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 | 6 min read | 06.11.26

CMS Announces New Medicaid Eligibility Requirements: Implications for Managed Care Plans

On Wednesday, June 3, 2026, the Department of Health and Human Services (HHS) published an interim final rule with comment (IFC) instructing all state Medicaid agencies to incorporate “community engagement” as an eligibility condition for program participation by no later than January 1, 2027. The rule (Medicaid Program; Community Engagement Requirement for Certain Individuals) does not impose affirmative operational obligations for Medicaid managed care plans, as it focuses primarily on equipping the states to administer the community engagement requirement. However, it does establish a few specific guardrails to govern the role managed care organizations, prepaid inpatient health plans, and prepaid ambulatory health plans may — and may not — play in that administration....

Rachel's Insights

Client Alert | 6 min read | 06.11.26

CMS Announces New Medicaid Eligibility Requirements: Implications for Managed Care Plans

On Wednesday, June 3, 2026, the Department of Health and Human Services (HHS) published an interim final rule with comment (IFC) instructing all state Medicaid agencies to incorporate “community engagement” as an eligibility condition for program participation by no later than January 1, 2027. The rule (Medicaid Program; Community Engagement Requirement for Certain Individuals) does not impose affirmative operational obligations for Medicaid managed care plans, as it focuses primarily on equipping the states to administer the community engagement requirement. However, it does establish a few specific guardrails to govern the role managed care organizations, prepaid inpatient health plans, and prepaid ambulatory health plans may — and may not — play in that administration....