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Payal Nanavati

Counsel | She/Her/Hers
Counsel | She/Her/Hers
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Areas of Focus

Overview

Payal Nanavati is a counsel who serves as a liaison between the Health Care and Government Contracts groups. Practicing at the crossroads of the two of the most highly regulated industries, Payal understands the highly technical requirements of government contract law and the equally challenging health care statutes and regulations. This understanding enables her to provide clients in these spaces with efficient and effective legal services.

Payal’s practice covers a wide range of investigation, counseling, and litigation matters for companies in the government contracts and health care industries. She advises and advocates for government contractors and health care entities facing government investigations or high stakes litigation, with a particular focus on the False Claims Act, which is a heightened risk for members of both industries. Payal also helps clients conduct internal investigations and strategically navigate regulatory inquiries, civil investigative demands, and subpoenas issued by federal and state agencies. In addition to her investigations practice, Payal regularly litigates high-value disputes between government contractors and the U.S. government under the Contract Disputes Act. Payal also conducts compliance reviews and proposes enhancements of compliance programs for health care entities, contractors, or grant recipients.

Payal is a co-host of Crowell & Moring’s health care podcast, Payers, Providers, and Patients – Oh My!, which covers legal and regulatory issues that affect health care entities’ in-house counsel, executives, and investors.

Payal’s pro bono representations include clients seeking asylum or legal immigration status under the Violence Against Women Act.

Career & Education

    • Columbia Law School, J.D.
      Journal of Gender and Law: staff member
    • University of North Carolina at Chapel Hill, B.S., highest honors
    • Columbia Law School, J.D.
      Journal of Gender and Law: staff member
    • University of North Carolina at Chapel Hill, B.S., highest honors

    • District of Columbia
    • New York
    • North Carolina
    • District of Columbia
    • New York
    • North Carolina

Payal's Insights

Client Alert | 1 min read | 03.23.26

The Top FCA Developments of 2025

False Claims Act (FCA) settlements and judgments hit record highs yet again in FY 2025, surpassing the previous record by over $1 billion and setting a new high-water mark for the number of new FCA cases filed.  These records were built both on existing enforcement priorities such as pandemic-related fraud and healthcare enforcement actions and new guidance from the Executive Branch instructing the Department of Justice to enforce its 2025 priorities including Diversity, Equity, and Inclusion (DEI), civil rights, and customs issues.  Procurement fraud, cybersecurity issues, and small business fraud also remained focal points, with significant settlements in each of those areas.  In the courts, an Eleventh Circuit decision expanded relators’ ability to use discovery to avoid dismissal under Rule 9(b), and a Ninth Circuit ruling clarified a number of customs fraud issues while applying the Supreme Court’s Schutte scienter test.  Debate over the qui tam provisions’ constitutionality continued to grow, with arguments made in multiple circuits, including an Eleventh Circuit oral argument in the appeal of the Middle District of Florida’s Zafirov decision that helped to spark the recent wave of challenges.  Crowell FCA attorneys explain these developments, trends, and what’s next for the FCA in a “Feature Comment” published in The Government Contractor....

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Representative Matters

  • Representing hospital systems and plans in disclosing potential overpayments pursuant to the HHS OIG Self-Disclosure Protocol.
  • Representing a Medicare Advantage organization in a DOJ investigation regarding risk adjustment practices.
  • Assisting Medicare Advantage organizations in responding to risk adjustment data validation (RADV) audits and appealing unfavorable results.
  • Assessing and strengthening plan risk adjustment processes and procedures in light of historical audit activity, CMS regulatory activity, and government enforcement initiatives.
  • Defending leading health plan in class action litigation and investigations by state/federal regulators concerning compliance with the Mental Health Parity and Addiction Equity Act and state parity laws.
  • Representing health care clients in the development, enhancement, and implementation of compliance programs.
  • Assessing the reasonableness of legal advice concerning Stark Law and Anti-Kickback Statute compliance to help draft an expert report for a False Claims Act litigation.
  • Representing health plan in intervened False Claims Act litigation involving Medicare Advantage marketing payments to third-party marketing organizations.
  • Representing federal government contractor in audit negotiations with DCAA and DCMA, resulting in elimination and reduction of questioned costs.
  •  Representing a federal contractor in the aerospace industry in a qui tam suit.

Payal's Insights

Client Alert | 1 min read | 03.23.26

The Top FCA Developments of 2025

False Claims Act (FCA) settlements and judgments hit record highs yet again in FY 2025, surpassing the previous record by over $1 billion and setting a new high-water mark for the number of new FCA cases filed.  These records were built both on existing enforcement priorities such as pandemic-related fraud and healthcare enforcement actions and new guidance from the Executive Branch instructing the Department of Justice to enforce its 2025 priorities including Diversity, Equity, and Inclusion (DEI), civil rights, and customs issues.  Procurement fraud, cybersecurity issues, and small business fraud also remained focal points, with significant settlements in each of those areas.  In the courts, an Eleventh Circuit decision expanded relators’ ability to use discovery to avoid dismissal under Rule 9(b), and a Ninth Circuit ruling clarified a number of customs fraud issues while applying the Supreme Court’s Schutte scienter test.  Debate over the qui tam provisions’ constitutionality continued to grow, with arguments made in multiple circuits, including an Eleventh Circuit oral argument in the appeal of the Middle District of Florida’s Zafirov decision that helped to spark the recent wave of challenges.  Crowell FCA attorneys explain these developments, trends, and what’s next for the FCA in a “Feature Comment” published in The Government Contractor....

View All Insights

Insights

Client Alert | 1 min read | 03.23.26

The Top FCA Developments of 2025

Client Alert | 2 min read | 02.03.26

CMS Doubles Down on RADV Audit Changes

Client Alert | 6 min read | 01.30.26

CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D

Client Alert | 3 min read | 01.07.26

FDA Request for Information Signals New Path for VC Firms and their Portfolio Companies in Federal Contracting

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Practices

Payal's Insights

Client Alert | 1 min read | 03.23.26

The Top FCA Developments of 2025

False Claims Act (FCA) settlements and judgments hit record highs yet again in FY 2025, surpassing the previous record by over $1 billion and setting a new high-water mark for the number of new FCA cases filed.  These records were built both on existing enforcement priorities such as pandemic-related fraud and healthcare enforcement actions and new guidance from the Executive Branch instructing the Department of Justice to enforce its 2025 priorities including Diversity, Equity, and Inclusion (DEI), civil rights, and customs issues.  Procurement fraud, cybersecurity issues, and small business fraud also remained focal points, with significant settlements in each of those areas.  In the courts, an Eleventh Circuit decision expanded relators’ ability to use discovery to avoid dismissal under Rule 9(b), and a Ninth Circuit ruling clarified a number of customs fraud issues while applying the Supreme Court’s Schutte scienter test.  Debate over the qui tam provisions’ constitutionality continued to grow, with arguments made in multiple circuits, including an Eleventh Circuit oral argument in the appeal of the Middle District of Florida’s Zafirov decision that helped to spark the recent wave of challenges.  Crowell FCA attorneys explain these developments, trends, and what’s next for the FCA in a “Feature Comment” published in The Government Contractor....

View All Insights