Sean Sullivan

• Developing management services organization (MSO) and friendly PC arrangements for clients in all health care specialties based on state corporate practice of medicine (and other professions) restrictions and fee-splitting rules.
• Advising several providers and IT companies, including a Fortune 500 health IT developer and supplier of pharmaceutical and medical supplies, on HHS interoperability and information blocking regulations, including analyzing the impact on electronic health record (EHR) systems, other health IT products, provider network, and various other business lines.
• Advising telehealth-focused health care organizations on regulatory matters, contracting, telehealth, and remote patient monitoring policy, including during significant growth and changes during the COVID-19 pandemic.
• Counseling hospitals, health systems, physician groups, and post-acute care providers on Anti-Kickback Statute, Stark Law, and related state fraud and abuse law compliance, including helping health care providers develop compliant partner relationships and payment programs.
• Advising health care providers on telemedicine and remote patient monitoring program implementation, including licensure issues, informed consent, scope of practice limitations, compliance issues, and reimbursement.
• Overseeing regulatory due diligence and corporate structuring concerns for acquisitions and investments in the health care industry, including advising private equity and other investors on regulatory risk and navigating corporate practice of medicine restrictions.
• Assisting physician groups and hospitals in contracting matters, including for clinical trial agreements, preferred provider programs, and employment agreements.
• Negotiating, drafting, and advising on implementing electronic health record agreements between providers and vendors.
• Advising health care providers and business associates on patient privacy, data security, and HIPAA compliance, including reviewing policies and procedures for privacy and security, breach notification, and security assessments.
• Developed multistate hospice consent policies and forms for a large national hospice provider.
• Defending high-exposure government investigations of health care providers and other companies in highly regulated industries, both in criminal and civil investigations.
• Developing policies and procedures for multiple health care providers surrounding committees protected by the quality assurance, medical review, and peer review privileges in health care.
• Drafting and enforcing arbitration agreements for health care providers to limit liability, expedite dispute resolution, and protect patient and provider privacy.
• Assisted a national veterinary practice management company on state corporate practice of veterinary medicine rules, structuring considerations, and regulatory diligence for various acquisitions, including recapitalization and strategic partnership transactions and providing corporate M&A and regulatory counsel.

Sean Sullivan advises health care providers, technology companies, and investors on navigating complex regulatory and operational challenges at the intersection of health care delivery, data, and emerging technology. Known for practical, business oriented guidance, he helps clients structure compliant arrangements and innovate in areas such as digital health and data driven provider models.

Sean counsels on a wide range of regulatory issues, including corporate practice of medicine, fraud and abuse, reimbursement, health data compliance, information blocking, and licensure. He works closely with providers, health IT companies, and private equity sponsors to design compliant business models, execute transactions, and assess risk in acquisitions across sectors and provider specialties. He is particularly active in provider acquisitions and digital health transactions, where regulatory and compliance considerations are often central to deal strategy and value.

In addition to his transactional and advisory practice, Sean represents clients in government investigations, internal reviews, and compliance matters, with a focus on proactive risk mitigation and operational alignment.

Sean is a frequent speaker and author on emerging health care regulatory issues. His recent work focuses on AI governance, health data monetization, telehealth, and evolving enforcement trends, and he regularly presents to national industry organizations and contributes to publications on these topics.

Chambers USA: America’s Leading Lawyers for Business and The Best Lawyers in America^® has recognized him for excellence in the Healthcare category.

Bar Admissions

• Georgia

Education

• Georgia State University (J.D., 2007)
• Emory University (B.A., 2004)

Memberships