Stephen Bentfield
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.
Career & Education
- St. Lawrence University, B.A., 1995
- Suffolk University Law School, J.D., 2003
- District of Columbia
- Massachusetts
- Colorado
Stephen'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.
Client Alert | 6 min read | 04.29.26
CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)
Blog Post | 06.18.25
CMS Innovation Center Releases New Strategy In Line With “MAHA” Agenda
Client Alert | 11 min read | 04.03.25
CMS Issues Marketplace Integrity and Affordability Proposed Rule
Insights
Fox Rothschild, Husch Blackwell, Ballard Spahr, Crowell & Moring, Fennemore Add Attorneys
|04.05.24
Law Week Colorado
CMS Innovation Center Releases New Strategy In Line With “MAHA” Agenda
|06.18.25
Crowell & Moring's Health Law Blog
- |
08.15.24
Crowell & Moring's Health Law Blog An Overview of the ACO Primary Care Flex (ACO PC Flex) Model
|05.31.24
Crowell & Moring's Health Law Blog
Stephen'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.
Client Alert | 6 min read | 04.29.26
CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)
Blog Post | 06.18.25
CMS Innovation Center Releases New Strategy In Line With “MAHA” Agenda
Client Alert | 11 min read | 04.03.25
CMS Issues Marketplace Integrity and Affordability Proposed Rule




