Insights

Washington – September 24, 2025: Crowell & Moring today announced the arrival of two seasoned attorneys, Rachel Park and Jill Abrams, to its nationally recognized Health Care Group. Both join Crowell after more than two decades at the Department of Health and Human Services (HHS), where they served in various senior level positions across the department. The addition of Park and Abrams further strengthens the firm’s ability to advise sophisticated health care clients on complex regulatory, compliance, enforcement, and litigation matters. They join the firm as senior counsel in Washington, D.C.

In June 2026, federal regulators and lawmakers continued their efforts to improve drug affordability through targeted reforms. These recent developments will primarily impact pharmaceutical manufacturers, managed care organizations, and pharmacy benefit managers (PBM) serving Medicare Part D program members. PBMs, Medicare Advantage organizations, and Part D sponsors should monitor these changes in the interest of maintaining compliance and providing input on regulatory proposals that may influence their business operations or compensation structures in the future.

On Wednesday, June 3, 2026, the Department of Health and Human Services (HHS) published an interim final rule with comment (IFC) instructing all state Medicaid agencies to incorporate “community engagement” as an eligibility condition for program participation by no later than January 1, 2027. The rule (Medicaid Program; Community Engagement Requirement for Certain Individuals) does not impose affirmative operational obligations for Medicaid managed care plans, as it focuses primarily on equipping the states to administer the community engagement requirement. However, it does establish a few specific guardrails to govern the role managed care organizations, prepaid inpatient health plans, and prepaid ambulatory health plans may — and may not — play in that administration.

On May 27, 2026, the U.S. District Court for the Southern District of Georgia issued a sweeping decision in Clover Insurance Company v. HHS that could ultimately lead to the invalidation of nearly half of all Star Ratings measures and, potentially, lead the Centers for Medicare & Medicaid Services (CMS) to seek statutory changes to Medicare law.