Stephanie Willis

Stephanie Willis is a member of the firm's Health Care Group in Crowell & Moring's Washington, D.C. office. She counsels health care clients in matters involving regulatory issues, including fraud and abuse compliance, participation in new health care reform initiatives under the Affordable Care Act (ACA), as well as Certificate of Need (CON) and licensure matters. She has also advised clients on compliance with laws and regulations governing health IT initiatives and health care privacy and security, including the Health Insurance Portability & Accountability Act (HIPAA).

Firm/Organization: Crowell & Moring LLP

Blogs: C&M Health Law, Data Law Insights, Government Contracts Legal Forum

Latest Articles

C&M Health Law

HIPAA Spring Cleaning! Tidying Up Penalty Limits and FAQs on Patients’ Right of Access

By Jodi G. Daniel & Stephanie Willis on May 15, 2019

The HHS Office of Civil Rights (“OCR”) closed out the month of April with some updates to HIPAA civil monetary penalty (“CMP”) limits and clarifications to OCR’s stance on the Privacy Rule’s application to transfers of electronic protected health information (“ePHI”) to third-party applications and application programming interfaces (“APIs”). Differential CMP Caps Based on Enforcement Discretion Under the current HIPAA Enforcement Rule, HHS employs a four-tier level of culpability scale in line with the HITECH…

C&M Health Law

Government Affairs – The Progress of Telehealth Bills in Congress

By Traci Vitek, Jim Flood & Stephanie Willis on November 16, 2018

The Centers for Medicare & Medicaid Services (CMS) recently proposed a rule to allow Medicare Advantage plans to expand telehealth benefit coverage. (See alert for more detail) This proposed rule implements the statutory provisions in section 50323 the Bipartisan Budget Act of 2018. What you might not know, however, is that the Bipartisan Budget Act of 2018 is only one of many legislative vehicles by which advocates for telehealth expansion have been able to move…

C&M Health Law

2019 Physician Fee Schedule Rule Modifies Stark Regulations to Reflect Statutory Changes

By Troy A. Barsky, Meredith Parnell & Stephanie Willis on November 7, 2018

On November 1, 2018, the Centers for Medicare & Medicaid Services (“CMS”) filed the pre-publication version of the CY 2019 Physician Fee Schedule Final Rule (“2019 PFS Final Rule”). Within this massive publication, CMS finalized two regulatory changes affecting the exceptions at 42 CFR § 411.357 to the Physician Self-Referral Law (also known as the “Stark Law”) for compensation arrangements. The 2019 PFS Final Rule reconciles the regulations with the statutory changes made to the…

C&M Health Law

Digital Health Updates in the 2019 Physician Fee Schedule (PFS) Rule

By Jodi G. Daniel, Stephanie Willis & Maya Uppaluru on November 6, 2018

CMS has finalized the adoption of multiple CPT codes in the CY 2019 PFS that create more opportunities for providers and digital health companies to collaborate on chronic care management business models in the fee-for-service market. Virtual Check-Ins CMS finalized the creation of a new code to reimburse providers for brief “check-in” services conducted using communications technology by creating HCPCS code G2012, defined as “[b]rief communication technology-based service, e.g. virtual check-in.”…

C&M Health Law

Opioid Legislation: Expanding the Sunshine Act

By Stephanie Willis & Alice Hall-Partyka on October 15, 2018

On October 3rd, the United States Senate passed a bipartisan opioids package with a sweeping vote of 98 to 1, after the U.S. House of Representatives passed the final version of the bill with a vote of 393 to 8. One of its components, the “Fighting the Opioid Epidemic with Sunshine Act,” expands the scope of reporting requirements under the Physician Payment Sunshine Act (known as the “Sunshine Act”), which will have immense implications for…

C&M Health Law

CMS Proposed Rule Would Reduce States’ Health Care Access Monitoring Requirements

By Stephanie Willis & Matthew Vicinanzo on March 30, 2018

On March 22, 2018, the Centers for Medicare and Medicaid Services (CMS) announced a notice of proposed rulemaking (NPRM) that would, if finalized, exempt states with high rates of Medicaid beneficiaries in managed care plans from monitoring and reporting requirements related to Medicaid service access set forth in 42 C.F.R. §§ 447.203 and 447.204. The regulations currently require states to analyze and document the impact of Medicaid fee-for-service (FFS) payment amounts on beneficiary…

Data Law Insights

New OCR Settlement Targets Safety Net Provider on Security Rule Deficiencies

By Daniel Vinish, Maida Oringher Lerner, Kate M. Growley, CIPP/G, CIPP/US & Stephanie Willis on April 14, 2017

On Wednesday, the U.S. Department of Health and Human Services, Office for Civil Rights announced a $400,000 settlement with Metro Community Provider Network arising from MCPN’s alleged failure to implement adequate security management processes to safeguard electronic protected health information in accordance with the Health Insurance Portability and Accountability Act Security Rule. This settlement followed an investigation that OCR undertook in response to a breach report that MCPN filed on January 27, 2012. While OCR…

C&M Health Law

New OCR Settlement Targets Safety Net Provider on Security Rule Deficiencies

By Daniel Vinish, Maida Oringher Lerner, Stephanie Willis & Kate M. Growley, CIPP/G, CIPP/US on April 14, 2017

Government Contracts Legal Forum

Valentine’s Day Disappointment for FCA Practitioners Hoping for a Ruling on Stat Sampling

By Gail D. Zirkelbach, Jason M. Crawford, Mary Kate Healy & Stephanie Willis on February 22, 2017

On February 14, the Fourth Circuit issued an opinion in United States ex rel. Michaels v. Agape Senior Cmty. Inc. addressing only the first of the two issues that the district court had certified for interlocutory appeal: (1) whether the Department of Justice (DOJ) possesses an unreviewable veto authority over proposed settlements and (2) whether statistical sampling, the analysis of data from a subset of the population of interest in order to make projections across…

C&M Health Law

CMS Issues Final Rules on MACRA Quality Payment Program Implementation

By Harsh P. Parikh & Stephanie Willis on October 19, 2016

On November 2, 2016, the final rule with comment period (the “Final Rule”) implementing provisions of the Medicare Access and CHIP Reauthorization Act (MACRA) relating to the new Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) will be published in the Federal Register. The Center for Medicare and Medicaid Services (CMS) also launched a new website with tools and updates to help MIPS-eligible clinicians learn and prepare for participation in MIPS and…

Stephanie Willis

HIPAA Spring Cleaning! Tidying Up Penalty Limits and FAQs on Patients’ Right of Access

Government Affairs – The Progress of Telehealth Bills in Congress

2019 Physician Fee Schedule Rule Modifies Stark Regulations to Reflect Statutory Changes

Digital Health Updates in the 2019 Physician Fee Schedule (PFS) Rule

Opioid Legislation: Expanding the Sunshine Act

CMS Proposed Rule Would Reduce States’ Health Care Access Monitoring Requirements

New OCR Settlement Targets Safety Net Provider on Security Rule Deficiencies

New OCR Settlement Targets Safety Net Provider on Security Rule Deficiencies

Valentine’s Day Disappointment for FCA Practitioners Hoping for a Ruling on Stat Sampling

CMS Issues Final Rules on MACRA Quality Payment Program Implementation

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