OBBBA Medicaid Work Requirements: New CMS Interim Final Rule Clarifying Community Engagement Activities, Exemptions

Ms. Farrell provides legal and regulatory counseling as well as investigation, litigation, and transactional support to healthcare payers, providers, suppliers, trade associations, and other healthcare businesses, including private equity and other healthcare investors. With vast experience in Medicare, Medicaid, and the Affordable Care Act, she also advises clients on federal healthcare program reimbursement, compliance, fraud and abuse matters and government investigations. For over a decade, Ms. Farrell served as the lead attorney advising the Centers for Medicare & Medicaid Services (CMS) within the U.S. Department of Health & Human Services on complex and high-profile Medicaid and Medicare initiatives, offering providers, health plans and businesses a deep understanding of how to navigate the complex laws and evolving policies underpinning Medicare and Medicaid, including the many opportunities for innovation under both programs.

Mr. Malone helps health care organizations navigate the most complex regulatory, transactional, and strategic issues in managed care and delivery system reform. Managed care organizations, provider groups, value-based enablement companies, and trade associations seek his advice on matters involving, among other things: Medicare Advantage, SNPs, Medicaid managed care organizations, commercial insurers, participants in the Program of All-Inclusive Care for the Elderly (PACE), Medicare Shared Savings Program and ACO REACH entities, self-funded group health plans, third-party administrators, and pharmacy benefit managers. With a distinguished body of work on dual-eligible delivery systems and the Mental Health Parity and Addiction Equity Act, Mr. Malone is also a trusted counselor on value-based payment arrangements, risk-bearing structures, and corporate governance for integrated care models. His practice bridges regulatory compliance, business strategy, and dispute resolution, allowing clients to operate confidently in a fast-evolving health care environment. Before entering private practice, Mr. Malone served in senior policy roles at the CMS, where he developed financing and delivery models for dual-eligible beneficiaries, advanced PACE expansion, and shaped Medicaid policy for medically frail populations. He is a frequent speaker and author on managed care law and policy. He also serves as an accreditation reviewer for URAC’s Mental Health Parity Accreditation Program, assessing compliance with federal parity requirements and industry best practices, and teaches Managed Care Law & Policy as an adjunct professor at The George Washington University Law School.