Jenny M. Odom


(405) 270-6018
Oklahoma City

Jenny Odom is a healthcare attorney whose career experience not only includes representing and counseling public, private, and governmental healthcare clients of all sizes in a multitude of business transactions and compliance matters and related litigation, but also serving as an in-house counsel for a multi-campus regional health system for three years. As part of her daily legal practice, she leverages her collective experiences, insights, and insider knowledge of the ever-evolving healthcare industry to counsel medical professionals and physician groups, hospitals and other healthcare facilities, long-term care providers, durable medical equipment suppliers, and other service providers on a multitude of regulatory, administrative and day-to-day operational issues, both complex and routine. 

Jenny’s regulatory and administrative practice includes issues relating to Stark and anti-kickback compliance; Medicare and Medicaid enrollment, billing, and reimbursement; fraud and abuse; payer audits and appeals; internal audits and investigation; OIG and SRDP self-disclosures; implementation of corporate integrity agreements; HIPAA privacy, security, and breach notification; licensure and accreditation; certificates of need; medical staff credentialing and peer review; False Claims Act/qui tam claims; EMTALA; and other federal and state regulatory requirements.

A significant portion of Jenny’s practice is devoted to representing clients in a broad range of industry-related business transactions, including those involving facility development; investments and financing; asset and stock purchases and sales; joint ventures and strategic alliances; contract negotiation, drafting, and review; and real estate acquisition, development, sales, and leasing. 

Jenny’s achievements have earned her inclusion in Oklahoma Super Lawyers’ list of “Oklahoma Rising Stars,” which recognizes the state’s up-and-coming attorneys.

Representative Experience

  • Representation of durable medical equipment company in appeal of Medicare contractor’s flawed use of statistical sampling and extrapolation to determine overpayment.
  • Assisted a home health care facility in the appeal of a large Medicare ZPIC overpayment demand of more than $1 million based on sampling and extrapolation.
  • Counsels clients on Medicare and Medicaid provider enrollment issues, including CHOWs, changes of information, and revalidations.
  • Representation of health plans and healthcare providers regarding HIPAA compliance, including drafting business associate agreements, development of policies and procedures, conducting risk assessments, and sending breach notifications.
  • Provide ongoing regulatory and transactional counsel to numerous hospitals, physician groups, and long-term care providers.
  • Representation of hospitals and physician groups in connection with False Claims Act lawsuits, overpayments, audits and appeals for both government and commercial payers.
  • Representation of hospitals in obtaining Medicare provider-based status for outpatient clinics.
  • Representation of nursing facilities in Medicaid Upper Payment Limit (UPL) program transactions, including obtaining Certificate of Need and licensure approvals.
  • Assisted in the representation of a healthcare provider in a HITECH meaningful use audit.
  • Representation of hospitals, physicians and other healthcare providers in drafting and negotiating professional services contracts, service agreements, and employment contracts.
  • Representation of healthcare providers in evaluating compliance with Stark law and Medicare fraud and abuse laws and regulations.
  • Representation of clients in sales and acquisitions of unimproved and improved real property, including negotiation and documentation of purchase and sale agreements, title and survey diligence, regulatory compliance, and land use issues

Honors and Awards

  • Named to Oklahoma Super Lawyers’ list of “Oklahoma Rising Stars,” which recognizes the state’s up-and-coming attorneys

Professional Organizations and Memberships

  • Oklahoma Bar Association
  • Oklahoma Health Lawyers Association
  • American Health Law Association

Civic Involvement and Leadership

  • Junior League of Norman

Speaking Engagements

  • You Can Do That? New Flexibilities for Value-Based Arrangements

    Annual Checkup: Healthcare Industry Seminar 2022

    April 27, 2022
    | Oklahoma City, OK