Payal Nanavati is an associate in the firm's Washington, D.C. office, where she practices in the Health Care and Government Contracts groups. Payal’s government contracts practice focuses on defending companies under the False Claims Act (FCA), litigation before the Armed Services Board of Contract Appeals (ASBCA), and bid protests before the Government Accountability Office (GAO). Her health care practice includes working with providers and plans seeking to comply with laws and regulations applicable to digital health initiatives, fraud and abuse, and mental health parity.
Payal’s recent representative matters include:
- Representing major defense contractors in defending against claims of defective pricing and violations of Cost Accounting Standards at the ASBCA.
- Representing a hospital system in disclosing potential overpayments pursuant to the HHS OIG Self-Disclosure Protocol.
- Representing a federal contractor in the aerospace industry in a qui tam suit.
- 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.
- Conducting an internal investigation regarding compliance with Foreign Military Financing program requirements.
- Representing 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 an FCA litigation.
- Representing federal government contractor in audit negotiations with DCAA and DCMA, resulting in elimination and reduction of questioned costs.
- Providing regulatory counseling and preparing and submitting regulatory filings associated with the acquisition of two academically affiliated hospitals.
- Drafting comments for a health care client’s response to agencies’ Requests for Information seeking input about changes to the Stark Law and Anti-Kickback Statute.
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 recent pro bono representations include clients seeking asylum or legal immigration status under the Violence Against Women Act and successfully defending against eviction attempts by a client’s landlord. Payal received her J.D. from Columbia University Law School, where she served as a staff member for the Journal of Gender and Law. Payal graduated with highest honors from the University of North Carolina at Chapel Hill with a B.S. in business administration and global studies.
Affiliations
Admitted to practice: District of Columbia, New York
Speeches & Presentations
-
"The 101 of 101: The Foundation of Government Contracting," Crowell & Moring's Government Contracts 101 Seminar 2021
(October 18, 2021).
Speakers: Craig Barrett, Lorraine M. Campos, Gabrielle Trujillo, and Payal Nanavati.
-
"Health Care Investigations: FCA and Beyond," Investigations: Readiness and Response Webinar Series
(April 29, 2021).
Presenters: Troy A. Barsky, Michael Shaheen, Roma Sharma, and Payal Nanavati.
-
"A Look at the Top False Claims Act Developments of 2020," Healthcare Ounce of Prevention Seminar (HOOPS) 2021: Health Care in the Biden Era
(February 24, 2021).
Presenters: Michael Shaheen, Nkechi Kanu, and Payal Nanavati.
-
"Part 2 - A Look at the Top False Claims Act Developments of 2020," Crowell & Moring Webinar
(February 18, 2021).
Presenters: Michael Shaheen, Nkechi Kanu, and Payal Nanavati.
-
"The 101 of 101: The Foundations of Government Contracting," Government Contracts "101" - Back to Basics Webinar
(September 21, 2020).
Presenters: Lorraine M. Campos, Christian N. Curran, Gabrielle Trujillo, and Payal Nanavati.
Publications
-
"FEATURE COMMENT: The Top FCA Developments Of 2021," The Government Contractor, Vol. 64, No. 7
(February 16, 2022).
Authors: Tully McLaughlin, Lyndsay A. Gorton, Nkechi Kanu, Payal Nanavati, and Matt Vicinanzo.
-
"The Top Healthcare FCA Developments Of 2020," Compliance Today
(May 4, 2021).
Authors: Michael E. Shaheen, Matthew P. Vicinanzo, and Payal Nanavati.
-
"DoD Increases DCMA Cybersecurity Responsibilities: DCMA to Implement and Assess Company-Wide Cyber Compliance," Crowell & Moring's Government Contracts Legal Forum
(February 21, 2019).
Authors: Evan D. Wolff, Kate M. Growley, CIPP/G, CIPP/US, Michael G. Gruden, CIPP/G, Payal Nanavati and Judy Choi.
-
"FEATURE COMMENT: The Top FCA Developments Of 2018," The Government Contractor
(January 23, 2019).
Authors: Brian Tully McLaughlin, Jason M. Crawford, Sarah A. Hill, and Payal Nanavati.
-
"MA/PDP Star Ratings: Proposed Technical Changes for 2020," Crowell & Moring's Health Law Blog
(November 8, 2018).
Authors: A. Xavier Baker, Barbara H. Ryland, Joe Records and Payal Nanavati.
-
"Incumbent Employees’ Self-Disclosure of Salaries is Not a Procurement Integrity Act Violation," Crowell & Moring's Government Contracts Legal Forum
(May 23, 2018).
Authors: Olivia Lynch and Payal Nanavati.
-
"FDA’s Medical Device Safety Action Plan," Crowell & Moring's Health Law Blog
(May 8, 2018).
Authors: Jodi G. Daniel, Maya Uppaluru, Traci Vitek and Payal Nanavati.
-
"The Freight Train Gathers Steam: An Update on the Federal Response to the Opioid Crisis," Crowell & Moring's Health Law Blog
(April 26, 2018).
Authors: Ashley N. Southerland, Jodi G. Daniel, Traci Vitek and Payal Nanavati.
-
"New Draft NIST Guidance on Systems Security Engineering," Crowell & Moring's Government Contracts Legal Forum
(April 24, 2018).
Authors: Evan D. Wolff, Peter B. Miller, Maida Oringher Lerner, Kate M. Growley, Judy Choi, Michael G. Gruden and Payal Nanavati.
-
"GAO Implements Changes to Bid Protest Process with New Regulations," Crowell & Moring's Government Contracts Legal Forum
(April 11, 2018).
Authors: Anuj Vohra, Mark A. Ries, Christian N. Curran, Robert J. Sneckenberg, Rosamond Xiang and Payal Nanavati.
-
"Liberating Data to Transform Value-Based Care: MyHealthEData, Blue Button 2.0, and Price Transparency," Crowell & Moring's Health Law Blog
(March 16, 2018).
Authors: Jodi G. Daniel, Ashley N. Southerland and Payal Nanavati.
-
"GAO Lets Stand an Agency’s OCI Waivers in Face of a Multi-Prong Challenge," Crowell & Moring's Government Contracts Legal Forum
(March 14, 2018).
Authors: Olivia Lynch, Daniel Wierzba and Payal Nanavati.
Client Alerts & Newsletters
-
"Payers, Providers, and Patients – Oh My!: Massive Federal Investment in Mental Health,"
Podcast: Payers, Providers, and Patients – Oh My!
(July 28, 2022).
Contacts: Payal Nanavati, Joe Records, W. Scott Douglas, Charlotte Freed
-
"Payers, Providers, and Patients – Oh My!: Crowell Health Solutions Mini-Series Part 2 – A Health System’s Perspective on Prioritizing Health Equity,"
Podcast: Payers, Providers, and Patients – Oh My!
(June 21, 2022).
Contacts: Payal Nanavati, Joe Records, Janet C. Walker, Roma Sharma
-
"Payers, Providers, and Patients – Oh My!: Crowell Health Solutions Mini-Series Part 1 - The Intersection of Technology and Value-Based Care,"
Podcast: Payers, Providers, and Patients – Oh My!
(April 25, 2022).
Contacts: Payal Nanavati, Joe Records, Troy A. Barsky
-
"Payers, Providers, and Patients – Oh My!: What to Expect in Health Care Transactions in 2022,"
Podcast: Payers, Providers, and Patients – Oh My!
(March 28, 2022).
Contacts: Payal Nanavati, Joe Records, Kathryn Lynn Raffensperger, Todd D. Rosenberg, Alexis J. Gilman
-
"Payers, Providers, and Patients – Oh My!: What Health Care Companies Should Know about Developments in FCA Litigation,"
Podcast: Payers, Providers, and Patients – Oh My!
(February 28, 2022).
Contacts: Payal Nanavati, Joe Records, Matthew Vicinanzo
-
"The Top FCA Developments of 2021,"
Government Contracts Bullet Points
(February 25, 2022).
Contacts: Brian Tully McLaughlin, Lyndsay A. Gorton, Nkechi Kanu, Payal Nanavati, Matthew Vicinanzo
-
"Payers, Providers, and Patients – Oh My!: Reflecting on the First Year of the 2020 Stark & AKS Regulations,"
Podcast: Payers, Providers, and Patients – Oh My!
(January 14, 2022).
Contacts: Payal Nanavati, Joe Records, Troy A. Barsky, Roma Sharma
-
"Payers, Providers, and Patients – Oh My!: The New World of Health Data Interoperability,"
Podcast: Payers, Providers, and Patients – Oh My!
(December 8, 2021).
Contacts: Payal Nanavati, Joe Records, Jodi G. Daniel, Savanna Williams
-
"Payers, Providers, and Patients – Oh My!: How Health Plans Can Address Social Determinants of Health,"
Health Care Alert
(November 23, 2021).
Contacts: Payal Nanavati, Joe Records, Janet C. Walker
-
"Payers, Providers, and Patients – Oh My!: Business and Clinical Considerations for the Ketamine Industry,"
Podcast: Payers, Providers, and Patients – Oh My!
(October 25, 2021).
Contacts: Payal Nanavati, Joe Records, Lidia Niecko-Najjum, John T. Brennan Jr.
-
"Payers, Providers, and Patients – Oh My!: Recent Mental Health Parity Enforcement Activities,"
Podcast: Payers, Providers, and Patients – Oh My!
(September 22, 2021).
Contacts: Payal Nanavati, Joe Records
-
"Affordable Care Act Survives Third Supreme Court Challenge,"
Health Care Alert
(June 22, 2021).
Contacts: Stephen J. McBrady, Daniel W. Wolff, Payal Nanavati, Jay DeSanto, Ellie Riegel, Joe Records
-
"Payers, Providers, and Patients – Oh My!: The ACA Risk Corridors Case,"
Podcast: Payers, Providers, and Patients – Oh My!
(February 22, 2021).
Contacts: Stephen J. McBrady, Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Data Analytics and FCA Investigations,"
Health Care Alert
(January 21, 2021).
Contacts: Michael Shaheen, Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Rating in the Time of COVID,"
Podcast: Payers, Providers, and Patients – Oh My!
(December 10, 2020).
Contacts: Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: ERISA Preemption of State PBM Regulation,"
Podcast: Payers, Providers, and Patients – Oh My!
(August 3, 2020).
Contacts: Todd D. Rosenberg, Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My! - Bostock and HHS’s Nondiscrimination Regulations,"
Podcast: Payers, Providers, and Patients – Oh My!
(June 29, 2020).
Contacts: Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My! - Who CARES: The Provider Relief Fund and Other CARES Act Provisions,"
Health Care Alert
(June 4, 2020).
Contacts: Joe Records, Payal Nanavati, Matthew Vicinanzo
-
"Payers, Providers, and Patients – Oh My!: What Providers Should Know about COVID-19 (Part 2 – Federal and State Guidance),"
Podcast: Payers, Providers, and Patients – Oh My!
(March 27, 2020).
Contacts: Joe Records, Payal Nanavati, Brian McGovern
-
"Payers, Providers, and Patients – Oh My!: What Providers Should Know about COVID-19 (Part 1 – Labor and Employment Issues),"
Podcast: Payers, Providers, and Patients – Oh My!
(March 26, 2020).
Contacts: Eric Su, Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Medical Loss Ratios (Part 2),"
Podcast: Payers, Providers, and Patients – Oh My!
(March 18, 2020).
Contacts: Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Medical Loss Ratios (Part 1),"
Podcast: Payers, Providers, and Patients – Oh My!
(February 25, 2020).
Contacts: Joe Records, Payal Nanavati
-
"The Top FCA Developments of 2019,"
GSA Schedule Bullet Points
(January 30, 2020).
Contacts: Brian Tully McLaughlin, Nkechi Kanu, Payal Nanavati
-
"FY 2020 NDAA,"
Government Contracts Bullet Points
(January 16, 2020).
Contacts: Adelicia R. Cliffe, Peter Eyre, John E. McCarthy Jr., Nicole Owren-Wiest, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Digital Health Innovation,"
Podcast: Payers, Providers, and Patients – Oh My!
(January 14, 2020).
Contacts: Jodi G. Daniel, Robert Holleyman, Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Multi-State Plan Program,"
Podcast: Payers, Providers, and Patients – Oh My!
(December 12, 2019).
Contacts: Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Pharmacy Benefit Managers,"
Podcast: Payers, Providers, and Patients – Oh My!
(November 13, 2019).
Contacts: Todd D. Rosenberg, Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: FDA Digital Health Guidance,"
Podcast: Payers, Providers, and Patients – Oh My!
(October 23, 2019).
Contacts: Jodi G. Daniel, Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Medicare Advantage Supplemental Benefits,"
Podcast: Payers, Providers, and Patients – Oh My!
(October 10, 2019).
Contacts: Barbara H. Ryland, Joe Records, Payal Nanavati
-
"If You Don't Ask, You Don't Get: Hearings Not Guaranteed in "Granston Memo" Dismissals,"
Government Contracts Bullet Points
(September 17, 2019).
Contact: Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Removal under ERISA,"
Podcast: Payers, Providers, and Patients – Oh My!
(September 11, 2019).
Contacts: Joe Records, Rochelle-Leigh Rosenberg, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Some Potential Impacts of Legal Challenges to the ACA,"
Podcast: Payers, Providers, and Patients – Oh My!
(August 21, 2019).
Contacts: Troy A. Barsky, Joe Records, Alice Hall-Partyka, Payal Nanavati
-
"CMS Proposes Changes to its Stark Law Advisory Opinion Process,"
Health Care Alert
(August 13, 2019).
Contacts: Troy A. Barsky, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Health Care Compliance Programs,"
Podcast: Payers, Providers, and Patients – Oh My!
(August 7, 2019).
Contacts: Payal Nanavati, Joe Records
-
"Payers, Providers, and Patients – Oh My!: Private Equity Investing in Health Care,"
Podcast: Payers, Providers, and Patients – Oh My!
(July 24, 2019).
Contacts: Lex Eley, Joe Records, Payal Nanavati
-
"Payers, Providers, and Patients – Oh My!: Fiduciary Duties Under ERISA,"
Podcast: Payers, Providers, and Patients – Oh My!
(July 10, 2019).
Contacts: Payal Nanavati, Joe Records
-
"Payers, Providers, and Patients – Oh My!: FCA Dismissals Under the Granston Memo,"
Podcast: Payers, Providers, and Patients – Oh My!
(June 26, 2019).
Contacts: John T. Brennan Jr., Joe Records, Payal Nanavati
-
"DOJ Centralizes Guidance on "The Evaluation of Corporate Compliance Programs","
Government Contracts Bullet Points
(May 7, 2019).
Contacts: Thomas A. Hanusik, Derek A. Hahn, Lorraine M. Campos, Paul Freeman, Nkechi Kanu, Payal Nanavati
-
"The Top FCA Developments Of 2018,"
Government Contracts Bullet Points
(February 4, 2019).
Contacts: Brian Tully McLaughlin, Payal Nanavati
-
"DoD Rescinds IR&D "Technical Interchange" Requirement,"
Government Contracts Bullet Points
(September 4, 2018).
Contacts: Nicole Owren-Wiest, Payal Nanavati
-
"FY 2019 NDAA,"
Government Contracts Bullet Points
(August 15, 2018).
Contacts: Peter Eyre, J. Chris Haile, Anuj Vohra, Laura J. Mitchell Baker, Nkechi Kanu, Monica DiFonzo Sterling, Payal Nanavati
-
"ASBCA Dismisses Appeal for Lack of Jurisdiction After Government Claim Rescinded,"
Government Contracts Bullet Points
(July 9, 2018).
Contacts: Stephen J. McBrady, Nicole Owren-Wiest, Skye Mathieson, Payal Nanavati
-
"DoD Lightens Contractors' Burden on Voluntary Defective Pricing Disclosures,"
Government Contracts Bullet Points
(May 7, 2018).
Contacts: Nicole Owren-Wiest, Payal Nanavati
-
"GAO Implements Changes to Bid Protest Process,"
Government Contracts Bullet Points
(April 6, 2018).
Contacts: Christian N. Curran, Anuj Vohra, Payal Nanavati
-
"DOJ Memo Limits the Use of Agency Guidance in FCA Enforcement,"
False Claims Bullet Points
(February 22, 2018).
Contacts: Brian Tully McLaughlin, Payal Nanavati
-
"Contractor’s Unwaivable CDA Right to Board Review,"
Government Contracts Bullet Points
(December 5, 2017).
Contacts: Stephen J. McBrady, Charles Baek, Skye Mathieson, Payal Nanavati
Firm News & Announcements