William J. Spratt, Jr.

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A former healthcare administrator, Bill Spratt represents large healthcare companies and private equity sponsors in multi-jurisdictional transactions, traversing complex state and federal laws and regulations. He counsels institutional and non-institutional healthcare providers including hospitals, ambulatory surgery centers, outpatient and urgent care centers, skilled nursing facilities, hospices, home health agencies, health maintenance organizations, clinical laboratories, radiation therapy centers, durable medical equipment companies, physician networks, and specialty physician groups.

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SCOTUS May Resolve Circuit Split on the Specificity Required of False Claims Act Claims: Relief or More FCA Grief for Providers?

By William J. Spratt, Jr., Jeremy Burnette and Lauren Gandle on Posted in Fraud & Abuse & False Claims Act
Currently, providers have different risks of potential False Claims Act (“FCA”) liability depending on where they are geographically located due to the difference in the standards required by the U.S. Courts of Appeals regarding the level of specificity when relators (whistleblowers) plead FCA violations.  The FCA imposes civil liability on any person requesting government funds … Continue Reading

Caveat Emptor: Private Equity Firms Are Increasingly Vulnerable to Qui Tam Lawsuits

By William J. Spratt, Jr. and Jeremy Burnette on Posted in Fraud & Abuse & False Claims Act, Healthcare M&A, Joint Ventures, Transactions & Health Ventures
The U.S. Department of Justice (“DOJ”) has settled six qui tam lawsuits brought in various jurisdictions by whistleblowers against a private equity firm and its portfolio healthcare companies. A group of diagnostic testing companies and the private equity firm, which held a minority investment interest in the parent, settled claims that they violated the False … Continue Reading

Limited Stark and Anti-Kickback Sanction Waivers Issued for Provider Payments During the Pandemic

By William J. Spratt, Jr. and Danielle C. Gordet on Posted in Healthcare Law, Healthcare Litigation, Hospitals & Health Systems, Physicians
The COVID-19 pandemic has led to urgent changes to how and where healthcare services are delivered. These changes could require expedited entry into new or modified arrangements for the delivery of essential healthcare goods and services, creating potential conflicts with the Stark Law (Section 1877 of the Social Security Act) and its regulations and potential … Continue Reading

Direct Patient Billing Can Create Provider Liability in Florida

By William J. Spratt, Jr. on Posted in Healthcare Law, Healthcare Litigation, Hospitals & Health Systems, Physicians
To bill or not to bill, that is the question. Or, more appropriately, who to bill and when to bill, that is the question. Providers who bill patients under the circumstances described below may face liability. What is a provider to do? A patient was injured in the course of her employment in December 2013 … Continue Reading

Owner of Medical Marketing Company Found Guilty in $2 Million Medicare Fraud Scheme…Again!

By William J. Spratt, Jr. on Posted in Fraud & Abuse & False Claims Act, Healthcare Law, Medicare & Medicaid
The Department of Justice announced on June 27, 2019 that David Brock Lovelace, the owner of DBL Management LLC, was found guilty by a federal jury in the U.S. District Court for the Middle District of Florida of conspiracy to pay healthcare kickbacks and structuring currency transactions to avoid reporting requirements. According to the evidence … Continue Reading

Florida Patient Brokering Act Amended – Does it Clarify or Create New Issues?

By William J. Spratt, Jr. on Posted in Fraud & Abuse & False Claims Act, Government Affairs, Licensure & Regulatory, Healthcare Law, Hospitals & Health Systems, Medicare & Medicaid, Physicians
The Florida Legislature recently passed HB 369 (the Bill), which would tweak an important provision of the Florida Patient Brokering Act, Section 817.505 of the Florida Statutes (Patient Brokering Act).  It seeks to clarify the exception to the Patient Brokering Act which incorporated by reference the criminal provisions of the federal Anti-Kickback Statute (42 U.S.C. … Continue Reading

Year in Review/Year Ahead: The Eliminating Kickbacks in Recovery Act of 2018-The New All-Payor Anti-Kickback Statute

By William J. Spratt, Jr. on Posted in Fraud & Abuse & False Claims Act, Health Insurers & Managed Care Organizations, Healthcare Law
The Akerman Healthcare Practice Group, as part of its ongoing informational blogs and Practice Updates, will be publishing a series of articles, each outlining a significant healthcare industry issue from 2018, with an eye towards what to expect in 2019.  The following is the first in our series – The Year in Review/The Year Ahead: … Continue Reading

Florida Department of Health Adopts New Telemedicine Rule: Florida Legislature Considers Changing the Law

By William J. Spratt, Jr. on Posted in Government Affairs, Licensure & Regulatory, Physicians
While the Florida Department of Health (DOH) adopted a new telemedicine rule on March 12, 2014 [Rule 64B8-9.0141 and Rule 64B15-14.0081 of the Florida Administrative Code], several bills on the same subject are under consideration by the Florida Legislature. [See, SB 1646, SB 0070, HB 751, and HB 0167]  At the same time, the Federation … Continue Reading
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