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Stephanie D. Willis

Phone: +1 202.624.2721
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

Chosen as a "Rising Star"
in Health Care by
Super Lawyers Magazine
in 2014 to 2019.

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).

The following list illustrates the range of Stephanie’s health care law experience:

Fraud and Abuse Compliance Matters:

  • Coordinating a large university health system’s internal investigation of its financial arrangements with physicians for compliance with the Physician-Self Referral Law (Stark Law) and subsequent reporting under the Centers for Medicare & Medicaid Services (CMS) Self-Referral Disclosure Protocol (SRDP).
  • Providing critical analysis and compliance advice to a U.S. subsidiary of an international pharmaceutical company regarding its potential liability and reporting obligations under the Physician Payments Sunshine Act enacted under the ACA.
  • Developing compliance programs to ensure health care providers and institutions educate employees and contractors about fraud, waste, and abuse laws, and the Foreign Corrupt Practices Act.

Privacy and Security Compliance Matters:

  • Managing the internal investigation and drafting of key notifications to patients related to unauthorized disclosures of data by a Medicaid managed care organization.
  • Advising a non-profit Federally Qualified Health Center (FQHC) on the review and implementation of its privacy and security policies and procedures under HIPAA and analogous state laws.

Certificate of Need/Licensure Matters:

  • Drafting and submitting CON applications and related filings for retail clinic, renal dialysis facility, and an acute care hospital, including a successful application for the largest hospital construction project in District of Columbia’s history.
  • Providing representation, including submission of interested party comments challenging CON applications filed in the District of Columbia and Maryland.

Health Care Reform Matters:

  • Coordinating the formation and governance of clinically integrated delivery systems, including accountable care organizations (ACOs) accepted into the Centers for Medicare & Medicaid Services Medicare Shared Savings Program (MSSP), large physician practices, independent physician associations (IPAs), and physician-hospital organizations (PHOs).
  • Providing regulatory counseling and advice to health care entities participating in other CMS-administered programs including the Comprehensive Care for Joint Replacement Initiative, Oncology Care Model, and Next Generation ACO Model.

In addition, Stephanie previously served as a contributing author for the District of Columbia Practice Manual’s chapter on Health Maintenance Organizations, and is currently one of the authors of the chapter on Managed Care Fraud and Abuse in the American Bar Association’s Health Care Fraud and Abuse: Practical Perspectives treatise. She also frequently writes blog posts and articles on emerging health care regulatory developments and is an active part of the firm’s multi-practice initiatives that focus on issues of relevance to multiple industries, such as Digital Health/Health IT, the Internet of Things (IoT), and Privacy and Cybersecurity.


  • Harvard University, A.B. government (2005)
  • Tufts University, M.P.H. (2009)
  • Northeastern University Law School, J.D. (2009)


Admitted to practice: District of Columbia, Massachusetts (inactive)

Leadership Positions

American Health Lawyers Association

  • Young Professionals Council Vice Chair (2014-2015)
  • Young Professionals Council Delegate to the Board of Directors (2015-2016)
  • Fundamentals in Health Law Conference Planning Committee (2016)

American Bar Association, Health Law Section

  • Web & Technology Committee (2014-current)

National Association of Health Services Executives-Washington Metropolitan Area Chapter

  • Law & Public Policy Committee Chair (2016)

Awards & Recognitions

  • Washington D.C. Super Lawyers: Rising Star - Health Care (2014-2019)
  • City Year: Washington, D.C. - Idealist of the Year (2013)

View More

"SAMHSA's "Final" Substance Use Disorder Records Confidentiality Rules: a Short-Term Change Towards Further Alignment with HIPAA in 2021," Health Care Alert (July 23, 2020). Contacts: Jodi G. Daniel, Stephanie D. Willis, Brandon C. Ge
Client Alert / Newsletter
"Medicare Agency Announces More Telehealth and Virtual Care Service Expansions in Second Round of Federal Waivers and Rule Changes," Health Care Alert (May 14, 2020). Contacts: Jodi G. Daniel, Stephanie D. Willis
Client Alert / Newsletter
"OIG Seeks Comment on Key Enforcement Parameters and Deadlines For Information Blocking; HHS Delays Enforcement," Health Care Alert (April 29, 2020). Contacts: Jodi G. Daniel, Roma Sharma, Maya Uppaluru, Stephanie D. Willis
Client Alert / Newsletter
"COVID-19 is Driving Telehealth Adoption: Understand the New Opportunities," Crowell & Moring Webinar (April 29, 2020). Presenters: Gary Baldwin, Jodi G. Daniel, Roma Sharma, and Stephanie D. Willis.
"Telehealth Guidance for Health Plans in California During the COVID-19 State of Emergency," Health Care Alert (April 16, 2020). Contacts: Gary Baldwin, Kevin B. Kroeker, Stephanie D. Willis
Client Alert / Newsletter
"Eligible Providers Can Now Apply for Telehealth Related Funding Through FCC COVID-19 Telehealth Funding Program," Health Care Alert (April 15, 2020). Contacts: Jacinta Alves, Jodi G. Daniel, Roma Sharma, Stephanie D. Willis
Client Alert / Newsletter
"HHS Lifts Major Barriers to Telehealth to Help Reduce the Spread of COVID-19," Health Care Alert (March 20, 2020). Contacts: Troy A. Barsky, Jodi G. Daniel, Barbara H. Ryland, Stephanie D. Willis, Joe Records, Roma Sharma, Michelle Chipetine
Client Alert / Newsletter
"CMS Finalizes New Requirements on Health Plans to Release Health Data; Updates Medicare Conditions of Participation for Hospitals to Send Electronic Notifications," Health Care Alert (March 11, 2020). Contacts: Jodi G. Daniel, Maya Uppaluru, Stephanie D. Willis
Client Alert / Newsletter
"HHS Finalizes Sweeping Regulations on Interoperability of Health Information and Information Blocking," Health Care Alert (March 9, 2020). Contacts: Jodi G. Daniel, Maya Uppaluru, Brandon C. Ge, Stephanie D. Willis, Amber Mulcare, CIPP-US
Client Alert / Newsletter
"Practice Fusion Settlement Highlights Government’s Increasing Focus on Health Information Technology Certification and Financial Relationships in Enforcement Actions," Health Care Alert (February 4, 2020). Contacts: Jodi G. Daniel, Kelly Hightower Hibbert, Stephanie D. Willis, Ian Logan
Client Alert / Newsletter

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Crowell & Moring LLP is an international law firm with more than 500 lawyers representing clients in litigation and arbitration, regulatory, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity. The firm has offices in Washington, DC, New York, Los Angeles, San Francisco, Orange County, London, Brussels, and Shanghai.

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