Courtney G. Tito

How Courtney Helps Clients

Courtney is a board-certified healthcare attorney with extensive experience advising healthcare providers nationwide on a broad spectrum of legal and regulatory matters. Her practice encompasses payor reimbursement disputes, audits, government investigations and compliance, with a focus on helping clients navigate complex federal and state regulations.

Core Areas of Practice:

• Reimbursement and Audits:
  Courtney has in-depth experience representing clients in all types of Medicare audits—including Unified Program Integrity Contractor (UPIC), Recovery Audit Contractor (RAC), Targeted Probe and Educate (TPE) and Supplemental Medical Review Contractor (SMRC) audits—and managing subsequent internal investigations. She advises on voluntary overpayment refunds and strategies to address reimbursement challenges across a variety of provider types and substantive issues including as examples: clinical laboratories, Durable Medical Equipment (DME) suppliers, Ambulatory Surgery Centers (ASCs), physician practice groups, genetic testing, molecular pathology, substance abuse diagnostics, vein treatments and skin substitutes.
• Government Investigations:
  A key focus of Courtney’s practice involves representing clients during investigations into healthcare fraud, waste and abuse by the Department of Justice (DOJ) and Office of Inspector General (OIG). She assists in responding to Civil Investigative Demands (CIDs), OIG investigations, and negotiations surrounding potential criminal, civil and administrative penalties. Courtney also advises on internal investigations, helping clients develop strategic responses to mitigate risks and ensure ongoing compliance.
• Regulatory and Compliance Counseling:
  Courtney provides guidance on licensing, CLIA standards, and federal and state fraud and abuse laws. She offers strategic advice on regulatory compliance, billing practices, documentation and contractual arrangements, including telehealth and direct-to-consumer issues.
• Broader Healthcare Sector Experience:
  Her experience spans numerous healthcare sectors, with particular emphasis on laboratories, DME suppliers and other providers facing billing, coverage and reimbursement challenges. Courtney has represented clients in Medicare Administrative Appeals and Medicaid overpayment proceedings as well as relationships and disputes with commercial payors.
• Outside General Counsel:
  Courtney acts as outside general counsel for healthcare providers, assisting with regulatory compliance, reimbursement strategies, workflow optimization and contractual negotiations. Her holistic approach helps clients navigate the complexities of the healthcare industry while minimizing legal and regulatory risks.

Early in her career, Courtney served as a staff attorney for the Public International Law and Policy Group in Baghdad, Iraq. There, she collaborated with legislators and senior government officials on drafting and amending legislation and constitutional provisions.

What Clients Can Expect

Courtney delivers advice that’s both clear and actionable, transforming complex regulatory and statutory language into practical solutions that her clients can confidently implement. She takes a collaborative approach, always considering a company’s unique risk profile and business goals. With a focus on pragmatic strategies, Courtney aims to protect her clients’ interests, reduce potential liabilities and help navigate the ever-changing healthcare landscape with confidence and clarity.

Outside the Office

Courtney spends her free time with her family, which includes her husband, two boys and two dogs. She loves hiking and reading and spending time outdoors, often at her kids’ various sporting events.

Proof Points 

• Fully favorable ALJ decision, resulting in a reduction of a $3.2 million overpayment demand to a final amount of $5,000.
• Partially favorable ALJ decision, resulting in a reduction of a $2.1 million overpayment demand to a final amount of $1,000.
• Resolution and termination of a UPIC prepayment demand with no overpayment.
• Successful termination of Medicare payment suspensions through the rebuttal process.
• Successful resolution of a Medicaid overpayment demand from over $4 million to approximately $800,000.