Roma Sharma
Overview
Roma Sharma is a partner in Crowell & Moring's Washington, D.C. office and a member of the firm's Health Care Group. Roma represents healthcare clients in regulatory, transactions, and investigation matters. Roma is a fraud, waste, and abuse attorney primarily focused on the Stark Law, the Anti-Kickback Statute (AKS), coding and billing fraud, medical necessity, and risk adjustment. Roma represents Fortune 500 companies across the spectrum, including providers, payors, technology companies, distributors, and laboratories. In her role, clients rely on Roma for counseling on day-to-day compliance, in high-stakes False Claims Act (FCA) investigations and audits against the government, and to lead healthcare due diligence during mergers and acquisitions (M&A). Roma also represents clients nationally on matters related to certificate of need (CON), licensing, billing, the practice of medicine, innovative and value-based payment models, and artificial intelligence (AI).
Career & Education
- 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
- District of Columbia
- Illinois (Inactive)
Roma's Insights
Client Alert | 3 min read | 09.28.26
CMS Expands ACCESS Model to Cover More Chronic Conditions
The Centers for Medicare and Medicaid Services (CMS) will add four condition tracks to its Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model next spring, according to a September 15 announcement, to address gaps in chronic disease management between scheduled provider visits. The 10-year voluntary model officially launched on July 5, 2026. In its initial form, ACCESS targeted four high-prevalence conditions: high blood pressure, diabetes, chronic musculoskeletal pain, and depression. CMS reports that three out of four Medicare beneficiaries qualify for at least one existing ACCESS track. The new and expanded condition tracks are heart failure, chronic obstructive pulmonary disease (COPD), substance use disorders (SUDs), and tobacco cessation. In addition, the existing chronic musculoskeletal pain track, which is currently limited to an initial 12-month period, will be extended for certain specified conditions.
Firm News | 5 min read | 08.20.26
Speaking Engagement | 07.15.26
"In Data We Trust: Data Analytics Under the False Claims Act,” Crowell & Moring Webinar
Representative Matters
- Conduct internal fraud, waste, and abuse investigations and compliance review for large academic medical centers (AMCs) and hospital systems, assessing legal risk and offering risk mitigation solutions.
- Counsel vertically integrated provider-payer organization on the fraud and abuse compliance of several complex and innovative coverage models under the federal Stark Law and Anti-Kickback Statute, working closely with in-house legal and business teams.
- Represent hospitals, ambulatory surgery centers, technology companies, and nursing home systems, to obtain, oppose, serve as an Interested Party in and strategize on business competition related to, Certificate of Need matters – including Amazon, MedStar, Johns Hopkins University, George Washington University, AmSurg, and Hill Valley Healthcare, among others.
- Advise on the business models and fraud and abuse compliance of payment arrangements for large Fortune 10 technology companies, digital health platforms, and start-ups.
- Represent large managed care organization (MCO) in multi-year risk adjustment investigations by the Department of Justice (DOJ).
- Represent national inpatient rehabilitation facility (IRF) system in a multi-year FCA Medicare billing investigation conducted by DOJ, successfully reaching favorable settlement.
- Defend large hospital system against the Department of Health and Human Services (HHS) Office of Inspector General (OIG) audit of physician billing, resulting in dismissal of audit in its entirety saving client over $50M.
- Lead teams conducting health care regulatory due diligence for numerous Fortune 500 companies purchasing group practices in multimillion and billion dollar deals.
- Counsel Accountable Care Organizations (ACOs) on legal and business matters related to Medicare Shared Savings Program (MSSP), ACO REACH, and other Centers for Medicare and Medicaid Innovate (CMMI) models.
- Prepare and submit self-disclosures to the CMS Self-Referral Disclosure Protocol (SRDP) on behalf of hospital systems, laboratories, and pharmacies – resulting in successful resolution.
Roma's Insights
Client Alert | 3 min read | 09.28.26
CMS Expands ACCESS Model to Cover More Chronic Conditions
The Centers for Medicare and Medicaid Services (CMS) will add four condition tracks to its Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model next spring, according to a September 15 announcement, to address gaps in chronic disease management between scheduled provider visits. The 10-year voluntary model officially launched on July 5, 2026. In its initial form, ACCESS targeted four high-prevalence conditions: high blood pressure, diabetes, chronic musculoskeletal pain, and depression. CMS reports that three out of four Medicare beneficiaries qualify for at least one existing ACCESS track. The new and expanded condition tracks are heart failure, chronic obstructive pulmonary disease (COPD), substance use disorders (SUDs), and tobacco cessation. In addition, the existing chronic musculoskeletal pain track, which is currently limited to an initial 12-month period, will be extended for certain specified conditions.
Firm News | 5 min read | 08.20.26
Speaking Engagement | 07.15.26
"In Data We Trust: Data Analytics Under the False Claims Act,” Crowell & Moring Webinar
Recognition
- The Best Lawyers in America: Ones to Watch, Administrative / Regulatory Law, Health Care Law, 2023-2027
Roma's Insights
Client Alert | 3 min read | 09.28.26
CMS Expands ACCESS Model to Cover More Chronic Conditions
The Centers for Medicare and Medicaid Services (CMS) will add four condition tracks to its Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model next spring, according to a September 15 announcement, to address gaps in chronic disease management between scheduled provider visits. The 10-year voluntary model officially launched on July 5, 2026. In its initial form, ACCESS targeted four high-prevalence conditions: high blood pressure, diabetes, chronic musculoskeletal pain, and depression. CMS reports that three out of four Medicare beneficiaries qualify for at least one existing ACCESS track. The new and expanded condition tracks are heart failure, chronic obstructive pulmonary disease (COPD), substance use disorders (SUDs), and tobacco cessation. In addition, the existing chronic musculoskeletal pain track, which is currently limited to an initial 12-month period, will be extended for certain specified conditions.
Firm News | 5 min read | 08.20.26
Speaking Engagement | 07.15.26
"In Data We Trust: Data Analytics Under the False Claims Act,” Crowell & Moring Webinar
Insights
Speaking Engagement | 07.15.26
The Promise And Peril Of Advancing Health Equity Through Artificial Intelligence
|08.28.23
The Health Lawyer
"In Data We Trust: Data Analytics Under the False Claims Act,” Crowell & Moring Webinar
|07.15.26
"AI and Health Care: Perspectives from Policymakers and Movers in the Industry," Crowell & Moring Seminar, Washington, D.C.
|11.02.23
FDA Proposes Framework to Assess AI Model Output Credibility to Support Regulatory Decision-Making
|01.29.25
Crowell & Moring’s Health Law Blog
Crowell Presents “AI and Health Care: Perspectives from Policymakers and Movers in the Industry”
|12.14.23
Crowell & Moring's Health Law Blog- |
11.02.23
Crowell & Moring's Health Law Blog
Coalition for Health AI Introduces Blueprint for Trustworthy AI in Healthcare
|06.15.23
Crowell & Moring's Health Law Blog
AI in Health Care: AI Bill of Rights, Future Regulations, and What Business Should Consider Now
|05.04.23
Crowell & Moring's Health Law Blog
ONC Releases a Framework for Nationwide Health Information Exchange
|02.03.22
Crowell & Moring's Health Law Blog
OIG Issues Advisory Opinion Rejecting the Labeling of Test Tubes at No Cost
|02.22.17
Crowell & Moring's Health Law Blog
Medicaid Managed Care Final Rule: Prevention of Fraud, Waste, and Abuse
|08.04.16
Crowell & Moring's Health Law Blog
New Payment Models and Data: Changes and Themes to Watch
|07.12.16
Crowell & Moring’s Health Law Blog
Roma's Insights
Client Alert | 3 min read | 09.28.26
CMS Expands ACCESS Model to Cover More Chronic Conditions
The Centers for Medicare and Medicaid Services (CMS) will add four condition tracks to its Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model next spring, according to a September 15 announcement, to address gaps in chronic disease management between scheduled provider visits. The 10-year voluntary model officially launched on July 5, 2026. In its initial form, ACCESS targeted four high-prevalence conditions: high blood pressure, diabetes, chronic musculoskeletal pain, and depression. CMS reports that three out of four Medicare beneficiaries qualify for at least one existing ACCESS track. The new and expanded condition tracks are heart failure, chronic obstructive pulmonary disease (COPD), substance use disorders (SUDs), and tobacco cessation. In addition, the existing chronic musculoskeletal pain track, which is currently limited to an initial 12-month period, will be extended for certain specified conditions.
Firm News | 5 min read | 08.20.26
Speaking Engagement | 07.15.26
"In Data We Trust: Data Analytics Under the False Claims Act,” Crowell & Moring Webinar
