Diploma, University of Virginia School of Law, 2009
B.A., Northwestern University, 2000
Susan Banks is a counsel in the Health Care Practice Group in Dentons US LLP's Washington, D.C. office, and was recently named one of Super Lawyers' Washington, D.C. Rising Stars in Health Care. In her practice, Banks advises healthcare providers and suppliers on the full range of Medicare and Medicaid compliance and reimbursement issues, including issues involving the calculation of prospective payment system rates and coverage and billing rules for various items and services in the rapidly evolving federal regulatory landscape. She has particular experience regarding issues related to graduate medical education reimbursement. She also advises clients regarding participation requirements under the 340B Drug Discount Program. Recent representative engagements have included advising clients regarding Medicare’s outpatient physician supervision requirements, billing rules for outpatient observation services, medical necessity of inpatient admissions, physician signature requirements on orders for items and services, and issues related to "provider-based" status.
Banks also assists clients in conducting internal reviews to evaluate the existence of potential overpayments, and to make appropriate self-disclosures and voluntary refunds to federal payors. Banks has experience advising and defending clients in litigation and investigations involving alleged instances of fraud and abuse in federal healthcare programs arising under the federal False Claims Act, the Anti-Kickback Statute, and the physician self-referral statute and its implementing regulations, commonly referred to as the Stark Law. She represents clients in connection with investigations and audits undertaken by federal and state regulatory and enforcement agencies, including the U.S. Department of Justice, the U.S. Department of Health and Human Services Office of Inspector General, the Centers for Medicare and Medicaid Services and its contractors, and the Health Resources and Services Administration.
Banks regularly drafts comment letters advocating on behalf of her clients before various state and federal administrative bodies and assists providers with appeals before the Provider Reimbursement Review Board, administrative law judges and in federal courts.