Gulnara Anzarova advises health care providers and regulated businesses responding to government investigations, enforcement actions and audits involving federal and state agencies. She works with hospitals, health systems, physician groups and other providers on matters involving health care fraud and abuse enforcement, the False Claims Act, Anti-Kickback Statute, Stark Law, Medicare and Medicaid reimbursement and coverage requirements, FDA regulatory matters, Administrative Procedure Act (APA) challenges and related litigation.

Gulnara supports clients in high-stakes, time-sensitive matters involving government inquiries, internal reviews, factual record development and strategic responses to agency requests. Her work includes helping organizations address compliance challenges, manage risk and navigate evolving enforcement expectations in matters involving Medicare, Medicaid, federal benefits programs, data-driven enforcement activity and challenges to agency action under the APA.

She also assists clients with antitrust-related matters and regulatory issues involving SBA loans and other federal lending programs. Her experience includes work related to program integrity enforcement, Medicaid claims data, CMS initiatives, provider screening, enrollment scrutiny, data analytics expansion, cross-program enforcement alignment, HIPAA and Part 2 compliance issues, Medicare drug pricing models, FDA enforcement trends and federal anti-fraud priorities.

Before entering legal practice, Gulnara conducted research in tumor immunology, developing a foundation in scientific analysis and attention to detail that informs her work on complex investigations and data-driven matters.

Education

  • University of Denver Sturm College of Law (J.D., 2025)
    • Wichita State University (B.S., cum laude, 2016)
      • Biology; Chemistry

    Bar Admission

    • District of Columbia

    Languages

    • Russian
    • Turkmen

    Clerkships

    • Clerkship for the U.S. Attorney's Office for the District of Colorado
    Publications
    Fraud & Abuse: Recent Trends, Key Developments and What's Next
    Polsinelli proudly introduces its Fraud and Abuse: Recent Trends, Key Developments and What’s Next e-book. This publication is intended to serve as a valuable resource for health care industry stakeholders, aiming to equip you with insight into the past year’s happenings in order to better navigate the complex landscape of health care fraud and abuse enforcement. Drawing upon the decades of experience that Polsinelli’s government investigations team has in defending False Claims Act cases and health care government investigations, we curated the most notable settlements, court decisions and guidance from regulators in 2025.
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    Texas Turns Up Heat on Medicaid Fraud
    Key Takeaways: Texas has launched investigations into dozens of Medicaid providers using newly released federal claims data, marking a significant expansion of data-driven enforcement. The initiative signals heightened enforcement risk for providers, particularly in home health, occupational therapy and COVID-19-related services. Providers should expect more proactive investigations and potential enforcement actions as federal and state efforts intensify. On April 7, 2026, Texas Attorney General Ken Paxton’s office announced that its Healthcare Program Enforcement Division (HPED) has launched investigations into dozens of Medicaid providers across the state relying on newly released Medicaid claims data from the U.S. Department of Health and Human Services (HHS) made available through the Department of Government Efficiency (DOGE). The initiative reflects an increasingly data-driven approach to identifying potential fraud, with
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