Farrell

Caroline L. Farrell

Counsel
New York

Clients benefit from my analytical, strategic, and creative problem-solving skills.

Caroline 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, Caroline 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.

During her tenure at CMS, she represented the organization on issues of national importance in the Medicare and Medicaid programs, including advising CMS on issues related to the Affordable Care Act’s Medicaid expansion; the innovative programs sponsored by the Center for Medicare and Medicaid Innovation (CMMI); and Medicaid initiatives related to health equity and social determinants of health.

Caroline has extensive experience reviewing complex agreements for CMS, including the Special Terms and Conditions for Medicaid demonstration projects and waivers, participation agreements for CMMI models, and the three-way contracts for Medicare-Medicaid Plans under the capitated model of the Financial Alignment Initiative to better integrate care for dual-eligible beneficiaries. Her administrative law acumen enables her to provide clients with unique insights into complicated and ambiguous laws and processes that CMS is charged with implementing. 

While in law school, Caroline interned for the Honorable Richard D. Bennett of the U.S. District Court for the District of Maryland as well as the United States Attorney’s Office for the District of Maryland.

Education

  • University of Maryland School of Law, J.D., 2010
  • George Washington University, M.P.H., Health Policy, cum laude, 2007
  • George Washington University, B.A., Political Science, cum laude, 2005
     

Bar and Court Admissions

BAR ADMISSIONS
  • Maryland
  • New Jersey

Experience

PROFESIONAL EXPERIENCE
  • Maryland Carey School of Law, Adjunct Professor, MS in Law Health Reform Course
  • Attorney, U.S. Department of Health & Human Services, Office of the General Counsel, CMS Division, Program Review Branch

Honors & Involvement

HONORS
  • Articles Editor, Maryland Law Review
  • William P. Cunningham Graduation Award Recipient
  • Paul D. Bekman Leadership in Law Scholarship Recipient, Leadership Scholars Program
INVOLVEMENT
  • American Health Law Association, member; Institute on Medicare and Medicaid Payment Issues Planning Committee
  • NewYorkBIO, member
  • New York State Bar Association Health Law Section, member

Other Events

  • Speaker, "Value Reimagined: Healthcare Payment Reform in the Wake of OBBBA," American Bar Association Washington Health Law Summit (2025)
  • Panelist, "Policy, Pricing, and Market Access: Preparing for the Future," Foley Hoag's Boston Life Sciences Summit (October 2025)
  • Presenter, Practicing Law Institute’s Medicare and Medicaid Nuts and Bolts CLE (2016-2025)
  • Presenter, The American Health Law Association, Institute on Medicare and Medicaid Payment Issues (2016-2025)
  • Presenter, "Fundamentals of Health Law," The American Health Law Association (2016-2025)
  • Presenter, "Annual Meeting," The American Health Law Association (2018)
  • Presenter, "Health Law Section, Emerging Issues in Health Law," American Law Association (2018)