Cori Casey Turner

Regulatory Compliance

• Assisted preeminent research facility with the development of COVID testing innovation and research strategy, including analysis of FDA, EUA, LDT and PREP Act implications and community outreach contracts.
• Navigated complex federal and state licensing and credentialing laws related to development of integrative medicine clinic with medical, fitness, cosmetic and spa services. Assisted with project from ground up and provided structural and strategic guidance based on federal and state licensing considerations.
• Developed comprehensive compliance plan effectiveness audit tool used by healthcare providers across Midwest.
• Helped evaluate compliance with federal research regulations (informed consent/IRB issues), NIH Grants Policy Statement, and related federal regulations and investigations in area of pediatric and adult research.
• Advised compensation committee of healthcare system on compliance with Internal Revenue Service and healthcare regulatory requirements, including presentation of educational sessions for committee members and hospital's executive leadership team.
• Developed a multi-state guardianship and consent matrix and decision tool for client currently being utilized by providers in Colorado, Kansas, Montana, Utah and Wyoming to help front line personnel navigate sensitive and oftentimes highly controversial situations related to the terminally ill and end of life decisions, durable power of attorney and healthcare proxies, minor consent issues and guardianship.

Medicare and Medicaid

• Assisted with complex change of ownership (CHOW) applications for numerous facilities related to large acquisition of mental health facilities. Successfully worked with Centers for Medicare & Medicaid Services (CMS) representatives to navigate online and paper documents required for timely and smooth transition.

Contracting

• Assumed role of interim in-house counsel for international pharmaceutical service provider. Reviewed and negotiated contracts for contract research organization (CRO) services, pharmacovigilance services, HUB/commercial services, nursing services and patient assistance program services.
• Advised multihospital health system on all aspects of physician contracting, including contract development and negotiation, regulatory analysis and operational considerations.

Staffing

• Represented large health system in development of new systemwide physician employment agreement model and compensation methodology and facilitated transition of more than 100 employed physicians to new model.
• Evaluated quality bonus programs for employed and contracted physicians in adult and pediatric context, including facilitating valuation efforts and development of quality initiatives, benchmarks and bonus methodology.
• Collaborated with valuation experts to apply fair market value principles to pediatric employment, professional services and other affiliation arrangements.
• Assisted with operational practice/staffing review and development of comprehensive compensation model for exclusive anesthesia provider of large hospital.
• Led a lengthy and complex negotiation between anesthesiology group and hospital to facilitate the transition of 11 anesthesiologists and select clinical and operations staff to the hospital.

Investigations and Self-Disclosures

• Directed comprehensive audit and regulatory analysis of physician contracts at children's hospital and submitted Stark Law disclosure to CMS under self-referral disclosure protocol. Provided operational and corrective action recommendations related to audit findings.
• Helped settle Stark Law violation with Department of Justice (DOJ) and Office of Inspector General (OIG) for Department of Health and Human Services after four-year internal investigation, self-disclosure and extensive negotiations. Matter was resolved with no criminal charges, no admissions of False Claims Act violations, and no imposition of corporate integrity agreement or government oversight.

Other

• Assisted with development and structuring of primary care medicine concierge practice to address federal and state healthcare, reimbursement, insurance and privacy/data security issues.
• Represented healthcare businesses in evaluating and developing medical franchise strategy and associated disclosure documents/ancillary agreements.
• Advised on evaluation of multisite cloud-based patient information access portal proposed by concierge medicine franchise.