Sara Kay Wheeler
practices exclusively in the area of health law where she advises a diverse array of organizations including health systems, academic medical centers, health plans, faculty practice plans and entities involved in the drug delivery system, including retail pharmacies (chain pharmacies and large retailers with pharmacy operations), specialty pharmacies, pharmacy benefit managers and retail clinics. She has extensive experience in the creation and implementation of corporate compliance programs and investigations, government contractor audits (including RACs, MACs, MICs, PSCs and ZPICs), Medicare regulation (including Medicare Part D issues), Medicaid regulation (including managed care, audit and enforcement matters), fraud and abuse concerns, internal investigations, voluntary disclosure strategies, clinical research compliance, privacy matters and managed care arrangements. Ms. Wheeler also works with King & Spalding’s Special Matters Group to defend healthcare providers that are investigated by federal and state enforcement entities. Ms. Wheeler has authored numerous publications in the healthcare trade press and regularly speaks on a wide variety of industry topics. Ms. Wheeler is Certified in Healthcare Compliance.
Ms. Wheeler currently serves as Second Vice President on the Health Care Compliance Association (HCCA) Board of Directors, is a member of the HCCA Executive Committee and previously served as HCCA Treasurer and HCCA Secretary. Ms. Wheeler is a past president of the Georgia Academy of Healthcare Attorneys, and chaired the Advisory Council for the Health Law Partnership (HeLP), a collaboration among the Georgia State University College of Law, the Atlanta Legal Aid Society and Children's Healthcare of Atlanta. She is also a graduate of the Leadership Georgia Program.
Memberships
2010-2011 Class of Leadership Georgia
American Health Lawyers Association
Moderator, AHLA Compliance List Serve
Atlanta Speech School Guild, Volunteer and Board Member, 2002-2005; Gala Co-Chair, 2004
Georgia Academy of Healthcare Attorneys
Past President, 2007-2008; President, 2006-2007; President-Elect, 2005-2006; Secretary/Treasurer, 2004-2005; Board of Directors, 2001-2005
Member, 1992-Present
Healthcare Financial Management Association (HFMA)
Health Care Compliance Association
Board of Directors, 2009-2014
Second Vice President
Member of Executive Committee
Co-Chair, Southeast Regional Conference, 2006-2013
Former Board Secretary
Former Board Treasurer
Co-Chair, Southeast Regional Conference, 2006-2011
Health Law Partnership (HeLP), Chair, Advisory Council, 2004-2006
The Junior League of Atlanta, Atlanta Speech School Liaison 2006-2007; District Chair, 2004-2005; District Chair-elect, 2003-2004; District Advisor, 1998-2004; Member, 1994-2005
National Association for Medicaid Program Integrity (NAMPI), Member, 2009 - Present
The American Association of Nurse Attorneys, Member, 1997-2005
The University of Pennsylvania, Alumni Secondary School Committee
Wake Forest Law Alumni Council
Publications
“Scales Tip in Favor of 68% Pay for Denied Claims, but Hospital Finds It’s a Lot of Work,” Report on Medicare Compliance, September 15, 2014
“Navigating the Medicare Appeals Process ALJ decisions on owarding Part B Payment,” Dennis Barry's Reimbursement Advisor, co-authored with Stephanie F. Johnson, November 2012
“2012 OIG Work Plan: Part 2, Additional OIG Reviews,” HCCA Compliance Today, Volume 14, Number Two, co-authored with Stephanie Johnson, February 2012
“2012 OIG Work Plan: Part 1, Priorities by provider and supplier type,” HCCA Compliance Today, Volume 14, Number One, co-authored with Stephanie Johnson, January 2012
“Utilize RAC Delay to Prepare for Audits; CMS Uses Different Tactics for MICs, RACs,” The HCCA-AIS Medicaid Compliance News, Volume 5, Number 3, co-authored with Kate Stern, March 2011
"2011 OIG Work Plan, Part 2: Additional Areas of Focus," Health Care Compliance Association Compliance Today, co-authored with Stephanie L. Fuller, February 2011
“Meet the Fraud Busters: Program Safeguard Contractors and Zone Program Integrity Contractors,” Journal of Health & Life Sciences Law, co-authored with Stephanie L. Fuller, and J. Austin Broussard, February 2011
"2011 OIG Work Plan: Projects reflect shifting regulatory environment, Part 1," Health Care Compliance Association Compliance Today, co-authored with Stephanie L. Fuller, January 2011
“ZPICs: Strategies for Medicare Audits Meeting New Fraud and Abuse Enforcement Challenges,” co-presented with Steve Lokensgard , Strafford Publications Live Webinar, July 29, 2010
“Compliance Officer Roundtable: American Health Lawyers Association Fraud and Compliance Forum,” presented with Alana B. Sullivan, Kim Lansford, and Sara Kay Wheeler, Journal of Health & Life Sciences Law, April 2010
January 2010 HCCA Compliance Today, “2010 OIG Work Plan: Providing the Script for OIG Review,” co-authored with Tizgel High
“A Compliance Officer’s Guide to the Stark Laws and Regulations,” The Health Care Compliance Professional’s Manual, Health Care Compliance Association (HCCA), co-authored with Kim Roeder, Kate Stern and Kinshasa Williams, July 2009
“Medicaid Integrity Are You Ready for the MIC Movement?” Dennis Barry's Reimbursement Advisor co-authored with Tizgel High, October 2009
18th Annual King & Spalding Health Law and Policy Forum: “Hot Topics” In Healthcare Fraud Enforcement - Administrative. Interview with Kim Roeder, The Metropolitan Corporate Counsel magazine, April 2009.
“Understanding the Golden Carrot: Voluntary Disclosure Strategies after the April 15, 2008, OIG Open Letter,” Journal of Health Care Compliance, co-authored with Tizgel High, Sept/Oct, 2008.
“Medicaid Auditors Soon to Follow RACs,” HcPro, Inc.’s Healthcare Auditing Weekly, September 2008
“CMS Sheds Light on the New Medicaid World,” AHLA Member Briefing, November 2007“
CMS Posts Enforcement, Audit and Corrective Action Plan Summaries,” PoGo Alert, co-authored with Kim Roeder, October 2007
“Establishing Physician Protocols,” Counsel to Counsel Magazine, co-authored with Kim Roeder, October 2007
“Proposed Stark Amendment Targets Physician-Owned Hospitals,” PoGo Alert, co-authored with Kinshasa Williams, August 2007
“Medicaid Enforcement Amidst the Perfect Storm,” Journal of Health Care Compliance, co-authored with Tizgel High, July - August 2007
“CMS Document Sheds Light On The New Medicaid World,” AHLA.com, co-authored with Sandra Herron, July 2007
“Chapter Five of CMS' Prescription Drug Benefit Manual: Benefits and Beneficiary Protections,” American Health Lawyers Association Member Briefing, co-authored with Benjamin Erwin, May 2007
Speaking Engagements
“Hot Topics in Healthcare Compliance,” Tennessee Hospital Association (THA) Fall Compliance Conference, Nashville, TN, October 10, 2014
“Compliance Lessons Learned From Recent CIA Developments,” The King & Spalding University e-Learn Pharma Series Interactive Web Seminar, co-presented with Seth H. Lundy and Michael E. Paulhus (King & Spalding), August 28, 2014
“The Keys to an Effective Compliance Program,” King & Spalding 2014 Compliance Summit, co-presented with Alana Sullivan (Erlanger Health System) and Robin Sangston (Cox Communications), Atlanta, GA, May 7, 2014
“The 2014 IPPS Inpatient Admission Rule: Beneficial or Bedlam,” Health Care Compliance Association (HCCA) Southeast Regional Annual Conference, co-presented with Joan Ragsdale (MedManagement) and Terri Yancey (Community Health Systems Professional Services Corporation), Atlanta, GA, January 24, 2014
“Why the Two-Midnight Rule Won't Solve the Turbulent RAC Program,” King & Spalding 20th Annual Health Law and Policy Forum, co-presented with Allison Kassir, Christopher Kenny and Mark Polston (King & Spalding), Atlanta, GA, March 17, 2014
“Regulatory, Compliance and Legislative Update for Inpatient Rehabilitation Providers,” North West Association of Rehabilitation Facilities (NWARF), co-presented with Jane Snecinski of Post Acute Advisors, Seattle, WA, October 25, 2013
“Bracing for Change: Medicare’s Final Hospital Payment Rule for FY 2014,” King & Spalding Healthcare Roundtable, co-presented with Daniel Hettich, Mark Polston, and Donna Thiel (King & Spalding), Atlanta, GA, September 9, 2013
“Hot Topics in Healthcare Compliance,” Tennessee Hospital Association Fall Compliance Conference, , Nashville, TN, September 5, 2013
“A Conversation With A Healthcare Fraud Defense Team: Current Issues Facing Healthcare Providers,” King & Spalding Healthcare Roundtable, co-presented with Joe Lynch, Michael Paulhus, Adam Robison and Rick Shackelford (King & Spalding), Atlanta, GA, August 23, 2013
"Understanding Audit Error Rates: How are we doing?,” HCCA's 17th Annual Compliance Institute, co-presented with Tim Renjilian (FTI Consulting), National Harbor, MD, April 22, 2013
"Update on Attorney Client Privilege: Practical Tips From Rulings in Halifax Medical Center," Tennessee Hospital Association (THA)/ East Tennessee Health Care Fraud Working Group, Knoxville, TN, April 2, 2013
“The Regulatory and Compliance Update: 2013 Begins With A Bang!,” Tennessee Hospital Association (THA)/East Tennessee Health Care Fraud Working Group, co-presented with Phyllis B. Sumner (King & Spalding), Knoxville, TN, April 2, 2013
“Beware of Wolves in Sheep’s Clothing: Exploring CMS Ruling and Proposed Rule on Part B Rebilling Issues,” King & Spalding Healthcare Roundtable, co-presented with Dennis Barry and Mark Polston (King & Spalding), Atlanta, GA, March 26, 2013
“Hot Developments in Medical Necessity,” King & Spalding 19th Annual Health Law and Policy Forum, co-presented with Donna K. Thiel, (King & Spalding) Atlanta, GA, March 18, 2013
“Understanding Audit Error Rates: How are we doing and what do we do next?,” Health Care Compliance Association (HCCA) Southeast Regional Annual Conference, co-presented with Tim Renjilian (FTI Consulting); Atlanta, GA, January 25, 2013
“Government Contractor Audits & Disputes: Recent Developments and Practical Strategies,” Institute of Continuing Legal Education in Georgia (ICLE) Health Care Fraud Institute, Atlanta, GA, December 13, 2012
“Compliance Issues in Post-Acute Care: Avoid Getting in the ‘Hot’ Seat,” Health Care Compliance Association's South Central Regional Conference, Nashville, TN, November 30, 2012
“Hot Topics,” Tennessee Hospital Association Fall Compliance Conference, Nashville, TN, September 21, 2012
“Medicaid RACs Are On The Scene: Are You Ready?,” Regional Online RAC Summits,
September 2012
“Recent Medicaid Developments Resulting from the Implementation of and the Supreme Court's Ruling on PPACA, Enforcement Activities, and Other Medicaid Reforms,” King & Spalding Healthcare Roundtable, co-presented with Allison Kassir, Adam Robison and Kim Roeder, (King & Spalding) Atlanta, Georgia, August 24, 2012
“Legal Update ,” The First National Medicare-Medicaid Payment Incentives and Penalties Summit, Washington, DC, May 31, 2012
“Developments in Medicaid Enforcement, Audits & Compliance,” Georgia Academy of Healthcare Attorneys (GAHA) Annual Meeting, Atlanta, GA, May 11, 2012
“Exploring CMS’s Proposed Rule on Reporting and Refunding Overpayments: Complex Challenges for Providers and Suppliers,” Tennessee Hospital Association (THA) Webinar, co-presented with Rick Shackelford and Greg Etzel (King & Spalding), April 23, 2012
“Everything You Want to Know About Billing Audits: How to Prepare and Respond ,” National Investment Center for the Seniors Housing & Care Industry’s (NIC’s) Skilled Nursing Investment Forum 2012, co-presented with Paul Nevala (GE Healthcare), Nancy Truver (GE Healthcare) and Richard Brame (Regency Health Management), Boca Raton, Florida, March 26, 2012
“Compliance in the Era of Health Reform: A Panel Discussion,” MedeAnalytics Live Webinar, co-presented with Greg Radinsky (North Shore-LIJ Health System), Jerry Williamson, MD and Barbara Piascik (MedeAnalytics), March 22, 2012
“Healthcare Industry: Hot Developments in Enforcement and Compliance,” Georgia State University Law School, March 20, 2012, co-presented with Michael Paulhus (King & Spalding)
“Turning Up The Heat on Medicaid Compliance: Is Your Organization Prepared?,” Health Care Compliance Association (HCCA) Southeast Regional Annual Conference, co-presented with Robert M. Finlayson, III (Inspector General, Georgia Dept. of Community Health) and Alana Sullivan (Senior Vice President & Chief Compliance Officer, Erlanger Health System), Atlanta, GA, January 20, 2012
“Overpayments and Refund Strategies in 2011: Time to Address New Healthcare Reform Strategies,” Georgia Chapter HFMA C.A.R.E. Fall Forum, Macon, Georgia, October 5, 2011
“Addressing Overpayments and Refunds: Practical Strategies in Light of Healthcare Reform Requirements,” Tennessee Chapter HFMA Fall Forum, Gatlinburg, Tennessee, October 13, 2011
“Regulatory and Compliance Update: Hottest Topics Right Now!,” Tennessee Hospital Association (THA) Fall Compliance Conference, Nashville, Tennessee, October 14, 2011
“New ZPIC Medicare Audits: Are You Ready? Preparing for Heightened CMS Enforcement Against Fraud and Abuse,” co-presented with Steve Lokensgard, Strafford Publications Live Webinar, August 11, 2011
“The New Alphabet Soup of Contractors,” Arkansas Hospital Association 2011 Compliance Forum, Little Rock, Arkansas, April 21, 2011
“Voluntary Disclosure and Overpayment and False Claims Act Liability,” Health Care Compliance Association’s (HCCA) 15th Annual Compliance Institute, Orlando, FL, April 13, 2011
“Medicaid RACs are on the Way: Tips and Guidance to Protect Your Payments,” Compliance 360 Live Webinar, March 30, 2011
“Overpayments and Refund Strategies in 2010: Time to Address New Healthcare Reform Strategies,” Georgia Chapter HFMA C.A.R.E. Forum Educational Conference, March 17, 2011
“Overview of the Medicaid Integrity Program,” The Fifth National Medicare RAC Summit, Washington, DC, March 10, 2011
“Take Charge of Contractor Chaos,” King & Spalding Healthcare Roundtable, co-presented with Richard L. Shackelford, Adam Robison and Kate Stern, (King & Spalding) Atlanta, Georgia, February 23, 2011
“Medicaid RACs: Get Ready ‘Cause Here They Come!” HCCA Web Conference, February 3, 2011
“Medicaid Audit Recovery Initiatives: The Plot Thickens with Medicaid RACs,” Health Care Compliance Association (HCCA) Southeast Regional Annual Conference, co-presented with Robert M. Finlayson, III (Inspector General, Georgia Dept. of Community Health), Gwyn E. Walters (VP for Research & Reimbursement, Tennessee Hospital Association) and Elisa White, Esq. (VP & General Counsel, Arkansas Hospital Association), Atlanta, GA, January 21, 2011
“HealthCare Reform and Other Burning Compliance Considerations,” Health Care Compliance Association (HCCA) South Central Regional Annual Conference, co-presented with Kate Stern (King & Spalding), Nashville, TN, November 12, 2010
“New ZPIC Audits: Are You Ready?: Preparing for Heightened CMS Enforcement Against Fraud and Abuse,” American Health Lawyers Association (AHLA) Webinar regarding Medicare Claims Appeals: What Providers Need to Know about MACs, RACs, and ZPICs, co-presented with Dawn G. Benson (Associate Counsel, Phoebe Putney Health Systems, Inc.) Donna K. Thiel (Partner, Baker Donelson), October 19, 2010
“HealthCare Reform and Other Burning 2010 Compliance Considerations,” Tennessee Hospital Association (THA) 2010 Fall Compliance Conference, Nashville, TN, October 1, 2010
“Compliance Officer Roundtable: Significant Challenges in 2010 and Practical Solutions,” American Health Lawyers Association (AHLA) Fraud & Compliance Forum, Baltimore, MD, co-presented with Alana Sullivan (Vice President & Chief Compliance Officer, Erlanger Health System) Kim Lansford (Vice President, Compliance and Internal Audit (Catholic Health East), September 26-28, 2010
“ZPICs: Strategies for Medicare Audits Meeting New Fraud and Abuse Enforcement Challenges,” presented with Steve Lokensgard, Strafford Publications Webinar, July 29, 2010
“RACs, MICs, ZPICs: How Deep and High is the Audit Pile?” American Health Lawyers Association (AHLA) Annual Meeting, Seattle, WA, co-presented with Joanne B. Erde, (Duane Morris), Ronald S. Connelly, Principal, (Powers Pyles Sutter & Verville PC), June 27-June 30, 2010
“Medicaid Integrity Contractors: Best Practices to Prepare and Appeal.” HCPro, Inc. Live Audio-conference, May 17, 2010
“The Compliance Department and MIC Audits,” Arkansas Hospital Association’s 2010 Compliance Forum, Little Rock, AR, May 5, 2010
“Update on RACs, MICs, ZPICs and Other Contractors,” Health Care Financial Management (HFMA) Annual Conference (Hawaii Chapter), Honolulu, HI, April 27 - 28, 2010
“Revenue Integrity and Safeguarding: Comprehensive Strategies for Contractor Combat (RACs, MICs, ZPICs and Others,)” HCCA Compliance Institute, Dallas, Texas, co-presented with Christopher Thomason (Vanderbilt University Medical Center “Managing Medicaid MIC Audits and Appeals, An Operational Guide,” Compliance 360 Webinar, March 23, 2010
“The Evolving Landscape of Government Audits and Investigations: Are You Prepared for Contractor Combat?” King & Spalding Annual Healthcare Forum, co-presented with Glen Moyers, KPMG, March 15, 2010
“The Medicaid Integrity Program and Medicaid Integrity Contractors,” Health Care Conference Administrators, L.L.C., The Third National Medicare RAC Summit, Washington, D.C., March 4, 2010
“The Government Contractor Conundrum: Questions and Answers,” Health Care Compliance Association Southeast Regional Meeting, Atlanta, Georgia, co-presented with Curtis Watkins (AdvanceMed Corporation), Elizabeth Schoen (Georgia Hospital Association) and Stephen Johnson (Erlanger Health System), January 15, 2010
“FDA’s New Final Rule on Expanded Access to Experimental Drugs: What Providers Need to Know Now, Managing Risks of Patient Expectations for Access,” King & Spalding Healthcare Roundtable, Atlanta, Georgia, November 20, 2009
“Revenue Integrity: Preparing for Contractor Combat,” East Tennessee Fraud Working Group 2009 Fall Compliance Conference, October 21, 2009
“Medicaid Integrity Contractor Audits: Know What to Expect and How to Prepare,” HCPro, Inc. Live Audio-conference, co-presented with Jim Sheehan (New York Medicaid Inspector General), October 15, 2009
“Compliance Officer Roundtable - Advanced Compliance Topics,” AHLA/HCCA Fraud and Compliance Forum, Planning Committee Member and Speaker, co-presented with Kim Lansford, Catholic Health East, and Alana Sullivan, Erlanger Health System, October 4-6, 2009
“Important Developments in Voluntary Disclosure Strategies,” HCCA/SCCE Audio Web Conference, Joint Presentation with Susan L. Walberg, MedStar Health System, May 14, 2009
“A ‘Perfect Storm’ in Fraud Enforcement? False Claims Act Expansion, Audit Contractor Employment, Self-Disclosure Developments and Fortified Enforcement Priorities,” King & Spalding Healthcare Roundtable, Atlanta, GA, co-presented with Chris Burris, Steve Cowen, Mike Paulhus, Kim Roeder and Rick Shackelford, July 17, 2009
“Recent Developments in Voluntary Disclosure Strategies,” HCCA 13th Annual Compliance Institute, co-presented with Tamar V. Terzian, Esq., Office of the Inspector General and David M. Glaser, Esq., Fredrikson & Byron, April 26-29, 2009
“Hot Topics in Healthcare Fraud Enforcement,” King & Spalding Annual Healthcare Forum, co-presented with Steve Cowen, King & Spalding, Kim Roeder, King & Spalding, February 17, 2009
“Medicaid Risk Areas: Strategies for Auditing Enforcement Targets,” HCPro, Inc. Live Audioconference, Joint presentation with Brian Flood, KPMG, January 29, 2009
“Voluntary Disclosure Strategies,” Health Care Compliance Association Southeast Regional Meeting, co-presented with Robert Finlayson, Inspector General, Georgia Dept. of Community Health and Amy Berne, U.S. Attorney’s Office, Northern District of Georgia, January 9, 2009
“Medicare Part D: How to Ensure Your Appeals, Grievances, Determinations and Reconsiderations Meet CMS Requirements,” Health Care Compliance Association Medicare Prescription Drug Part D Compliance Conference, co-presented with Kirk Dobbins, King & Spalding LLP, December 7-9, 2008
“Getting Ahead and Staying Ahead of Medicare RACs and Other Program Integrity Contractors,” King & Spalding Healthcare Roundtable, co-presented with Richard Shackelford, Kirk Dobbins, Laura Loeb and Stephanie Webster, King & Spalding LLP, October 20, 2008
“Current Legal Issues in Clinical Research,” King & Spalding LLP Drug & Device Roundtable, co-presented with Kirk Dobbins, Kim Roeder, Laura Loeb and Beverly Lorell, King & Spalding, June 27, 2008
“Treatment for Sale: Rethinking Provider-Vendor Relationships,” GAHA Health Law Update and Annual Meeting, May 7, 2008
Health Care Compliance Association's 12th Annual Compliance Institute “Identifying and Controlling Individual and Institutional Conflicts of Interest,” New Orleans, LA, April 13-16, 2008. co-presented with Sylvia Friedl, Research Compliance Officer, University of Tennessee College of Medicine
“Advanced Compliance 2008 Challenges and Strategies,” HCCA Southeast Local Annual Conference, February 29, 2008
“Clinical Research: Responsibility, Liability and Credibility,” UTCOM, Chattanooga, TN Annual Research Compliance Update, February 28, 2008
“Medicaid Compliance: Strategies to Assess the Top Risk Areas, HCPro, Inc. Live Audioconference, co-presented with Michael Mangano and David Butler, Strategic Management Systems, February 20, 2008
“2008 Medicaid Update: Enforcement and Regulatory Developments,” HFMA Winter Institute, January 24-25 2008
“Compliance Update,” East Tennessee Fraud Working Group Tennessee Hospital Association Fall Compliance Conference, October 2007
“Medicaid Compliance: Get Ready for the Enforcement Revolution,” HCPro, Inc. Audioconference, Joint presentation with Doug Colburn of OIG and Rebekah Casteel Latchis of Bon Secours, August 2007
“Clinical Research Compliance: Hospital Assessment and Integration Strategies,” Georgia Hospital Association's Compliance Officer Roundtable, July 2007
“Regulatory and Enforcement Update: Medicare Part D,” Financial Research Associates, LLC's, Medicare Compliance and Operations Summit 2007, July 2007
“Managing Compliance Investigations,” Blue Cross Blue Shield 2007 Compliance and Ethics Conference, June 2007
“Practical Effects of the DRA: Medicaid Enforcement Developments and Compliance Strategies,” HCCA's 11th Annual Compliance Institute, April 2007
“Medicaid Integrity in 2007: Is Your House in Order?,” HCCA Southeast Local Annual Conference, February 2007
