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Douglas A. Grimm

Partner and Health Care Practice Leader
Douglas advises hospitals and health care systems with an emphasis on regulatory counseling.
Douglas A. Grimm, FACHE, Attorney, Arent Fox

Douglas maintains a national practice guiding and advising health care providers and investment firms through the complex regulatory, transactional, and government enforcement challenges in the health care industry. He previously served as a former Chief Executive Officer of multiple acute-care hospitals throughout the United States, and remains active in health care administration as a Fellow of the American College of Healthcare Executives (FACHE), the premier certification in health care management. This unique background enables Douglas to provide legal counsel with a practical, pragmatic perspective gained from years of experience as a health care executive and attorney.

Douglas focuses in the areas of mergers and acquisitions; strategic and compliance planning; fraud and abuse; Medicare reimbursement; health information privacy and security; and telehealth. He represents a wide range of clients including health systems, investment funds, group practices, clinical laboratories, specialty providers, and medical device manufacturers.

Client Work

Douglasclient engagements include:

  • Advised a multi-billion dollar global retail company in the establishment of clinical laboratories across the United States.
  • Defended a national specialty provider before the Department of Justice, FBI, the Centers for Medicare and Medicaid Services, and the Office of the Inspector General in a False Claims Act investigation that resulted in the government walking away with no fines, penalties, or restitution.
  • Represented an integrated health system in a whistleblower proceeding that involved parallel Stark and anti-kickback investigations by CMS and OIG of medical necessity issues.
  • Advised a community health system regarding a $180 million acquisition of multiple Ambulatory Surgery Centers (ASCs).
  • Advised a large academic medical center on the development and implementation of compliance plans and related procedural requirements.
  • Represented a specialty surgical hospital before the Department of Justice in a proceeding charging a hospital contractor with criminal fraud and money laundering, with no adverse consequence to the hospital.
  • Represented a community health system before the Office for Civil Rights in a HIPAA breach proceeding involving the medical records of over 100,000 patients with no adverse consequences to the health system.
  • Represented an investor-owned chain of nursing homes in its sale to a nonprofit community health system.
  • Represented physicians and physician groups in various recovery audit contractor proceedings involving claims in excess of $3 million.

Professional Activities

In addition to his FACHE certification, Douglas is also a member of the American Health Law Association (AHLA); the Healthcare Financial Management Association (HFMA); and the Health Care Compliance Association (HCCA).

Douglas was recently appointed to the Center for Telehealth & eHealth (CTeL) Legal Resource Team, serving as a subject matter legal expert for the CTeL Board of Directors, staff, and greater telemedicine community. 

Publications, Presentations & Recognitions

Douglas 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 often quoted in industry publications such as Bloomberg Law and Modern Healthcare. Recent articles and speaking engagements include:

Telemedicine

  • Co-Speaker, “Telehealth Reimbursement and Public Policy,” CTeL Digital Health Summit, June 9, 2021
  • Moderator, “The State of Telehealth Today: Practical Realities, Public Policy, and the Law,” ArentFox Schiff Webinar, April 28, 2021
  • Co-Speaker, Remote-Patient Monitoring: The New Rule, Scenarios, and Pitfalls to Avoid,” CTeL Digital Health Virtual Summit, December 3, 2020

Transactions/Corporate

  • FTC Hosts ‘Health Check on COPAs: Assessing the Impact of Certificates of Public Advantage in Health Care Markets’, July 9, 2019
  • Increased Health Care M&A Activity: Representation and Warranty Insurance Coverage, The Ambulatory M&A Advisor; December 22, 2014
  • Speaker, Unique Partnerships - Structure, Pennsylvania Institute of Certified Public Accountants; July 2014 (Hershey, PA)

Compliance/Fraud and Abuse

  • "A Pebble in the Pond? Potential Ripple of a Court Decision to Vacate the Medicare Part C/D 60-Day Overpayment Rule," Health Care Counsel; September 17, 2018
  • Co-Speaker, "Status of the ACA and Provider Compliance Programs," National Capital Healthcare Executives (NCHE) Meeting; February 20, 2018 (Arlington, VA)
  • Co-Speaker, "The Affordable Care Act: What Now?" Lawline; June 5, 2017 (Webcast)

HIPAA/Privacy

  • Speaker, "Cyber Vulnerabilities: What to Know and What to Do," Healthcare Group Purchasing Industry Initiative, May 16, 2019
  • Co-Panelist, "Health Care Technology 2017: Critical Issues in Cybercare, Digital Medicine, and Structuring Effective Agreements," PLI Annual Health Care IT Conference; June 13, 2017 (New York, NY)
  • Co-Panelist, "Health Care IT 2016: New Technology, New Legal Issues," PLI Annual Health Care IT Conference; June 3, 2016 (New York, NY)

Reimbursement

  • Co-Speaker, “Telehealth Reimbursement and Public Policy,” CTeL Digital Health Summit, June 9, 2021
  • Speaker, HHS’s Provider Relief Fund: What Happens After Today?,” Virginia-DC HFMA Spring Education Virtual Conference, April 15, 2021
  • "CMS Releases CY 2020 Proposed Physician Fee Schedule," Health Care Counsel; August 2, 2019

Research

  • Bar & Court Admissions
    • District of Columbia Bar
    • Texas Bar
    • Supreme Court of the United States
    • US District Court, District of Columbia
  • Education
    The George Washington University Law School, LL.M., summa cum laude, Health Law
    South Texas College of Law, JD, cum laude; Editor-in-Chief, South Texas Law Review
    Virginia Commonwealth University, MHA
    The College of William & Mary, BA, Government

Awards

Awards

The Legal 500 – The Clients Guide to Law Firms