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 | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 4 min read | 04.10.26
CMS Finalizes Rate Notice for Medicare Parts C and D (CY 2027)
Blog Post | 04.08.26
Client Alert | 2 min read | 03.27.26
CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans
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 | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 4 min read | 04.10.26
CMS Finalizes Rate Notice for Medicare Parts C and D (CY 2027)
Blog Post | 04.08.26
Client Alert | 2 min read | 03.27.26
CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans
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
Payal's Insights
Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 4 min read | 04.10.26
CMS Finalizes Rate Notice for Medicare Parts C and D (CY 2027)
Blog Post | 04.08.26
Client Alert | 2 min read | 03.27.26
CMS Releases PY 2020 RADV Audit Methods and Instructions: Key Takeaways for Health Plans




