Leech Tishman advises healthcare organizations on the regulatory and operational risks associated with revenue cycle management, billing practices, and clinical documentation. In an environment where enforcement agencies and payors increasingly rely on data analytics to identify outliers and utilization trends, even well-intentioned practices can give rise to significant regulatory exposure.
Our attorneys work with healthcare providers, management organizations, and healthcare platforms to evaluate and mitigate risks across the full revenue cycle—from patient intake and coding to billing, reimbursement, and collections. We focus on identifying vulnerabilities before they trigger audits, repayment demands, or enforcement actions.
Our work includes:
- Assessing coding, billing, and documentation practices across service lines
- Evaluating utilization patterns and identifying outlier risk
- Reviewing compliance with Medicare and Medicaid coverage and reimbursement rules
- Analyzing arrangements involving care management, telehealth, diagnostic services, and ancillary services
- Identifying risks associated with delegation, outsourcing, and third-party billing vendors
We routinely assist clients in preparing for and responding to audits conducted by Medicare Administrative Contractors (MACs), Unified Program Integrity Contractors (UPICs), commercial payors, and other oversight entities. Our attorneys help clients develop audit response strategies, prepare documentation, and address repayment and overpayment issues.
In situations where potential issues are identified, we work with clients to:
- Conduct internal billing and documentation reviews
- Quantify potential exposure and repayment obligations
- Develop and implement corrective action plans
- Strengthen documentation and coding protocols
- Align operational practices with regulatory expectations
Our approach reflects a deep understanding of how billing and documentation issues are evaluated by regulators and enforcement agencies, including under the False Claims Act. We focus not only on technical compliance, but also on how patterns of conduct may be interpreted in an enforcement context.
By combining regulatory knowledge with practical insight into healthcare operations, we help clients build revenue cycle processes that are accurate, defensible, and aligned with both reimbursement requirements and long-term risk management.