WHITNEY NEBOLISA has extensive experience representing companies in government enforcement actions, internal investigations, and compliance counseling matters.
She has handled numerous U.S. Department of Justice (DOJ) criminal and civil investigations and internal investigations involving, healthcare fraud and abuse (including issues arising under the False Claims Act (“FCA”), the federal Anti-Kickback Statute (“AKS”), and Stark Law), off-label promotion and marketing practices, pricing and reimbursement, data integrity, clinical trial and laboratory practices, and Quality System Regulation (QSR)/ current Good Manufacturing Practices (GMP) issues.
Whitney’s practice also includes counseling corporations about their corporate compliance programs, conducting program reviews, risk assessments, employee training, M&A and contractor due diligence, and policy/procedure development.
Whitney was recognized in the 2022 edition of Best Lawyers: Ones to Watch in America for Health Care Law.
A sample of Whitney’s recent work includes:
- Representing a large managed care provider group in a Department of Justice (DOJ) investigation involving allegations of “upcoding”
- Representing a large hospital system in connection with criminal and civil investigations related to alleged kickbacks and billing fraud
- Representing a pharmaceutical manufacturer in a joint enforcement action by FDA, DOJ and Congress in connection to an investigation involving alleged kickback and off-label promotion
- Representing a biomedical device company in connection with a government investigation related to alleged kickbacks to physicians
- Advising a telehealth company on healthcare compliance considerations and assisting with the development of key compliance policies in advance of the company’s SPAC merger
- Conducting regulatory due diligence reviews for life sciences transactions on behalf of private equity firms, and advising clients on U.S. healthcare regulatory risks in connection with the transactions
- Representing a pharmaceutical manufacturer in a criminal investigation into alleged violations of cGMP regulations
- Advising a biopharmaceutical manufacturer in connection with an internal review regarding alleged clinical trial misconduct
- Providing fraud and abuse counseling to a wide array of clients, including pharmaceutical manufacturers, medical device companies, providers and patient assistance organizations
Prior to joining Sidley, Whitney was a D.C. Bar Association Pro Bono Fellow for Whitman Walker Health where she assisted the nonprofit by drafting healthcare privacy and compliance policies. Whitney also served as a speech-writing intern to the Director of Communications for the Office of William J. Clinton and the Clinton Foundation.
Whitney earned her law degree from the University of North Carolina School of Law, where she was the symposium editor for the First Amendment Law Review. Whitney received her B.A. in Journalism, Electronic Communications and Communication Studies, Rhetorical Studies from the University of North Carolina at Chapel Hill.