Jeremiah Sinclair is a Managing Director at Ankura, based in Chicago. Jeremiah specializes in data analytics that support compliance investigations, self-disclosures, expert testimony, and Independent Review Organization (IRO) activities. Jeremiah has broad experience in the healthcare industry, supporting provider, payer, and pharmacy clients, as well as handling numerous Medicare and Medicaid reimbursement repayment calculations, many of which have involved large, complex data sets and various damages scenarios. He has assisted clients dealing with qui tam, False Claims Act, Stark, anti-kickback statutes, and other legal matters.
Jeremiah’s professional experience includes:
- Expert Report, University-Owned Medical Research Center: Managed a team that aimed to counter damages claims related to allegations that a center employee had falsified research. Jeremiah oversaw the review of NIH grant documentation and NIH RePORTER data to quantify the extent to which specific federally-funded grants were affected by the research in question, ultimately classifying more than $100,000,000 in grant funds into categories that challenged the plaintiff’s damages assertion.
- 340(b) Repayment Support, Regional Health System: Managed a team assisting the system’s counsel in identifying prescriptions that were not eligible for 340(b) pricing and calculating potential repayments. Jeremiah oversaw efforts to use data from the client’s Sentry pharmacy system and to obtain invoice data from wholesalers. Performed a repayment and refund calculation utilizing that data, and in certain instances, performed a FIFO-based manual accumulation model where a connection between the Sentry system and wholesaler invoice data did not exist.
- Data Analytics, Institutional Pharmacy: Supported the client’s defense against allegations that it had contracted with skilled nursing facilities at below-market rates to provide drugs for Medicare Part A patients on a per-diem basis in exchange for the patients’ Part D drug business. Jeremiah developed calculation models analyzing pharmacy claims data, invoices, and inventory-purchasing data to help determine whether the per-diem rates constituted remuneration under the Anti-Kickback Statute. This profitability study of the Part A business was used to establish and support several defense strategies and calculate potential damages related to other government business.
- Data Analytics and Litigation Support, Medical Laboratory Testing Company: Created a calculation model using the client’s billing and reimbursement data to support defense against a qui tam action alleging that client charged services to Medicaid programs at rates higher than the rates offered to other payers. Performed numerous iterations of pricing model based on scenarios with multiple variable assumptions.
- Independent Review Lead, Healthcare Service Provider: Led a team serving as the IRO for a company that provides podiatry, ophthalmology, and other medical services to residents of long-term care facilities. Jeremiah prepared annual reports that detailed the data collection, validation, random sampling, claim review, and overpayment calculations.
- Billings and Claims Analysis and Litigation Support, Hospital System: Analyzed data to calculate designated health services (DHS) revenue from Medicare and Medicaid payers to support the client’s defense against allegations of self-referral violations under the Stark Law. Jeremiah identified DHS revenue from services, procedures, durable medical equipment, prescription drugs, and other sources.
- Claims Analysis and Litigation Support, Claims Processor Firm: Led a team that reviewed the billing and collections database of emergency medical services (EMS) claims that were the subject of lawsuit filed against the client by a large US municipality. Jeremiah supported an expert witness with report drafting, deposition preparation, and review and rebuttal of opinions from the plaintiff’s expert.
- Claims Analysis and Litigation Support, Claims Processing Firm: Supported the client in a lawsuit filed by a state Medicaid agency, managing a team of more than 10 consultants responsible for document review and data entry. Jeremiah’s efforts included establishing the specifications for online review software used by the team and developing automated quality-control and other analyses. Led a team that conducted analysis of the billing and collections database for orthodontia claims processed on behalf of the Medicaid program.