Christopher “CJ” Frisina

• Advising health care providers on compliance with the CARES Act Provider Relief Fund (PRF) requirements.
• Submitted an application to the HHS OIG that reinstated an OIG exclusion.
• Overturned a $8 million disallowance issued against an FQHC.
• Submitted proposed health care arrangements for an HHS OIG advisory opinions.
• Represented an independent review organization in a lawsuit against its accrediting agency.
• Drafted amicus briefs in the Medicaid Work Requirements and Public Charge cases in federal court.

Pro Bono Representation

• Appealed a provider’s exclusion from federal health programs before an HHS administrative law judge, the DAB, and in federal court.
• Appealed a district court’s denial of a petition for a writ of habeas corpus before the U.S. Court of Appeals for the Seventh Circuit.
• Appealed a district court’s denial of a motion to exclude evidence, arguing that law enforcement stopped the defendant’s vehicle without the reasonable articulable suspicion required by the Fourth Amendment.

Christopher “CJ” Frisina focuses his practice on health care regulatory matters, including compliance with federal and state anti-kickback statutes, the Civil Monetary Penalties, and the Stark Law. His past employment with the U.S. Department of Health and Human Services (HHS) and in private practice allow him to provide health care providers a unique perspective on regulatory and enforcement matters. CJ has experience assisting providers in developing compliant health care delivery programs and representing providers before the HHS Office of the Inspector General (OIG), Departmental Appeals Board (DAB), and in federal court, including under the Administrative Procedure Act. CJ assists clients on issue related to Medicare and Medicaid reimbursement, HHS OIG exclusions, graduate medical education arrangements and reimbursement, telehealth, suspension and debarment, and federal grant funding. CJ’s clients include hospitals, individual providers, pharmacies, home health agencies, and federally qualified health centers (FQHCs).

Before joining Alston & Bird, CJ practiced at a boutique Washington D.C. law firm addressing federal grant issues, and another corporate law firm focusing on health care fraud, waste, and abuse and white collar crime. CJ also worked for the HHS as a procurement analyst working on suspension and debarment matters. He earned his law degree and master of public policy from American University. Super Lawyers named CJ to its Rising Stars list for health care law in 2019.

Bar Admissions

• District of Columbia

Education

• American University (J.D., 2015)
• American University (M.P.P., 2015)
• Emmanuel Christian Seminary (M.A.R., 2011)
• Johnson University (B.A., 2008)

Memberships