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 | 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.  ...

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 | 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.  ...

Practices

Industries

Jill '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.  ...