Christopher (“CJ”) Frisina is an associate with the Firm in the Health Law and Federal Grants Law practice groups.
In his health law practice, CJ reviews provider, service, and similar arrangements to determine compliance with federal fraud and abuse laws, such as the Anti-Kickback Statute (the “AKS”) and Civil Monetary Penalties (the “CMPs”). When an arrangement does not fit into an applicable safe harbor or exception, CJ drafts requests for advisory opinions from the Office of the Inspector General (the “OIG”). Additionally, when providers discover evidence of potential health care fraud, CJ prepares submissions to the OIG’s Provider Self-Disclosure Protocol. CJ is also prepared to counsel clients on a variety of health care issues, including those related to graduate medical education (“GME”) supervision and reimbursement, telehealth, and institutions of mental disease.
In his federal grants practice, CJ routinely advises clients on the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”), including, but not limited to, cost allocation and allowability, time and effort reporting, and subrecipient monitoring. CJ’s counsel includes guidance on compliance requirements for certain federal programs, including, but not limited to, the Community Health Center, Head Start, and the Community Services Block Grant programs, as well as Small Business Innovation and Research (“SBIR”) and Small Business Technology Transfer (“STTR”) awards. CJ also assists clients with nonprocurement suspension and debarment matters, by performing initial risk assessments, responding to notices of proposed debarment, and, when necessary, drafting administrative agreements.
CJ’s primary representations in both practice groups involve dispute resolution. Understanding that the deference afforded to an awarding agency increases as a dispute proceeds, CJ has assisted clients facing cost disallowances, deficiency findings, and grant terminations, resolving many through negotiations with agency officials prior to the need for any administrative appeal. CJ also has significant experience representing clients before the HHS Departmental Appeals Board, in federal district court, and in the federal circuit courts of appeals. In addition to these federal grant-related matters, CJ has represented clients in federal district court addressing Medicaid reimbursement issues and breach of contract disputes.
Prior to joining FTLF, CJ worked in HHS’s Office of Recipient Integrity Coordination in the Office of Grants and Acquisition Policy and Accountability, exclusively handling suspension and debarment cases pursuant to the Non-Procurement Common Rule (2 C.F.R. Part 180) and the Federal Acquisition Regulation (“FAR”) subpart 9.4. CJ earned his law and Master of Public Policy degrees from American University in 2015.