Sarah Charles Wright
Member
swright@sturgillturner.com | 859.255.8581
An experienced health care and corporate law attorney, Sarah Charles has extensive experience navigating state and federal laws and regulations impacting health insurers and employee group health plans, as well as healthcare providers including hospitals, clinics, long-term care facilities, and physician practices. Health care is one of the more intricate and highly regulated industries, and Sarah Charles stays up-to-date on relevant legislative developments to provide the most inclusive and informed counsel possible.
Sarah Charles provides legal counsel to health care providers and organizations regarding the Affordable Care Act and Accountable Care, Medicare and Medicaid, ERISA, HIPAA, Managed Care Relationships, Physician Licensure and other matters of federal and state regulatory compliance. A signature area of her practice includes drafting and negotiating contracts and policies for institutional providers, and the managed care industry. She also advises medical practices on practice management and employment issues generally and related to complying with federal Privacy and Fraud and Abuse laws, Provider Reimbursement, commercial Network and ACO participation, and Credentialing and Peer Review matters.
Additionally, Sarah Charles is experienced in forming business and professional entities and in representing creditors in bankruptcy cases.
Areas of Practice
Representative Experience
Drafts, reviews and negotiates numerous health care industry agreements including for:
Provider Participation in commercial provider networks, Accountable Care Organizations and Medicare Advantage Organizations
ERISA Summary Plan Descriptions
Network Lease Arrangements
Healthcare IT Licensing and Administrative Services
HIPAA Business Associates and Trading Partners
Third Party Administration for ERISA Regulated Employee Group Health Plans
Utilization Management
Data Analytics
NCQA Delegation (credentialing, utilization review, quality improvement)
Value-based Provider Compensation
Certificates of Coverage
Employer Group Health Insurance Contracts
Pharmacy Benefits Management including Medicare Part D
Non-disclosure / Non-competition / Non-solicitation
Physician Employment and Subcontracting arrangements for Fraud and Abuse Compliance
Drafts organizational documents including corporate articles, bylaws and operating agreements for business, professional and non-profit entities;
Drafts employee handbooks and employment contracts for commercial and non-profit entities;
Has advised clients regarding:
Licensing software and other intellectual property rights
Department of Labor group health plan audits
Internal regulatory compliance/whistleblower complaints
Medicaid Waiver program compliance
Physician peer review
Medicare Advantage compliance
Sale of physician practice
Physician and hospital fraud and abuse compliance in employment and other contractual arrangements
Physician exclusion and CMS post-exclusion reinstatement
Medicare compliance and multi-state contracting for long-term acute care facilities
Medicare change of ownership rules
Health care clients’ rights as creditors in bankruptcy proceedings
Physician practice legal and ethical obligations
Professional Affiliations
American Health Lawyers Association, Managed Care Section
Fayette County Bar Association, Health Care Section
Kentucky Bar Association, Heath Care, Business Law and Bankruptcy Sections
Kentucky Chamber of Commerce Health Care Policy Council
Publications
Surprise! What the “No Surprises Act” Means for Patients, Providers and Health Plans, Medical News (May 2021)
New HIPAA Privacy Rule Revisions–What You Need to Know, (with Emily B. Pence) M.D. Update (April 2021)
As Overdose Deaths Rise, Kentucky Proposes First in Nation Plan to Expand Medicaid Coverage for Inmates, Medical News (January 2021)
Revised SUD Confidentiality Rules—What’s Changed and What Hasn’t., M.D. Update (December 2020)
Significant Amendments to Kentucky’s Health Insurance Utilization Review Laws, M.D. Update (November 2019)
Unanswered Questions Left in the Wake of the Medical Review Panel Act’s Demise, M.D. Update (March 2019)
New Kentucky Legislation Clears State Law Barriers to Direct Primary Care Practice Model, M.D. Update (November 2017)
Fair Market Value in Physician Compensation Arrangements under the Stark Law, M.D. Update (January 2016)
Treating Patients by Telehealth in Kentucky, M.D. Update (November 2014)
Buying and Selling a Physician Practice, M.D. Update (December 2013)
Patient-Centered Medical Homes—Are you eligible?, M.D. Update (April 2013)
How the ACA will Affect your Small Business, Business Lexington (January 2013)
Seminars
How to Manage a Compliant Health Benefit Plan: DOL Audits & Fiduciary Responsibility (February 2018)
Accolades
Best Lawyers in America®: Health Care Law
Fayette County Bar Association Citizen Lawyer Award (2021)
Community Involvement
The Well of Lexington, Past President and current member, Board of Directors
Lexington Chamber Music Festival, Past member Board of Directors
Episcopal Church of the Good Shepherd, Past Junior Warden and Vestry member
Lexington Art League, Past President, Vice President and member Board of Directors
Education
University of Kentucky, B.A. (1980)
University of Louisville, J.D. (1987)