Payal Nanavati
Areas of Focus
Overview
Payal Nanavati is a counsel who serves as a liaison between the Health Care and Government Contracts groups. Practicing at the crossroads of the two of the most highly regulated industries, Payal understands the highly technical requirements of government contract law and the equally challenging health care statutes and regulations. This understanding enables her to provide clients in these spaces with efficient and effective legal services.
Career & Education
- Columbia Law School, J.D.
Journal of Gender and Law: staff member - University of North Carolina at Chapel Hill, B.S., highest honors
- Columbia Law School, J.D.
- District of Columbia
- New York
- North Carolina
Payal's Insights
Client Alert | 2 min read | 03.27.26
CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans
On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review.
Client Alert | 1 min read | 03.23.26
Client Alert | 2 min read | 02.03.26
Client Alert | 6 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
Representative Matters
- Representing hospital systems and plans in disclosing potential overpayments pursuant to the HHS OIG Self-Disclosure Protocol.
- Representing a Medicare Advantage organization in a DOJ investigation regarding risk adjustment practices.
- Assisting Medicare Advantage organizations in responding to risk adjustment data validation (RADV) audits and appealing unfavorable results.
- Assessing and strengthening plan risk adjustment processes and procedures in light of historical audit activity, CMS regulatory activity, and government enforcement initiatives.
- Defending leading health plan in class action litigation and investigations by state/federal regulators concerning compliance with the Mental Health Parity and Addiction Equity Act and state parity laws.
- Representing health care clients in the development, enhancement, and implementation of compliance programs.
- Assessing the reasonableness of legal advice concerning Stark Law and Anti-Kickback Statute compliance to help draft an expert report for a False Claims Act litigation.
- Representing health plan in intervened False Claims Act litigation involving Medicare Advantage marketing payments to third-party marketing organizations.
- Representing federal government contractor in audit negotiations with DCAA and DCMA, resulting in elimination and reduction of questioned costs.
- Representing a federal contractor in the aerospace industry in a qui tam suit.
Payal's Insights
Client Alert | 2 min read | 03.27.26
CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans
On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review.
Client Alert | 1 min read | 03.23.26
Client Alert | 2 min read | 02.03.26
Client Alert | 6 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
Insights
The False Claims Act: Compliance issues in US government procurement and healthcare
|08.07.24
Global Investigations Review
FEATURE COMMENT: The Top FCA Developments Of 2021
|02.16.22
The Government Contractor, Vol. 64, No. 7
DOJ and HHS Launch FCA Working Group: Heightened Enforcement Risk for Health Care Entities
|07.08.25
Crowell & Moring's Health Law Blog
- |
02.21.19
Crowell & Moring's Government Contracts Legal Forum
MA/PDP Star Ratings: Proposed Technical Changes for 2020
|11.08.18
Crowell & Moring’s Health Law Blog
Incumbent Employees’ Self-Disclosure of Salaries is Not a Procurement Integrity Act Violation
|05.23.18
Crowell & Moring's Government Contracts Legal Forum
The Freight Train Gathers Steam: An Update on the Federal Response to the Opioid Crisis
|04.26.18
Crowell & Moring's Health Law Blog
New Draft NIST Guidance on Systems Security Engineering
|04.24.18
Crowell & Moring's Government Contracts Legal Forum
GAO Implements Changes to Bid Protest Process with New Regulations
|04.11.18
Crowell & Moring's Government Contracts Legal Forum
- |
03.16.18
Crowell & Moring’s Health Law Blog
GAO Lets Stand an Agency’s OCI Waivers in Face of a Multi-Prong Challenge
|03.14.18
Crowell & Moring's Government Contracts Legal Forum
Payal's Insights
Client Alert | 2 min read | 03.27.26
CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans
On March 20, 2026, the Centers for Medicare and Medicaid Services (CMS) released new guidance outlining the agency’s audit methods and instructions for Medicare Advantage (MA) plans subject to upcoming risk adjustment data validation (RADV) audits for payment year (PY) 2020. In addition to providing necessary context for MA plans selected for auditing, this resource clarifies CMS’s methodological and procedural expectations. While the high-level takeaways are recapped below for convenience, we strongly recommend that MA organizations selected for PY 2020 audits closely review the guidance to understand what may be involved — or required — during the agency’s review.
Client Alert | 1 min read | 03.23.26
Client Alert | 2 min read | 02.03.26
Client Alert | 6 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D




