Kristen Gentry Klos

Kristen focuses her practice in the area of Medicaid and Medicare program reimbursement, providing seasoned legal and consulting services to all providers, state agencies, lenders and contractors. Her vast array of experience and deep understanding of Medicaid and Medicare program reimbursement are reflected in the following representative experience:

• Design and implementation of Medicaid Supplemental Payment (Upper Payment Limit) programs, Medicaid Disproportionate Share Hospital programs and Medicaid Administrative Claiming programs in Indiana, Illinois, Idaho, Michigan, Utah and Wyoming (see below for more).
• General representation of entities participating in Medicaid Supplemental Payment (Upper Payment Limit) programs, Medicaid Disproportionate Share Hospital programs and Medicaid Administrative Claiming programs.
• Representation of providers in front of state and federal agencies and their third party contractors (included managed care entities), state professional licensing and facility licensing boards, state Medicaid agencies (and managed care contractors), Medicaid Fraud Control Units, state attorney general offices, the Centers for Medicare and Medicaid Services and their Medicare Administrative Contractors, the Provider Reimbursement Review Board and the Departmental Appeals Board.
• Representation of manufacturers in front of state and federal agencies, including pharmacy boards, Medicare contractors, the Healthcare Common Procedure Coding System and the American Medical Association CPT Editorial Panel.
• Analysis and evaluation of complex business relationships of providers to determine compliance under the various state and federal fraud and abuse laws, including the False Claims Act, Anti-Kickback Statute, Physician Self-Referral Law (Stark), Exclusion Authorities and Civil Monetary Penalties Law and assisting providers with obtaining favorable Office of Inspector General opinions.
• Experience in 340B pricing for manufacturers, covered entities and contractors.
• General healthcare representation of healthcare providers and their contractors, including physician groups, hospitals, dentists, dental clinics, ambulatory surgery centers, DME and drug manufacturers, pharmacies, managed care plans, third party administrators, pharmacy benefit managers, etc.