Thomas C. Hardy
Overview
Thomas Hardy is a member of Crowell & Moring’s Health Care Group. He has extensive experience in managed care litigation, including complex, high-stakes litigation involving ERISA, the Federal Employee Health Benefits Act, the Affordable Care Act (ACA), Medicare and Medicaid, insurance bad faith, state statutory claims, pricing disputes, and other issues.
Career & Education
- University of California, Hastings College of the Law, J.D., 2007
- Washington University, B.A., 1997
- Illinois
- U.S. District Court for the Northern District of Illinois
- U.S. Court of Appeals for the Fifth Circuit
- U.S. Court of Appeals for the Seventh Circuit
- U.S. District Court for the Central District of Illinois
- U.S. District Court for the Southern District of Illinois
- U.S. Bankruptcy Court for the Central District of Illinois
- U.S. District Court for the Northern District of Texas
- Member, Chicago Bar Association
- Member, American Bar Association
Thomas's Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 04.24.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
Blog Post | 04.24.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
Firm News | 4 min read | 08.06.25
Representative Matters
- Secured a dismissal with prejudice in a residential treatment behavioral health lawsuit alleging breach of contract and violations of the Texas Insurance Code on behalf of managed care organization who administered the plan for a state university.
- Secured dismissal with prejudice on behalf of a managed care client of a provider lawsuit based on an ERISA assignment of benefits that alleged underpayment of claims for infusion services.
- Successfully defended appeal $17 million guaranty judgment before the Seventh Circuit. Inland Mortgage Capital Corporation v. Chivas Retail Partners, LLC, 740 F.3d 1146 (7th Cir. 2014)
- Successfully defended appeal of summary judgment on Interest Act claims involving calculation of interest on 365/360 basis. Hubbard St. Lofts, LLC v. Inland Bank and Trust, 2011 IL App. (1st) 102640
- Obtained dismissal of several commercial borrowers’ Chapter 11 cases as bad faith filings.
- Foreclosed $22 million mortgage on ice sports facility.
- Foreclosed $10 million mortgages on eight commercial offices/shopping centers.
- Foreclosed $3 million mortgages on portfolio of nine multifamily properties.
Thomas's Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 04.24.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
Blog Post | 04.24.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
Firm News | 4 min read | 08.06.25
Recognition
- Illinois Super Lawyers: Rising Star, Health Care, 2016
- Thomson Reuters: Stand-Out Lawyers list, 2025
Thomas's Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 04.24.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
Blog Post | 04.24.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
Firm News | 4 min read | 08.06.25
Insights
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
|04.24.26
Crowell & Moring’s State AG Blog
Thomas's Insights
Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 04.24.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
Blog Post | 04.24.26
Bipartisan Coalition of State AGs Backs Federal PBM Transparency Rule
Firm News | 4 min read | 08.06.25
