Amy O. Garrigues


Internal and External Investigations: When and How to Maintain Privilege, ICLE 24th Annual Health Law Institute, March 2018.
[03/08/2018] SEE MORE


Amy Garrigues is a Shareholder and the Managing Partner of Hall Render's Raleigh office and concentrates her practice exclusively on health law. She primarily represents academic medical centers, hospitals and health systems across the country, as well as ancillary service providers, private equity companies and medical device companies. Amy regularly advises clients on regulatory and compliance matters; federal False Claims Act lawsuits and investigations; internal investigations; fraud and abuse laws, including Stark and Anti-Kickback; health care transactions; Medicare and Medicaid reimbursement issues; and administrative appeals. Prior to law school, Amy worked as a health care strategy consultant with a global consulting firm.


Harvard University, A.B., magna cum laude, Phi Beta Kappa - 2001

Harvard Law School, J.D. - 2006


  • North Carolina - 2006
  • U.S. District Court for the Eastern District of North Carolina
  • U.S. District Court for the Fourth Circuit


  • American Health Lawyers Association
  • American Bar Association, Health Law Section
  • North Carolina Bar, Health Law Section
  • North Carolina Society of Health Care Attorneys


  • Representation of hospital and health systems in resolution of multiple False Claims Act inquiries and lawsuits related to various Medicare and Medicaid reimbursement issues and associated retaliation claims.
  • Representation of academic medical centers, hospitals, publicly traded health care companies and other health care clients in connection with multiple confidential internal investigations related to government inquiries, potential compliance matters, potential violations of the federal Anti-Kickback Statute and/or the Stark Law, potential Medicare reimbursement matters, potential falsification of reports and claim submission or other documents, grant funding allocation issues and other matters.
  • Representation of academic medical center in government inquiry and False Claims Act litigation related to teaching physician supervision and medical direction of anesthesia services.
  • Representation of national radiation therapy provider in resolution of a False Claims Act case related to medical necessity of FISH testing and subsequent entry into Corporate Integrity Agreement.
  • Representation of hospitals and health systems in connection with Office of Inspector General audits and other inquiries.
  • Representation of large hospital systems in connection with filing over 1,200 Recovery Audit Contractor appeals to the Qualified Independent Contractor and Administrative Law Judge.
  • Representation of large health system in connection with litigation with the Department of Health and Human Services related to a potential writ of mandamus to compel ALJ hearings within the prescribed regulatory timeframe.
  • Representation of health care providers in hospital, physician practice and management company acquisitions.
  • Representation of multiple health care providers in multiple hearings related to compliance with EMTALA.
  • Representation of hospitals and health systems in connection with self-disclosures to the government under the federal Stark Law.
  • Representation of hospitals in connection with ambulatory surgery center private placements.
  • Representation of private equity firm and lenders in acquisitions of health care providers and health information companies.
  • Routine general advice and counsel to health care systems regarding Stark, anti-kickback and other fraud and abuse issues.
  • Regulatory advice regarding Section 111 reporting requirements under the MMSEA to foreign client.
  • Representation of multiple hospital and health system clients in connection with analysis of contracts and arrangements under the Stark Law and subsequent filing of self-disclosures under the Stark Self-Referral Disclosure Protocol to CMS or under the Self-Disclosure Protocol to the OIG for hospitals located in California, Pennsylvania, North Carolina, Ohio, Texas, New Jersey and Connecticut.
  • Representation of multiple hospital and health system clients in Stark and AKS matters that resulted in decision that activities were reasonably compliant and a self-disclosure was not warranted.
  • Conducted internal investigations at hospitals, academic medical centers and other health care provider clients related to a number of allegations potentially implicating the FCA, including but not limited to those covering: (i) allegations of Stark and anti-kickback noncompliance related to physician compensation; (ii) allegations of receipt of improper benefits from a medical device company; (iii) allegations of improper receipt of products from pharmaceutical companies and potential provision of free services to government beneficiaries; (iv) allegations of noncompliance by former executives post-termination; (v) allegations of distributing free items to referring physicians; (vi) allegations of lack of physician presence in the operating room setting; (vii) receipt of meaningful use payments; and (viii) improper inpatient billing for certain services.


  • Best Lawyers in America
  • Listed in North Carolina Super Lawyers Rising Stars – 2010