Jolie N. Havens

Jolie is a partner in the Vorys Columbus and Houston offices and the immediate past chair of the firm’s health care group.  She also serves as the firm’s chief diversity & inclusion officer where she leads the firm’s strategy, policies, and practices related to diversity, equity, and inclusion.

Jolie maintains a national practice focused on health care compliance and provider/practitioner reimbursement, with significant experience involving hospitals and physicians.  Jolie has counseled providers, practitioners, and other stakeholders across the industry, including adult and children's hospitals, physicians and physician groups, pharmacies and pharmacy benefit managers, home health agencies, ambulatory surgery centers, diagnostic centers, and faculty practice plans, as well as manufacturers, distributers, and sellers of medical devices, pharmaceuticals, dietary supplements, and other products regulated by the Food and Drug Administration (FDA), on legal issues involving:

• Third party payor enrollment and contracting (including managed care);
• Provider/practitioner licensure, certification, registration, and accreditation, as well as scope of practice issues;
• Medicare and Medicaid billing, coding, documentation, coverage, and reimbursement, including related appeals, audits, and disclosures of overpayments, as well as government and internal investigations;
• Compliance with federal and state fraud and abuse laws, including the federal Anti-Kickback Statute, the federal Stark Physician Self-Referral Laws, the federal False Claims Act, and related government investigations and audits before the Centers for Medicare and Medicaid Services and their contractors, as well as the Department of Justice and the Office of the Inspector General;
• Mergers, acquisitions, and other industry consolidation, integration, and service expansion models;
• Issues unique to concierge medical practices, medical spas, and other aesthetic providers, including supervision and scope of practice issues associated with injectables (including botulinum toxins and dermal fillers), lasers, hydration therapy, and other cosmetic treatments and procedures;
• Compliance with the federal Food, Drug, and Cosmetic Act, other FDA guidance, and related federal and state laws, as related to drugs, medical devices (including personal protective equipment), dietary supplements, vaccines, biologics, cosmetics, medical foods, and nutraceuticals, including pre-market strategies and applications (510(k)s, emergency use authorizations (EUAs), and testing), as well as post-market compliance, such as labeling, advertising and promotion, adverse event reporting, recalls, good manufacturing practices, and responding to enforcement actions; 
• Compliance with Emergency Medical Treatment and Active Labor Act (EMTALA) and various other health care laws;
• Professional disciplinary actions, including representation of physicians, nurses, pharmacists, nursing home administrators, counselors, and other licensed practitioners before the State Medical Board of Ohio, Ohio Board of Nursing, Ohio Board of Pharmacy, Board of Executives of Long-Term Services and Supports, and Counselor, Social Worker and Marriage and Family Therapist Board; and
• Legal and business implications of medical marijuana, cannabis products, and hemp products.

Career highlights include:

• Assisting clients across the health care industry and in various other industries (including the retail industry) with business and compliance issues related to the manufacturing, distribution, and sale of medical devices, including personal protective equipment, in conjunction with the COVID-19 pandemic;
• Assisting clients across the health care industry with formation of compliance and reimbursement strategies, including considerable experience relative to start-up sites, operational expansion, and mergers and acquisitions;
• Representing a multi-state hospital in a multi-million dollar False Claims Act investigation, including formulation and implementation of medical records and claims review protocols, negotiations with the Department of Justice, and analysis of overpayment liability;
• Representing hospitals, physician groups and other provider types relative to consolidation, alignment, and integration strategies, including negotiating physician employment arrangements, space and equipment leasing, and practice leasing and asset purchase agreements;

Jolie regularly speaks both nationally and locally on health care reimbursement and compliance, as well as health care reform policy and compliance, and publishes often on the subjects.

Jolie is a member of the American Health Lawyers Association and the Society of Ohio Healthcare Attorneys.

Honors & Recognitions

The Best Lawyers in America, Health Care Law, 2021-2023

Chambers and Partners, "Outstanding Contribution to Furthering the Advancement of Diversity in the Legal Profession” Award, 2019

Most Powerful and Influential Woman, Ohio Diversity Council, 2018

Columbus CEO, Top Lawyers in Columbus, 2015

Chambers and Partners, Leading Lawyer in Health Care, 2012-2015, 2019-2022