People sometimes think of the law as an endless list of proscriptions inhibiting the accomplishment of goals, but I see it as a series of guardrails that can facilitate getting you where you want to go. When writing poetry, you must understand that a sonnet is constructed of three quatrains and a couplet written in iambic parameter, and the practice of law lends itself to a similar approach. Once you understand the structure and make that part of your creative process, you can make magic.
Mr. Sullivan concentrates his practice in healthcare and insurance law, with a particular emphasis on the intersection of healthcare finance and delivery. He regularly represents and counsels health plans and healthcare providers in regulatory compliance and filings, and alternative financial models for healthcare delivery, including Organized Delivery Systems (ODS), Accountable Care Organizations (ACO), Multiple Employer Welfare Arrangements (MEWA), and health system equity ownership or participation in insurance organizations.
As Assistant Commissioner of the New Jersey Department of Banking and Insurance (DOBI) from 2010-2014, Mr. Sullivan oversaw the Office of Life and Health during 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, including CO-OPs, ACOs, and health system equity ownership or participation in insurance organizations; and the transition to electronic health records and implementation of the ICD-10 mandate.
In his role at DOBI, Mr. Sullivan 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.
Honors & Awards
- Mr. Sullivan ranked among the top 15 professionals in the NJBIZ annual “Power 50 in Healthcare” list in 2012 - 2014
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- New Jersey State Bar Association; Insurance Benefits Committee (Chair, 2017)
- New Jersey Life & Health Insurance Guaranty Association (Board of Directors, 2004 - 2010)
- New Jersey Department of Banking and Insurance; Individual and Small Employer Health Coverage Program Boards (2010 - 2014); Legal Committee (former member)
More Activities & Experience
- Mr. Sullivan’s prior experience includes serving as in-house counsel at New Jersey’s largest health insurer, as General Counsel for a community hospital, and as Director of Group Contracts for New Jersey’s largest life insurer.
- As Assistant General Counsel at Horizon Blue Cross Blue Shield of New Jersey, Mr. Sullivan represented the company before state and federal regulators for new product development, changes and proposed changes to regulations, and market conduct matters.
Presentations & Speaking Engagements
- Presenter, What ALL Business Owners Who Received Pandemic Relief Funds Need to Know about the Government’s Crackdown on PPP Loan FraudSponsor: New Jersey Business & Industry Association, June 29, 2022
- Sponsor: Strafford, March 2, 2022
- Sponsor: Greenbaum, Rowe, Smith & Davis LLP, November 20, 2020
- Sponsor: Greenbaum, Rowe, Smith & Davis LLP, NJ Hospital Association, NJ Healthcare Financial Management Association, Medical Society of NJ, and NJ Dental Association, July 1, 2020
- Speaker, The Health Financing and Delivery System From the Flintstones to the JetsonsSponsor: Healthcare Financial Management Association, NJ Chapter, September 10, 2015
- Speaker, ACA ImplementationSponsor: National Conference of State Legislatures, August 8, 2011
- Speaker, Navigating Health Care ReformSponsor: American Law Institute, February 23, 2010
Publications & Alerts
- Greenbaum, Rowe, Smith & Davis LLP Healthcare Perspectives Blog, December 14, 2022
- Author, Providers May Soon Be Unable to Report Unpaid Medical Debt to Collection or Credit Reporting FacilitiesGreenbaum, Rowe, Smith & Davis LLP Healthcare Perspectives Blog, August 18, 2022
- Greenbaum, Rowe, Smith & Davis LLP Healthcare Perspectives Blog, August 12, 2022
- Co-Author, Three Issues to Consider When Assessing the Impact of the U.S. Supreme Court’s Decision in Dobbs v. Jackson Women’s Health OrganizationGreenbaum, Rowe, Smith & Davis LLP Healthcare Perspectives Blog, July 14, 2022
- Greenbaum, Rowe, Smith & Davis LLP Healthcare Perspectives Blog, July 8, 2022
- Author, Texas Court Sides with Challengers to Independent Dispute Resolution Process Under No Surprises ActGreenbaum, Rowe, Smith & Davis LLP Client Alert, March 29, 2022
- Co-Author, Federal “No Surprises Act” Brings National Oversight of Unexpected Billing for Healthcare ServicesGarden State Focus, Spring 2021
- Co-Author, Federal “No Surprises Act” Brings National Oversight of Unexpected Billing for Healthcare ServicesGreenbaum, Rowe, Smith & Davis LLP Client Alert, March 2, 2021
- Greenbaum, Rowe, Smith & Davis LLP Client Alert, July 7, 2020
- Greenbaum, Rowe, Smith & Davis LLP Client Alert, June 11, 2020
- Co-Author, Title III of the CARES Act: Supporting America’s Health Care System in the Fight Against the CoronavirusGreenbaum, Rowe, Smith & Davis LLP Client Alert, March 31, 2020
- NJHFMA's Garden State Focus Magazine, Summer 2016, Vol. 62, No. 4
- NJHFMA's Garden State Focus, Summer 2015, Vol. 61, No. 5