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Kristin M. Bohl


Kristin Bohl advises health care systems, hospitals and providers in compliance and regulatory issues.

Featured Videos

Physician Self-Referral (Stark) Law and Anti-Kickback Final Sprint Rules: Understanding the Impact December 3, 2020
COVID-19 Outbreak: Understanding the Physician Self-Referral Law 1135 "Blanket" Waiver April 8, 2020

Professional Biography

Ms. Bohl advises hospitals, health care systems, and providers in compliance and regulatory issues, with particular emphasis on fraud and abuse matters as well as recently implemented Medicare payment models. Drawing on her experience in the federal government, she counsels clients on actual and potential compliance concerns that arise on a day-to-day basis as well as offers assistance navigating more serious concerns that require a more extensive plan of action to address. With the changes to Medicare reimbursement under the Quality Payment Program (QPP), Ms. Bohl advises clients participating in both Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs).

Ms. Bohl assists clients with analysis of issues involving the Stark physician self-referral statute, the Anti-Kickback Statute, and Medicare payment policy. She advises clients on arrangements among health care providers, internal compliance issues, communication with the federal government related to compliance issues including the submission and resolution of voluntary disclosures to the OIG and CMS self-disclosure protocols when necessary. She provides guidance on the legal aspects of health systems operations and drafts and implements compliance programs and policies.

New issues for clients to consider continue to arise as CMS continues to develop new payment systems and bundled payment programs. Participation in the Quality Payment Program presents new concerns and sometimes requires new strategies for success. As part of the Bundled Payment Team at Baker Donelson, Ms. Bohl assists clients to decipher the path forward in compliance with program rules as well as applicable fraud and abuse limitations.

Prior to entering private practice, she served as the Technical Advisor in the Division of Technical Payment Policy at the Centers for Medicare & Medicaid Services (CMS) where she worked on Stark Law policy. During her tenure at CMS, she was part of the team that developed and implemented aspects of the Stark Law, including the CMS Voluntary Self-Referral Disclosure Protocol. Her work also included the analysis and resolution of self-disclosures submitted pursuant to the protocol.

Ms. Bohl also provided technical assistance in the development of waivers of the Stark law for various Accountable Care Organizations (ACO) models, including the Medicare Shared Savings Program (MSSP) and other payment initiatives within CMS's Center for Medicare & Medicaid Innovation.

Ms. Bohl also brings experience from the provider's perspective. She was a registered nurse who, before attending law school, worked at Johns Hopkins Hospital and Memorial Sloan Kettering Cancer Center.

Professional Memberships

  • Member – American Health Law Association
    • Hospitals and Health Systems Practice Group
      • Editorial Board
      • Leadership Development Program
    • Mentoring Program
    • Public Interest Contributor
  • Member – American Bar Association
    • Health Law Section
  • Member – Maryland State Bar Association
  • Member – Anne Arundel Bar Association
  • Technical Advisor, Centers for Medicare & Medicaid Services
    • Division of Technical Payment Policy
  • Registered Nurse, Memorial Sloan Kettering Hospital
  • Registered Nurse, Johns Hopkins Hospital
  • Presenter – "Be Prepared: How the Proposed Stark and Anti-Kickback Regulations Impact Hospitals," Nashville Council of Health Care Attorneys (November 2019)
  • "Proposed Rules to Stark Law and Anti-Kickback Statute: What the Future Holds," Developments and Trends in Health Care Law 2019, Cumberland School of Law and Health Law Section of the Alabama State Bar (September 2019)
  • Presenter – "You Need to Worry About the Stupid Things," Healthcare Financial Management Association, Maryland Chapter 2018 Spring Conference (March 2018)
  • Presenter – "MACRA and Medicare Payment - Advanced APMs, Part 2," Webinar (January 2018)
  • Moderator – "MACRA and Medicare Payment - Medicare Incentive Payment System (MIPS), Part 1," Webinar (January 2018)
  • Presenter – "MACRA: Review of Proposed Changes to MIPS and Advanced APMs for 2018," AHLA webinar for the Regulation, Accreditation, and Payment Practice Group (August 2017)
  • Presenter – "The Quality Payment Program: What It Is and Why You Should Care," ABA Health Law Section 2017 Physicians Legal Issues Conference (June 2017)
  • Co-presenter – "The Stark Law: What Has Changed, What Remains the Same, and What Might Come Next," ABA Health Law Section 2017 Physicians Legal Issues Conference (June 2017)
  • Presenter – "The Impact of the Finalized Modifications to the Stark Law," Webinar, LeClairRyan (2015)
  • Presenter – "Effective Peer Review as Your Best Defense to Fraud and Abuse," Annual Meeting, American Health Law Association (2014)
  • Presenter – "Practitioner's Toolkit for Addressing 'Technical Violations of the Stark Law," AHLA Hospital and Health Systems Law Institute (2013)

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