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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 over 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, telehealth and regulatory compliance.

  • Advising hospital clients regarding COVID-19 strategies, including EMTALA, Temporary Expansion Sites, Acute Hospital Care at Home, Telehealth, and Disaster Privileges. 
  • Developing strategy for telehealth, including reimbursement, medical staff telehealth privileges and agreements for telehealth services.   
  • 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, unified medical staffs, 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.
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