Roma Sharma

Counsel & CHS Director | She/Her/Hers

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.

In addition, Roma has an active pro bono practice. She currently represents an inmate in a state prison abuse action and also represents an affirmative asylum applicant. She previously represented a client seeking clemency and has represented several non-profit organizations, providing counsel on telemedicine and HIPAA. 

Before joining Crowell & Moring, Roma interned with the Office of the General Counsel at the American Medical Association, the Health Care Bureau at the Illinois Office of the Attorney General, and the Federal Government Affairs and Public Policy division at Sanofi Pasteur. Roma graduated cum laude from The George Washington University Law School. She also holds a master in public health from The George Washington University Milken Institute, where she served as president of the Health Policy Student Association and was elected to the Delta Omega Honorary Society in Public Health.

Roma frequently writes client alerts, blog posts, and articles on emerging health information technology and fraud and abuse developments. She is an active member of the American Health Lawyers Association, the firm’s Diversity Council, and the Leadership Council on Legal Diversity (LCLD) Pathfinders class of 2020.  

Career & Education

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    • 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.
    • 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)
    • 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....

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....

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....

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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....