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
Judicial Clerkships
•Hon. William J. Bauer, U.S. Court of Appeals for the Seventh Circuit, 2007-2008
Recognition & Leadership
Awards & Accolades
•Listed, The Best Lawyers in America, Health Care Law, 2021-2026
•Listed, The Legal 500 United States, Healthcare> Service Providers, 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
