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Christina Randolph

Partner

St. Louis
314 552 6539 direct

Clients look to Christina for practical solutions to their complex regulatory compliance problems. She provides in-depth legal and business advice to a wide variety of health care clients, including integrated health care delivery systems, hospitals, physicians and physician practices, ambulatory surgical centers, and imaging providers.

Christina works closely with clients and their in-house counsel on day-to-day operational issues in order to minimize risk and achieve their business goals. Christina has extensive experience counseling clients on a variety of regulatory compliance issues faced by health care entities, with an emphasis on:

- Stark law

 - Medicare/Medicaid reimbursement

- RAC and ZPIC Audits

- Coding and billing practice self-audits

- Responding to government investigations

- Initiating self-disclosures to CMS and OIG

- Compliance plan operations

Christina also regularly advises clients on matters related to physician-hospital alignment strategies including acquisitions, contractual and equity joint ventures, employment arrangements, and hospital-based contracting arrangements. She works closely with in-house counsel and outside consultants to develop Stark-compliant compensation plans and revenue-sharing pools between hospitals and physicians.

Since 2009, Christina has served as an adjunct professor for the Center for Health Law Studies at Saint Louis University School of Law, which has been ranked as one of the top health law programs in the nation for nearly a decade.

Before joining private practice, Christina was a licensed clinical social worker providing counseling services to children, families and adults. She provided services in social service settings, including a community-based residential treatment center and a hospital emergency department.

Blogs

Final Rule on refund of Medicare overpayments: Key requirements to know

Record-breaking FCA settlements underscore importance of Stark Law compliance

OIG Updates 2015 Work Plan: New Medicare initiatives for hospitals, DMEPOS suppliers, clinical labs, GPOs

Timeline tightens for provider, supplier responses to MAC and ZPIC requests starting April 6, 2015

Hospital financial assistance policies: IRS gives new guidance on complying with Section 501(r)

IRS provides interim guidance for ACO participation in Medicare Shared Savings Programs and expands safe harbors for management contracts

OIG issues special fraud alert on laboratory payments to referring physicians

Presentations

"Navigating Care Improvement: Bundled Payments and Physician Compensation Incentives";
Healthcare Financial Management Assn., February 12, 2015

“Advanced Stark Law - Enforcement of the Stark Law and Strategies to Protect Your Organization”;
Missouri Hospital Association, April 2014

"Disruptive Physicians: Navigating the Employment of Medical Staff Issues";
Missouri Hospital Association Center for Education, February 2014

“Compliance and Auditing”;
Healthcare Financial Management Association, Southern Illinois Chapter, February 2014

“Stark Self-Disclosure (Do’s & Don’ts)”;
Healthcare Roundtable for General Counsel, September 2013

“The Heat is On! Government Enforcement of the Stark Law and Strategies to Protect Your Organization”;
Missouri Hospital Association, May 2013

“Physician Contracting: The Importance of Compliance”;
Healthcare Financial Management Association, Southern Illinois Chapter, February 2013

“The Stark Law Self-Referral Disclosure Protocol”;
Missouri Hospital Association Annual Convention, December 2012

“Physician Contract Arrangements – Know What to Watch For”;
National Catholic Health Audit Network, August 2012

“Hospital-Physician Arrangements: Can Your Organization Afford the Risk of Non-Compliance?”;
Healthcare Financial Management Association, Southern Illinois Chapter, March 2012

“Hospital-Physician Relationships: Is There Really no Such Thing as a Free Lunch”;
Healthcare Financial Management Association, Southern Illinois Chapter, March 2011