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Steven W. Ortquist
Founder and Principal, Managing Director
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Steve is a leading expert on the design, implementation, and operation of compliance programs. He has served as Chief Compliance Officer and led compliance programs for some of the nation’s largest complex health systems (Banner Health, Tenet, Sutter Health) and for two decades has been a thought leader on what makes compliance programs effective. He works regularly with clients to evaluate the structure and operation of compliance programs, and to recommend improvements that will enhance the organization’s ability to prevent, detect and correct non-compliance.  

 

Having started his career as chief financial officer for a multi-state, multi-specialty physician practice, Steve brings a practical approach grounded in operational experience to his work with organizations

on their compliance initiatives. 

 

Steve works often with clients subject to Corporate Integrity Agreements (“CIAs”).  He has served multiple times as the compliance officer or interim compliance officer responsible for implementing and managing CIAs. He has helped organizations assure timely and appropriate responses to CIA requirements.  He also serves as Independent Review Organization (“IRO”) and/or Board Expert for CIA obligated organizations.

 

Mr. Ortquist has extensive experience conducting compliance investigations.  He has investigated alleged provider billing, coding and revenue cycle irregularities in home health, hospital, physician office, and other settings.  He has considerable experience investigating allegations or concerns involving the Anti-Kickback Statute and Stark Law.  He has led teams in complex, multi-facility and multi-state investigations.  He has worked with organizations to self-disclose instances of non-compliance to CMS, the OIG, the DOJ and to other appropriate regulatory and law enforcement agencies. 

 

Steve is past president of the Health Care Compliance Association/Society of Corporate Compliance & Ethics (HCCA/SCCE).  He has participated in several industry-wide initiatives to better define the role of compliance officers and compliance programs.  He is a frequent author and speaker on matters related to the structure, operation and effectiveness of compliance programs; and on laws and regulations at the heart of compliance program efforts.  

Representative Matters:
  • Evaluated compliance program 
    effectiveness for organizations including community hospitals, DME providers, children’s hospitals and complex health system
     

  • Investigated non-compliant physician  arrangements and led related self-disclosure efforts for several provider organization
     

  • Managed IRO engagements, and served as IRO for CIA-obligated organizations
     

  • Advised Boards on compliance oversight obligations, and served as Board Expert pursuant to CIA
     

  • Served as interim Chief Compliance Officer 
     

  • Led responses to government-initiated audits and investigations
     

Education 

JD, Wake Forest University School of Law

 

BA, John Brown University


Licensure 
 

Licensed to Practice Law:  Michigan, Illinois, District of Columbia

 

Certification

Certified in Healthcare Compliance Fellow  (CHC-F)
 

Certified in Healthcare Research Compliance (CHRC)
 

Certified Compliance & Ethics Professional  (CCEP)