Rachel Park
Areas of Focus
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.
Career & Education
- 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.
Professional Activities and Memberships
- Member, American Health Law Association
Rachel's Insights
Client Alert | 5 min read | 04.23.26
CMS Proposes New Payment Policy for IOPOs and HCLs
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.
Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
Client Alert | 4 min read | 04.10.26
CMS Finalizes Rate Notice for Medicare Parts C and D (CY 2027)
Client Alert | 7 min read | 03.19.26
Insights
Wilmer Rehires Trump Transition Attorney, Crowell Adds To Health Care Team
|09.29.25
The National Law Journal
Rachel's Insights
Client Alert | 5 min read | 04.23.26
CMS Proposes New Payment Policy for IOPOs and HCLs
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.
Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
Client Alert | 4 min read | 04.10.26
CMS Finalizes Rate Notice for Medicare Parts C and D (CY 2027)
Client Alert | 7 min read | 03.19.26




