Alex Lucas

Partner

Overview

With a wealth of experience in health care compliance and regulatory matters, Alex Lucas serves as a trusted advisor to managed care organizations (MCO) across the country. She frequently advises clients on compliance with key legislation, including the Consolidated Appropriations Act of 2021, reproductive care and gender-affirming care laws, and various government program requirements. Alex also has experience addressing specific compliance issues involving Medicare Advantage Organizations, Medicaid MCOs, Marketplace products, and ERISA plans and administrators.

Alex is regarded as a leading national authority on the No Surprises Act (NSA) and its implications for MCOs. She advises her clients on wide-ranging NSA compliance issues, oversees administration of the NSA’s independent dispute process for multiple organizations, and aids in internal and regulatory audits to ensure NSA compliance. Additionally, she advises payors regarding compliance with the Transparency in Coverage rules, Medicare Advantage marketing rules, provider directory compliance, medical loss ratio reporting, privacy and interoperability requirements, and state and federal benefits mandates. Beyond her advisory work, Alex leverages her deep knowledge of the NSA to represent MCOs in litigation involving the independent dispute resolution (IDR) process, including defending against lawsuits seeking to enforce IDR awards and pursuing lawsuits on behalf of MCOs that target providers and affiliated parties who abuse the IDR process. She also provides strategic counsel to MCOs aiming to address improper practices in the IDR process and represents MCOs in lawsuits that target providers and affiliated parties who abuse the IDR process.

Alex is uniquely positioned to represent MCOs as her in-depth industry knowledge and subject matter proficiency go beyond just the legal matters. This includes a comprehensive understanding of procedural and diagnosis coding, various payment methodologies such as diagnosis-related groups and the outpatient prospective payment system, National Correct Coding Initiative edits, utilization management and front-end claim processing, actuarial considerations, and operational implementation of coverage requirements. Alex’s broad experience has equipped her to effectively navigate and resolve complex challenges that payors encounter in the industry.

Alex is deeply passionate about legal technology and has developed innovative legal technology solutions that MCOs can access through a subscription-based model. Among these offerings are the Post-Dobbs Tracker and the Gender-Affirming Care Tracker, which provide real-time updates on state and federal laws concerning reproductive care and gender-affirming care, as well as tailored analyses of associated payor risks. Alex is actively working on creating other similar technology offerings to further assist MCOs in their legal compliance endeavors.

Career & Education

    • University of Chicago Law School, J.D., 2013
      Served in the Institute for Justice Clinic on Entrepreneurship; staff member of the Chicago Journal of International Law
    • University of Minnesota, B.A., high distinction, Psychology, 2009
    • University of Chicago Law School, J.D., 2013
      Served in the Institute for Justice Clinic on Entrepreneurship; staff member of the Chicago Journal of International Law
    • University of Minnesota, B.A., high distinction, Psychology, 2009
    • Illinois
    • U.S. District Court for the Northern District of Illinois
    • U.S. District Court for the Southern District of Illinois
    • U.S. Court of Appeals for the Tenth Circuit
    • U.S. Court of Appeals for the District of Columbia Circuit
    • Illinois
    • U.S. District Court for the Northern District of Illinois
    • U.S. District Court for the Southern District of Illinois
    • U.S. Court of Appeals for the Tenth Circuit
    • U.S. Court of Appeals for the District of Columbia Circuit

Alex's Insights

Firm News | 5 min read | 08.06.25

Leading Health Care Practices Combine to Provide Comprehensive Counsel to Clients at a Time of Tremendous Change Across the Industry

Chicago – August 06, 2025: Crowell & Moring today announced that a group of 16 highly regarded health care litigation partners is joining the firm, together with their team, and led by accomplished trial attorney Martin J. Bishop. The strategic combination creates one of the largest health care practices in the country and expands the firm’s ability to provide clients across the industry with the full spectrum of litigation, investigations, regulatory, transactional, and recovery capabilities. The team joins from Reed Smith, where Bishop served on the firm’s executive committee....

Representative Matters

  • Counseled multiple managed care companies regarding compliance with and implementation of the No Surprises Act (NSA), which prohibits surprise balance billing by out-of-network providers on a federal level, as well as other requirements in the Consolidated Appropriations Act of 2021.
  • Pursued litigation on behalf of MCOs against multiple providers and affiliated entities alleging improper practices in the NSA’s independent dispute resolution (IDR) process and claiming RICO violations, among other state and federal causes of action.
  • Fully administered the NSA’s IDR process for multiple payors and assisted other payors in developing on IDR strategy and preparation of IDR-related written materials.
  • Consulted with multiple MCOs regarding Transparency in Coverage requirements, including compliance with machine-readable file specifications and implementation of the member cost estimator tool, as well as compliance with the gag clause prohibition.
  • Assisted in developing evidence of coverage (EOC) documents for state-regulated plans and individual retail policies to ensure compliance with applicable state and federal laws, with a focus on ACA and Marketplace requirements.
  • Advocated for clients in regulatory audits and developed procedures to reduce exposure in such audits, including performing internal audits of MCO compliance in anticipation of regulatory review.
  • Advised on compliance and risk under federal and state laws with regard to adjudication of health care claims for emergency services.
  • Advised on compensation and compliance issues regarding agents, brokers, and third-party marketing organizations who market government program products and individual insurance products.
  • Counseled clients regarding the internal processes necessary to ensure compliance with prompt payment requirements.
  • Obtained an arbitration ruling entirely in her MCO client’s favor in an arbitration brought by a large hospital system alleging breach of contract and underpayment of many Medicaid, Medicare Advantage, and commercial health care claims.
  • Secured a 12(b)(6) dismissal of an air ambulance company’s ERISA complaint when, given express exclusions in the benefit plan, the plaintiff had failed to allege that it was entitled to benefits as the patient’s assignee.
  • Tried and obtained a favorable ruling on behalf of a managed care company and Medicaid MCO in an arbitration brought by a hospital system alleging improper application of the prudent layperson standard to thousands of emergency department claims.
  • Obtained a summary judgment victory on behalf of a managed care company against operators of non-participating freestanding emergency departments who sought statutory penalties under the Texas prompt payment statutes with respect to thousands of health care claims.
  • Secured the dismissal of claims brought by an air ambulance provider against a managed care company on the basis that the Texas Insurance Code provision regarding payment for emergency services did not create a private right of action for providers.
  • Secured a 12(b)(6) dismissal of an ERISA benefits complaint against a managed care company alleging underpayment of air ambulance transportation because the plaintiff failed to identify the health benefit plan provisions entitling it to additional payment.
  • Secured a 12(b)(6) dismissal with prejudice of a former policyholder’s conspiracy-based claims against a managed care company because the court lacked subject matter jurisdiction; the D.C. Circuit upheld the decision.
  • Represented a managed care company in an arbitration involving cross-claims for overpayment and underpayment of nearly 700 hospital claims with complex, varied reimbursement issues.
  • Secured a 12(b)(6) dismissal of a provider’s tortious interference and defamation claims against a managed care company, securing the client’s rights to advise in-network providers of their contractual obligations; this dismissal was upheld by the Tenth Circuit.
  • Obtained a summary judgment dismissal of a $200 million arbitration claim against a managed care company that was sued by a hospital system for alleged violations of the Texas prompt pay statute and other provisions of the Texas Insurance Code.
  • Obtained a significant summary judgment ruling in the Fifth Circuit Court of Appeals for a managed care company holding that non-insured products are not subject to Texas’s prompt pay statute.

Alex's Insights

Firm News | 5 min read | 08.06.25

Leading Health Care Practices Combine to Provide Comprehensive Counsel to Clients at a Time of Tremendous Change Across the Industry

Chicago – August 06, 2025: Crowell & Moring today announced that a group of 16 highly regarded health care litigation partners is joining the firm, together with their team, and led by accomplished trial attorney Martin J. Bishop. The strategic combination creates one of the largest health care practices in the country and expands the firm’s ability to provide clients across the industry with the full spectrum of litigation, investigations, regulatory, transactional, and recovery capabilities. The team joins from Reed Smith, where Bishop served on the firm’s executive committee....

Recognition

  • Chambers USA: Illinois Healthcare, 2025

Alex's Insights

Firm News | 5 min read | 08.06.25

Leading Health Care Practices Combine to Provide Comprehensive Counsel to Clients at a Time of Tremendous Change Across the Industry

Chicago – August 06, 2025: Crowell & Moring today announced that a group of 16 highly regarded health care litigation partners is joining the firm, together with their team, and led by accomplished trial attorney Martin J. Bishop. The strategic combination creates one of the largest health care practices in the country and expands the firm’s ability to provide clients across the industry with the full spectrum of litigation, investigations, regulatory, transactional, and recovery capabilities. The team joins from Reed Smith, where Bishop served on the firm’s executive committee....

Alex's Insights

Firm News | 5 min read | 08.06.25

Leading Health Care Practices Combine to Provide Comprehensive Counsel to Clients at a Time of Tremendous Change Across the Industry

Chicago – August 06, 2025: Crowell & Moring today announced that a group of 16 highly regarded health care litigation partners is joining the firm, together with their team, and led by accomplished trial attorney Martin J. Bishop. The strategic combination creates one of the largest health care practices in the country and expands the firm’s ability to provide clients across the industry with the full spectrum of litigation, investigations, regulatory, transactional, and recovery capabilities. The team joins from Reed Smith, where Bishop served on the firm’s executive committee....