Insights

Los Angeles – October 21, 2022: Inland Counties Legal Services has named Crowell & Moring associate Alice Hall-Partyka as the Volunteer of the Year in recognition of her efforts to “make access to justice a reality in Riverside & San Bernardino Counties.” The award was presented at the Advocates for Justice celebration on October 20 in Riverside, CA.

Washington – July 22, 2022:  Crowell & Moring is advising Amazon on health care and related matters in its acquisition of One Medical for approximately $3.9 billion. Completion of the transaction is subject to customary closing conditions and regulatory approvals.

On Friday April 26th, the Office of Civil Rights (“OCR”) at the U.S. Department of Health and Human Services (“HHS”) released regulations under Section 1557 of the Affordable Care Act[1] (“Section 1557”), the nondiscrimination provision of the Affordable Care Act (the “Final Rule”). Promulgated almost two years after OCR’s proposed rule for Section 1557, the Final Rule restores critical protections for LGBTQI+ and pregnant individuals and significantly expands the scope of activity that is subject to Section 1557’s nondiscrimination provisions, in both instances by removing limitations to the scope of Section 1557 that went into effect during the Trump Administration.

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur.

On July 21, 2023, the Department of Health Care Access and Information of the California Health and Human Services Agency released a Notice of Proposed Rulemaking (the “Proposed Rule”) with regulations that would implement new financial and ownership transparency requirements for skilled nursing facilities (“SNFs”) in California.

Join us for this year’s Health Care Ounce of Prevention Seminar (HOOPS), a webinar series where our experienced practitioners will provide insight into a number of exciting topics. This year’s seminar will focus on topics such as Remote Health Care and Telemedicine, Mental Health Parity, Health Care Litigation, and Health Care Trends for 2022. 

In this episode, hosts Payal Nanavati and Megan Beaver talk to Chris Flynn and Alice Hall-Partyka regarding the proposed updates to the regulations under the Mental Health Parity and Addiction Equity Act (MHPAEA). We discuss the current regulatory environment, enforcement, and key takeaways from the proposed rule. For further reading, please see:

Payers, Providers, and Patients – Oh My! Is Crowell & Moring’s biweekly health care podcast, discussing legal and regulatory issues that affect health care entities’ in-house counsel, executives, and investors. In this episode, hosts Payal Nanavati and Joe Records talk with Troy Barsky and Alice Hall-Partyka about how recent litigation challenging the constitutionality of the Affordable Care Act may impact providers and payers. The discussion focuses on the authority for innovative health care models and important fraud and abuse provisions that were enacted in the ACA.