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.

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.

In keeping with ongoing efforts to intensify regulatory oversight of organ procurement organizations (OPOs) and curtail improper spending within federal health programs, the Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule that would, among other adjustments, align Medicare payment policies for non-renal organs to be consistent with those currently applicable to kidneys. If enacted as drafted, this latest rule could have a direct impact on the financial stability of OPOs and histocompatibility laboratories (HCL) at a time when such organizations face increasing pressure to meet CMS’s new outcome measures — or else face non-renewal or decertification later this year. 

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.

This podcast episode features the following speakers: