Jill Abrams

Senior Counsel

Overview

Jill Abrams is a senior counsel in Crowell & Moring’s Washington, D.C. office and a member of the firm’s Health Care Practice. She advises on managed care compliance and enforcement matters, with a focus on Medicare Advantage (MA) and Medicare Part D. Prior to joining Crowell, she spent over 20 years at the U.S. Department of Health and Human Services (HHS), where she took a key role in most of the significant enforcement matters regarding these programs. 

At HHS, Jill served as senior attorney in the Office of the General Counsel’s Centers for Medicare and Medicaid Services (CMS) Division, where she advised on fraud and abuse, enforcement, and other policy issues, working closely with the U.S. Department of Justice (DOJ) and the HHS Office of the Inspector General. Her extensive experience in this role and knowledge of agency personnel allows her to provide valuable support to managed care clients on regulatory and enforcement matters as well as appeals.

Jill’s experience includes advising on:

  • Government audits, including risk adjustment data validation (RADV) audits
  • Internal investigations
  • Disclosures to the government
  • Developing and implementing compliance plans
  • New and evolving regulations and guidance
  • Disputes with downstream service providers to MA plans
  • Medicare marketing rules
  • Compliance and enforcement actions, including sanctions, CMPs, and terminations
  • Administrative appeals processes relating to MA and Part D
  • General regulatory counseling regarding the prescription drug price negotiation program, particularly compliance and enforcement involving drug manufacturers
  • False Claims Act (FCA) cases involving MA and Part D

Career & Education

    • University of Michigan Law School, J.D., 1999
    • University of Pennsylvania, B.A., 1994
    • University of Michigan Law School, J.D., 1999
    • University of Pennsylvania, B.A., 1994
    • District of Columbia
    • District of Columbia

Jill 's Insights

Client Alert | 6 min read | 05.08.26

WISeR Under Scrutiny: AI Claims Review Debate Reaches CMS

The appropriate use of AI tools during the claims review process continues to be a major topic of debate within the health care industry — but in recent weeks, emerging litigation has inspired critics to turn their attention specifically to the technology’s application within federal health programs. On March 25, 2026, the Electronic Frontier Foundation (EFF) filed a lawsuit against the Centers for Medicare and Medicaid Services (CMS), citing the agency’s alleged failure to answer a Freedom of Information Act (FOIA) request for records the EFF believes will provide crucial insight into the design, safeguards, vendor relationships, and real-world performance of the Medicare Wasteful and Inappropriate Service Reduction (WISeR) Model, CMS’s  AI-driven prior authorization pilot program for certain Medicare services....

Recognition

  • Office of the General Counsel: Excellence of Service Group Award, Inflation Reduction Act Implementation and Legal Defense Team, 2024
  • Centers for Medicare and Medicaid Services Division: Program Impact Award, Risk Adjustment Data Validation Final Rule Team, 2023
  • Centers for Medicare and Medicaid Services Division: Secretary’s Award for Distinguished Service, Medicare Modernization Act Regulations Development Team, 2005

Jill 's Insights

Client Alert | 6 min read | 05.08.26

WISeR Under Scrutiny: AI Claims Review Debate Reaches CMS

The appropriate use of AI tools during the claims review process continues to be a major topic of debate within the health care industry — but in recent weeks, emerging litigation has inspired critics to turn their attention specifically to the technology’s application within federal health programs. On March 25, 2026, the Electronic Frontier Foundation (EFF) filed a lawsuit against the Centers for Medicare and Medicaid Services (CMS), citing the agency’s alleged failure to answer a Freedom of Information Act (FOIA) request for records the EFF believes will provide crucial insight into the design, safeguards, vendor relationships, and real-world performance of the Medicare Wasteful and Inappropriate Service Reduction (WISeR) Model, CMS’s  AI-driven prior authorization pilot program for certain Medicare services....

Practices

Industries

Jill 's Insights

Client Alert | 6 min read | 05.08.26

WISeR Under Scrutiny: AI Claims Review Debate Reaches CMS

The appropriate use of AI tools during the claims review process continues to be a major topic of debate within the health care industry — but in recent weeks, emerging litigation has inspired critics to turn their attention specifically to the technology’s application within federal health programs. On March 25, 2026, the Electronic Frontier Foundation (EFF) filed a lawsuit against the Centers for Medicare and Medicaid Services (CMS), citing the agency’s alleged failure to answer a Freedom of Information Act (FOIA) request for records the EFF believes will provide crucial insight into the design, safeguards, vendor relationships, and real-world performance of the Medicare Wasteful and Inappropriate Service Reduction (WISeR) Model, CMS’s  AI-driven prior authorization pilot program for certain Medicare services....