Roma Sharma
Overview
Roma Sharma is a counsel in Crowell & Moring's Washington, D.C. office and a member of the firm's Health Care Group. Roma's practice entails counseling and representing health care providers, managed care organizations, distributors, pharmacies, laboratories, and other health care entities in various regulatory, transactional, and litigation matters. Roma primarily works with health care clients seeking to comply with federal and state laws and regulations, including those related to fraud and abuse (e.g., the Stark Law, the Anti-Kickback Statute, the False Claims Act – and state corollaries), telemedicine, licensing, reimbursement, the practice of medicine, and federal and state demonstration programs.
Career & Education
- University of Michigan, B.S., with High Honors, brain, behavior, and the cognitive sciences, 2007
- The George Washington University Law School, J.D., cum laude
- The George Washington University, M.P.H.
- District of Columbia
- Illinois (Inactive)
Roma's Insights
Client Alert | 13 min read | 12.18.23
OIG Issues Updated General Compliance Program Guidance: Overview of Key Elements & Changes
The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published the General Compliance Program Guidance (GCPG) on November 6, 2023. The GCPG provides updated descriptions of the seven elements of an effective compliance program that health care entities have long relied upon. The new guidance also includes recommendations to conduct annual internal risk assessments, to consider quality of care as a component of the compliance program, and to emphasize the importance of a board’s and executive leadership’s oversight of compliance.
Client Alert | 6 min read | 11.27.23
Representative Matters
- Perform health care regulatory analysis of the business models and contracts of digital health technology companies – both nationally recognized and start-ups.
- Counsel telemedicine physician network and other entities on temporary Centers for Medicare & Medicaid (CMS) waivers and telemedicine rule changes during the COVID-19 declared public health emergency.
- Counsel health care entity on evaluating drive-through coronavirus testing opportunities and government outreach.
- Conduct internal investigation of managed care organization to analyze and determine compliance with Medicare Part D prescription drug regulations.
- Conduct health care regulatory due diligence for private equity firm in a $170 million transaction.
- Represent national inpatient rehabilitation facility (IRF) system in a multi-year False Claims Act Medicare billing investigation conducted by the Department of Justice, successfully reaching favorable settlement.
- Draft Medicare Shared Savings Program (MSSP) and Next Generation Accountable Care Organization (ACO) Model contracts and governance documents for ACOs and provide counsel on compliance and business issues.
- Counsel various health care entities on the fraud and abuse risks of proposed financial arrangements under the federal Stark Law and Anti-Kickback Statute.
- Prepare self-disclosures for submission to the CMS Self-Referral Disclosure Protocol (SRDP) on behalf of hospital systems, laboratories, and pharmacies.
- Defend Blue Cross and Blue Shield companies in national and statewide class actions asserting antitrust claims.
- Represent MedStar Health as an Interested Party in a Certificate of Need application.
Roma's Insights
Client Alert | 13 min read | 12.18.23
OIG Issues Updated General Compliance Program Guidance: Overview of Key Elements & Changes
The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published the General Compliance Program Guidance (GCPG) on November 6, 2023. The GCPG provides updated descriptions of the seven elements of an effective compliance program that health care entities have long relied upon. The new guidance also includes recommendations to conduct annual internal risk assessments, to consider quality of care as a component of the compliance program, and to emphasize the importance of a board’s and executive leadership’s oversight of compliance.
Client Alert | 6 min read | 11.27.23
Recognition
- The Best Lawyers in America: Ones to Watch in America, Health Care Law, 2023
Roma's Insights
Client Alert | 13 min read | 12.18.23
OIG Issues Updated General Compliance Program Guidance: Overview of Key Elements & Changes
The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published the General Compliance Program Guidance (GCPG) on November 6, 2023. The GCPG provides updated descriptions of the seven elements of an effective compliance program that health care entities have long relied upon. The new guidance also includes recommendations to conduct annual internal risk assessments, to consider quality of care as a component of the compliance program, and to emphasize the importance of a board’s and executive leadership’s oversight of compliance.
Client Alert | 6 min read | 11.27.23
Roma's Insights
Client Alert | 13 min read | 12.18.23
OIG Issues Updated General Compliance Program Guidance: Overview of Key Elements & Changes
The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published the General Compliance Program Guidance (GCPG) on November 6, 2023. The GCPG provides updated descriptions of the seven elements of an effective compliance program that health care entities have long relied upon. The new guidance also includes recommendations to conduct annual internal risk assessments, to consider quality of care as a component of the compliance program, and to emphasize the importance of a board’s and executive leadership’s oversight of compliance.
Client Alert | 6 min read | 11.27.23