Stephen Bentfield

Partner

Overview

Stephen Bentfield is a partner and a member of the firm’s Health Care Group. Stephen counsels health care organizations on a wide range of health care regulatory and transactional matters. His regulatory experience includes helping clients with issues such as fraud and abuse enforcement risk analysis and mitigation, organizational compliance programs and policies, managed care, value-based care, reimbursement, licensure, and state regulatory issues. On the transactional side, Stephen has extensive experience drafting contracts, advising on deal structuring and negotiation, including the creation of joint ventures and other new corporate structures, as well as mergers and acquisitions.

Before joining Crowell, Stephen served as vice president and group general counsel of DaVita Integrated Kidney Care, the value-based care subsidiary of DaVita Inc. In that role, he led the legal team responsible for structuring, advising, and operating the company’s portfolio of renal-specific accountable care organizations (ACOs), risk-based management services agreements with Chronic Condition Special Needs Plans, commercial risk contracts, and other value-based and integrated care arrangements. His work for DaVita included designing, structuring, and drafting the company’s arrangements with over 50 Kidney Contracting Entities, ESCO joint ventures, and Value-based Enterprises (VBEs), including all accompanying supporting agreements such as provider participation agreements, MSO agreements, and ancillary provider agreements.

Career & Education

    • St. Lawrence University, B.A., 1995
    • Suffolk University Law School, J.D., 2003
    • St. Lawrence University, B.A., 1995
    • Suffolk University Law School, J.D., 2003
    • District of Columbia
    • Massachusetts
    • Colorado
    • District of Columbia
    • Massachusetts
    • Colorado

Stephen's Insights

Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....

Stephen's Insights

Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....