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Neil M. Sullivan
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Neil’s healthcare and insurance law practice has a particular emphasis on the intersection of healthcare finance and healthcare delivery systems. He has significant experience assisting both healthcare providers and insurance companies in the negotiation and drafting of provider-payer contracting agreements, including participation in commercial, Medicare Advantage and managed Medicaid networks, and provides representation in insurer compensation disputes.

He regularly represents and counsels health plans and healthcare providers in regulatory compliance and filings, and alternative financial models for healthcare delivery, including Medicare Advantage (Part C) and managed Medicaid plans, Organized Delivery Systems (ODS), Accountable Care Organizations (ACO), Multiple Employer Welfare Arrangements (MEWA), and health system equity ownership or participation in insurance organizations. He has provided his expertise in complex regulatory requirements in conjunction with multiple lawsuits.

Neil served as Assistant Commissioner of the New Jersey Department of Banking and Insurance (NJ DOBI) from 2010-2014, a period of fundamental change in both the healthcare and insurance sectors. This encompassed the implementation of the Affordable Care Act (ACA) and the Dodd-Frank Wall Street Reform and Consumer Protection Act, the emergence of alternative financial models for health care delivery, and the transition to electronic health records and implementation of the ICD-10 mandate. 

In his role, he had overall responsibility for the implementation of insurance reforms under the ACA, including the establishment of a high-risk pool and feasibility study of health insurance exchanges, and rationalizing conflicting points of state and federal law. He served as the DOBI Commissioner’s designee on the NJ Individual Health Coverage (IHC) and Small Employer Health (SEH) program boards, the Mandated Health Benefits Advisory Commission, and the NAIC Regulatory Framework Task Force and Senior Issues Committee and acted as liaison with the Centers for Medicare & Medicaid Services (CMS) over ACA implementation.

Results may vary depending on your particular facts and legal circumstances.

Bar Admissions

  • New Jersey, 1993

Education

  • Rutgers University School of Law - Newark, J.D., 1993
  • Rutgers Graduate School of Management, M.B.A., 1986
  • Rutgers University Newark College of Art and Sciences, B.A., 1980

Recognition

  • Listed in The Best Lawyers in America (a trademark of Woodward/White, Inc.) in the Health Care Law practice area (2024)
  • Ranked among the top 15 professionals on the NJBIZ (a publication of Bridge Tower Media) annual “Power 50 in Healthcare” list  (2012-2014)

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Other Experience

  • New Jersey Department of Banking and Insurance: Individual and Small Employer Health Coverage Program Boards (2010 - 2014); Legal Committee (former member)
  • As Assistant General Counsel at Horizon Blue Cross Blue Shield of New Jersey, represented the company before state and federal regulators for new product development, changes and proposed changes to regulations, and market conduct matters.
  • Served as General Counsel for a community hospital, and as Director of Group Contracts for New Jersey’s largest life insurer.

Representative Matters

  • Representing two New Jersey health systems in high-stakes litigation against multiple Medicare Advantage plans seeking recovery of approximately $5 million in underpaid 340B drug reimbursements, following a U.S. Supreme Court decision invalidating the Center for Medicare and Medicaid Services’ reimbursement reductions; matters are proceeding toward mediation and arbitration.
  • Advising a local government agency on the formation of a compliant “friendly P.C.” structure for the operation of New Jersey’s largest psychiatric hospital, including drafting and negotiating all transactional and governance documents under New Jersey healthcare law.

Memberships

  • New Jersey State Bar Association: Insurance Benefits Committee (past Chair)
  • New Jersey Life & Health Insurance Guaranty Association (Board of Directors, (former Director)

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