• vcard
D 303.583.8202
F 720.228.2283
  • Education
    • J.D., University of Denver Sturm College of Law, 1989, with highest honors
    • B.S., cum laude, University of Michigan, 1981, Dean's List

Ann McCullough offers a practical perspective to health care clients.  She has a clinical background and 30 years of health law experience, both in private practice and as in-house counsel.

Ann has a deep understanding of the operational aspects of relating to hospitals and other health care providers, including hospital-physician financial arrangements, physician employment, medical staff, health facility licensure, telemedicine, EMTALA, contracting, and regulatory compliance.

  • Served as counsel in the planning and opening of two new hospitals, including Medicare enrollment, Joint Commission accreditation, facility licensure, life-safety codes, medical staff development, hospital-based physician agreements, and managed care strategy and negotiations with key third party payors.
  • Representing clients on EMTALA compliance matters, including development of a national EMTALA policy, EMTALA training, Medical Staff disciplinary matters, plans of correction, and defending hospitals before the QIOs and in the OIG civil monetary penalty phase.
  • Drafting and negotiating a variety of health care contracts, joint ventures, and acquisitions involving compliance with laws governing physician self-referrals (commonly referred to as the "Stark" law) and anti-kickback safe harbors.
  • Drafting medical staff bylaws, and advising hospitals and health care systems regarding medical staff development, credentialing, peer review, corrective action, antitrust, and other provider relationship matters.
  • Advising nonprofit tax-exempt health care organizations regarding IRS constraints on joint ventures, physician recruitment, physician practice acquisitions, physician compensation, and other private inurement and intermediate sanctions matters.
  • Development and operation of integrated specialty and multi-specialty provider networks, including antitrust counseling.
  • Preparing and revising corporate governance documents, policies, and procedures for the implementation and ongoing operation of health care systems.
  • Advising health care entities on regulatory compliance activities, including policy development, auditing, and internal investigations.
  • Advising health care providers on reimbursement matters, including Medicare and Medicaid reimbursement.
  • Advising health care providers on legal issues concerning informed consent, refusal of treatment, end of life, and other patient care related matters.
eAlerts Updates
November 2019
text icon Publications & Presentations
July 11, 2019
webinar Webinars
July 11, 2019
eAlerts Updates
April 2019
eAlerts Updates
March 2019
eAlerts Updates
November 2018
eAlerts Updates
Medical staff insight, peer review analysis, and updates for health care organizations presented quarterly by the nation’s health care law firm of the year.1
September 2018
text icon Publications & Presentations
Colorado End of Life Options
Colorado Bar Association
eAlerts Updates
October 2016
text icon Publications & Presentations
Developments in Mental Health Care
Colorado Hospital Association
Health Care Regulatory Update; presentation given by Ann McCullough, regarding revision to the standards for emergency commitments, as well as access and reimbursement issues
January 13, 2015
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