Shannon is not only the founder of Recycled Doggies, but she is also an active volunteer and foster mom for the Cincinnati-based nonprofit dog rescue. She especially loves to foster the sick and elderly dogs that have been cast off by prior owners, nursing them back to health and finding them loving forever families.
Shannon DeBra's practice emphasizes health care compliance, regulatory, and fraud and abuse matters. She works with health care providers to conduct compliance audits and internal investigations, as well as to put together voluntary disclosures to the U.S. Attorney’s Office, Office of Inspector General (OIG), and/or Centers for Medicare & Medicaid Services (CMS) when potential violations of law are discovered. She assists in implementing Corporate Integrity Agreements (CIA), creates new compliance policies and procedures, and reviews compliance procedures for consistency with OIG provider compliance guidance and CIA requirements. She has defended health care providers in sealed qui tam cases, including developing defense strategies and leading settlement discussions with the U.S. Department of Justice (DOJ). Additionally, Shannon advises on clinical research matters, school-based Medicaid, and 340B drug program compliance and management.
From November 2003 to January 2006, Shannon served as senior counsel in the Office of Counsel to the Inspector General, U.S. Department of Health and Human Services, in Washington, D.C., and represented the Inspector General in the resolution of civil False Claims Act (FCA) cases. She also worked with the DOJ in the investigation, development and resolution of FCA cases; investigated, developed and negotiated resolution of civil monetary penalty cases; and reviewed legal sufficiency of proposals for provider exclusion under the federal health care programs. Shannon has also worked as an assistant general counsel for the Commonwealth of Massachusetts, Division of Medical Assistance (the Massachusetts Medicaid Agency). In addition, she served as Chief Compliance Officer for UC Health in Cincinnati from 2012–2013.
"I commend Shannon DeBra and Chris Bennington on the work they did on behalf of our medical center regarding our compliance program. Their review and corresponding recommendations have been well-received by our staff and will provide a definitive roadmap for our compliance program."
"We have worked with Shannon DeBra and Chris Bennington for numerous years on countless compliance projects and concerns. The professionalism, knowledge and experience they bring to the table is immeasurable. They integrate themselves as if they are part of your team and truly work to provide counsel and guidance as if it were their own organization."
Hospital transition to orthopedic-only center
Assisted a health system in transitioning a hospital campus into a specialty services center, which required engaging physicians on the center’s medical staff to participate in quality improvement and cost reduction efforts. Developed, negotiated and prepared legal structure and contractual arrangements for the health system to engage physicians and ensure compensation at fair market value for these efforts.
Health system COVID-19 response
Provided 24/7 support to a health system responding to the COVID-19 pandemic. Advised the system on federal and state regulations, including waivers issued as a result of the public health emergency declaration. Also advised on staffing, compensation, quality and patient care issues, as well as expanding telehealth abilities and related reimbursement issues.
Clinical trial documents
Negotiated clinical trial documents on behalf of a nonprofit health system.
Clinical research budgeting
Advise health system on fraud and abuse considerations in developing a budget for clinical trials.
Clinical research fraud and abuse
Advise a health system on fraud and abuse considerations related to a non-employed physician as the principal investigator.
Hospital qui tam defense
Defended a hospital and health system in a qui tam lawsuit filed by an employed physician. The lawsuit involved claims that the system submitted false claims to Medicare and Medicaid by billing for services that did not comply with the applicable National Coverage Determination. The suit was ultimately settled and dismissed.
Hospice Medicare challenge
Assisted a nonprofit hospice provider in successfully challenging revocation of its Medicare enrollment and termination of its Medicare provider agreement.
Clinical research contracting and compliance
Review clinical trial agreements and related documents, including non-disclosure agreements and informed consent forms, for hospitals engaged in the conduct of clinical research. Advises hospital on critical provisions in clinical trial agreements, including subject injury, intellectual property, publication and indemnification. The firm has also assisted clients with a variety of compliance issues related to clinical research, including the Common Rule, billing, the Sunshine Act, conflicts of interest, FDA regulations and HIPAA.
Compliance program assessment, implementation and investigation
Conduct annual assessments of health care organization compliance programs and assist in the development and implementation of compliance programs for hospitals and managed care organizations. Annual compliance program evaluations are utilized by health care organizations to set annual improvement goals and to correct any identified deficiencies. The firm also conducts compliance investigations on behalf of health care organizations when the organizations determine that an outside investigation is preferable to an investigation conducted internally by the organization’s compliance department.
County hospital affiliation
Represented a county hospital that became affiliated with a large health care system, obtaining all regulatory approvals, overseeing self-disclosure of potential Stark issues and assisting with the payoff of outstanding bonds.
Professional & Community Activities
- Member, Health Care Compliance Association
- Member, American Health Law Association
- Founder, Recycled Doggies
Presentations & Published Works
- Speaker, "Stark Blanket Waivers and Anti-Kickback Compliance in a COVID-19 World," Ohio Hospital Association Webinar, October 2020
- Speaker, “How Effective is Your Compliance Program at Preventing, Detecting, and Addressing Potential Compliance Issues?” OSHRM/SOHA Fall Conference, September 2018
- Speaker, “Healthcare Legal Hot Topics,” OSHRM/SOHA Spring Conference, March 2018
- Speaker, “Freebies, Gifts & Referral Sources - When are they OK?” American Case Management Association, Ohio Chapter, March 2018
- Speaker, "Regulatory Compliance: What You Need to Know to Stay Out of Trouble," OSHRM/SOHA Fall Conference, September 2017
- Speaker, "Lessons from The Front Lines: Hot Topics in Research Compliance," Ohio Hospital Association Annual Meeting, June 2017
- Speaker, "Under Siege: When Government Agents Show Up at Your Hospital's Door with a Search Warrant," Ohio Hospital Association Annual Meeting, June 2017
- Speaker, “Provider-Based Clinics: What You Need to Know," Health Care Compliance Association Regional Conference, May 2017
- Speaker, "Compliance in the Post-Acute Care Environment," Ohio Health Information Management Association, March 2017
- Co-Author, "Post-Acute Network: The Discharge Planner's Dilemma," CareManagement Vol. 23, No. 1 February/March 2017
- Speaker, "OIG Medicare Compliance Reviews: A Compliance Officer's Guide to Survival," Health Care Compliance Association Regional Conference, October 2015
- Speaker, "Lessons Learned—How Compliance Officers Can Better Protect Their Organizations," Bricker & Eckler webinar, September 2015
- Speaker, "Getting into Compliance with Compliance Program Requirements for SNFs and NFs," Leading Age Ohio Annual Conference, September 2015; OHCA 2015 Annual Convention & Exposition, April 2015
- Speaker, "Weathering the Storm: One Hospital's Experience in Managing a HIPAA Crisis," Ohio Hospital Association Annual Meeting, June 2015
- Speaker, "Hospital System Growing Pains: A Compliance Officer's Guide to Risk Areas Resulting from Acquiring Physician Practices and Employing Physicians," Health Care Compliance Association Compliance Institute, April 2015
Bar Admissions & Activities
- Admitted, United States District Court for the Southern District of Ohio, 2019
- Admitted, State of Ohio, 2006
- Admitted, State of Massachusetts, 1998
- University of Massachusetts (M.B.A.), 2003
- Boston University (J.D.), 1998
- Boston University (B.S., summa cum laude), 1995
CMS and OIG finalize major changes to Stark and Anti-Kickback regulations: What health care entities need to knowMore
CMS and OIG issue long-awaited final rules changing the Stark Law, Anti-Kickback Statute and Beneficiary Inducement Civil Monetary Penalty LawMore
Webinar: Stark Law and Anti-Kickback Statute Final Rules – Exploring the major changes to fraud and abuse laws
- Monday, December 7, 2020 - Monday, December 14, 2020
- 12:00 PM to 1:00 PM