Anne M. Haule

Anne’s practice includes general counsel representation of hospitals with emphasis on hospital/physician relations (fraud and abuse and self-referral issues), compliance, medical staff credentialing and hearings, EMTALA representation before PROs and negotiating settlements with the OIG, transactional advice regarding joint ventures, affiliations and disaffiliations and managed care contracting issues. Anne’s practice also includes representation of other health care providers including imaging centers, skilled nursing facilities, assisted living centers, home health agencies and physician group practices. In addition to health care advice, Anne’s practice also includes providing antitrust advice to health insurers and multi-provider networks. Anne is also a skilled trainer and enjoys educating Boards and senior management.

Prior to joining Ungaretti & Harris, Anne served as Regional Counsel for the nation’s largest proprietary hospital chain with responsibility for legal operations matters for numerous hospitals, surgery centers, and home health agencies throughout the country. Her experience included virtually all aspects of health law plus client counseling with respect to governmental investigations and corporate compliance. She also served as General Counsel for an inner-city community hospital with responsibility for all legal matters as well as board education and risk management. Additionally, Anne served as Associate General Counsel for a major academic teaching hospital and medical center in Chicago with responsibility for corporate health law matters and litigation management.

Her experience includes having:

• Developed and implemented various compliance initiatives within healthcare systems, including physician contract audits, physician contracting guidelines, and model contracts.
• Provided regulatory and transactional advice on cutting edge hospital/physician joint venture for neuroscience, cardiac and rehabilitation centers of excellence.
• Provided education to various hospital Boards on hospital/physician compliance issues, fiduciary duty, conflict of interest and medical staff responsibility.
• Developed management training program for hospital executives with case studies and interactive sessions on fraud and abuse and self-referral issues.
• Represented medical executive committees and hearing panels in a variety of medical staff credentialing matters including hearings and appeals and has also negotiated numerous settlements without hearings.
• Represented hospitals and physicians in EMTALA investigations, drafted plans of correction, prepared testimony before the PRO and negotiated settlements with the OIG.
• Provided antitrust counsel to hospital clients on virtual mergers and managed care contracting price-fixing issues.
• Represented major insurance company executives in drafting testimony and appearing before the FTC and in responding to FTC subpoenas regarding ongoing price-fixing investigation of major health system and FTC investigation of merger of major insurance companies.

Anne has been quoted in numerous publications, including:

• Chicago Tribune, "Doctors took MRI kickbacks, suit says," January 18, 2007
• Wall Street Journal, Cleveland Clinic Defends Gift From a Vendor," August 8, 2006
• Physician Compensation Report, concerning Hospital-Physician Gainsharing, October 2005
• Radiology Administrator's Compliance & Reimbursement Insider, concerning compliance strategies for imaging center lease agreements, July 2005
• Health Care Auditing Strategies, concerning the release of an FTC/DOJ report advocating the abolition of Certificate-of-Need Laws, June 2005
• Wall Street Journal, "MRI and CT Centers offer Doctors Way to Profit on Scans", May 2, 2005
• Modern Healthcare, concerning the release of an FTC/DOJ report advocating the abolition of Certificate of-Need Laws, July 26, 2004