Rachel Park

Senior Counsel

Overview

Rachel Park is a senior counsel in Crowell & Moring’s Washington, D.C. office and a member of the firm’s Health Care Group. She advises clients on a wide array of health care matters, including Medicare and Medicaid reimbursement, managed care litigation, and health care fraud investigations and oversight. Prior to joining Crowell, she served for 24 years at the U.S. Department of Health and Human Services (HHS), most recently as principal deputy general counsel, the highest-level nonpolitical appointee in the HHS Office of the General Counsel. 

Over more than two decades at that office, Rachel gained a deep understanding of the regulatory issues facing health care providers and insurance companies. She also has deep experience in litigation and investigations, including extensive service as a first chair litigator. Spanning both government and health care, Rachel’s experience equips her to assist clients with a full suite of issues, from regulatory compliance to challenging government actions.   

Rachel’s practice includes advising on:

  • Health care regulation
  • Recovery litigation
  • Health care reimbursement
  • Risk adjustment audits
  • Organ procurement organizations

Career & Education

    • New York University School of Law, J.D., 1993
    • Swarthmore College, B.A., chemistry and psychology, 1988
    • New York University School of Law, J.D., 1993
    • Swarthmore College, B.A., chemistry and psychology, 1988
    • New York
    • U.S. Court of Appeals for the Third Circuit
    • U.S. District Court for the Northern District of New York
    • *Admitted in New York Only. Practicing under the Supervision of D.C. Bar Members.
    • New York
    • U.S. Court of Appeals for the Third Circuit
    • U.S. District Court for the Northern District of New York
    • *Admitted in New York Only. Practicing under the Supervision of D.C. Bar Members.
  • Professional Activities and Memberships

    • Member,  American Health Law Association

    Professional Activities and Memberships

    • Member,  American Health Law Association

Rachel's Insights

Client Alert | 7 min read | 10.05.26

Florida Court Upholds CMS Rule on Organ Procurement Organizations

 On September 28, 2026, the U.S. District Court for the Middle District of Florida upheld the U.S. Centers for Medicare and Medicaid Services’ (CMS) final rule governing organ procurement organizations (OPO). The rule, promulgated in 2020, will have its fullest effect when CMS releases final OPO performance rankings determining the fate of the 55 OPOs (Regulatory Uncertainty Ahead For Organ Transplant System). The Middle District of Florida is among five courts hearing challenges to the rule and the first to issue a decision. Legacy of Life Hawaii v. HHS, which was filed August 6, 2026, is the most recent.  ...

Rachel's Insights

Client Alert | 7 min read | 10.05.26

Florida Court Upholds CMS Rule on Organ Procurement Organizations

 On September 28, 2026, the U.S. District Court for the Middle District of Florida upheld the U.S. Centers for Medicare and Medicaid Services’ (CMS) final rule governing organ procurement organizations (OPO). The rule, promulgated in 2020, will have its fullest effect when CMS releases final OPO performance rankings determining the fate of the 55 OPOs (Regulatory Uncertainty Ahead For Organ Transplant System). The Middle District of Florida is among five courts hearing challenges to the rule and the first to issue a decision. Legacy of Life Hawaii v. HHS, which was filed August 6, 2026, is the most recent.  ...