contractor charged with criminal fraud, resulting in no adverse consequence to the hospital
  

Corporate/Strategic 

• advised and guided multiple providers through strategic integration initiatives, including ACO formation, co-management arrangements, physician employment and contracting, as well as payor alignment
  
  
• advised a community health system regarding acquisition of multiple ASCs
  
  
• advised multiple providers regarding the “meaningful use” regulations and attendant processes for qualifying for incentive payments
  

Health Information Privacy and Security 

• represented a community health system in disclosing a significant breach of PHI to the Office for Civil Rights and other enforcement authorities resulting in no adverse consequences to the hospital
  
  
• handled all aspects of multiple clients’ HIPAA issues, including management of OCR audits for compliance with the breach rules; negotiated, drafted and operationalized Business Associate Agreements and information privacy and security policies for providers and payors; and conducted internal HIPAA compliance audits and education efforts
  

General Counsel Services

Provided general counsel services addressing: 

• compliance with requirements of health care reform
  
  
• reimbursement maximization strategies
  
  
• medical staff and Board governance issues
  
  
• strategic planning
  
  
• quality of care and other risk management issues, including human resources
  

SPEAKING ENGAGEMENTS 

• “Health Care Reform: A Prescription for Change,” Southern New Jersey Chamber of Commerce, Voorhees, N.J. 
  
  
• “The OIG and You: Health Care Compliance,” National Capital Healthcare Executives, Arlington, Va. 
  
  
• “The 2011 OIG Work Plan, What You Need to Know,” National Webinar

PUBLICATIONS 

• “Proposed Rule Addresses Medicare Overpayments,” Health Care Alert 
  
  
• “The Bundled Payments for Care Improvement Initiative,” Health Care Alert 
  
  
• “ACOs and the Medicare Shared Savings Program - Deja Vu All Over Again?,” Health Care Alert 
  
  
• “Business Acumen and Regulatory Experience Enrich Healthcare Practice,” The Metropolitan Corporate Counsel 
  
  
• Co-author, “Major Changes to HIPAA Privacy, Security and Enforcement Rules Proposed by HITECH Privacy NPRM,” Health IT Law & Industry Report 
  
  
• “Will Privacy Concerns Slow Electronic Health Record Adoption Rates?,” Privacy & Data Security Law Journal 
  
  
• “The Practical Guide to Release of Information,” HCPro, Inc., 135–64 
  
  
• “Informed Consent for All! No Exceptions,” 37 New Mexico Law Rev. 39 
  
  
• “Medicare Enrollment Appeals,” Dennis Barry’s Reimbursement Advisor, Vol. 22, No. 9, Aspen 
  
  
• “OIG Continues to Scrutinize Place of Service Coding,” Dennis Barry’s Reimbursement Advisor, Vol. 22, No. 7, Aspen 
  
  
• “FDA, CLIA, or a ‘Reasonable Combination of Both’: Toward Increased Regulatory Oversight of Genetic Testing,” 41 San Francisco Law Rev. 107 
  
  
• “CMS Issues Final Rule and Revised Forms for Medicare Enrollment,” Dennis Barry’s Reimbursement Advisor, Vol. 21, No. 11, Aspen 
  
  
• “HHS’s Semi-Annual Regulatory Agenda,” Dennis Barry’s Reimbursement Advisor, Vol. 21, No. 5, Aspen