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Paige Jennings assists clients with matters related to Medicare, Medicaid, the Affordable Care Act, pharmaceutical pricing, federal anti-kickback law, health information technology, and health care data and privacy. Ms. Jennings has particular experience with administrative appeals filed with the U.S. Department of Health and Human Services and related challenges in federal court.
Ms. Jennings joined the firm after working for a number of years on health policy matters in government and the private sector. Prior to earning her law degree and Master of Public Affairs, she worked in the U.S. Senate advising Senators John Breaux of Louisiana and Tom Carper of Delaware on health and social policy matters. Ms. Jennings later handled federal health policy issues for WellPoint, Inc. (now Anthem).
While in law school, Ms. Jennings worked with the U.S. Office of Management and Budget during consideration of the Affordable Care Act, and with the Federal Trade Commission for then-Chairman Jon Leibowitz. She clerked for the Honorable Royce C. Lamberth on the U.S. District Court for the District of Columbia.
- Successfully represented state government in appeal of nearly $100 million federal Medicaid disallowance.
- Representing hospital provider in litigation to recover reimbursement for emergency services rendered to Affordable Care Act plan enrollees.
- Representing health benefits company in administrative appeal of HHS decision involving the Medicare Part D prescription drug benefit program.
- Representing state government in appeal of $200 million federal Medicaid disallowance related to complex real estate and financial transactions.
- Assisted in preparation of amicus brief in King v. Burwell, No. 14-114 (U.S. Supreme Court 2015).
- Advised pharmaceutical clients on 340B pricing, Medicaid drug rebates, Medicare Part B pricing, and health care data transparency issues.
- Advised clients on issues related to the federal anti-kickback statute.
- Represented multiple state government clients in challenging disallowances of funds in federal programs.
Pro Bono
- Successfully challenged federal agency’s withholding of Affordable Care Act data from national non-profit organization in Freedom of Information Act suit. Secured releases of requested data for use in client’s online health plan comparison tools for consumers in multiple states.
- Advised non-profit organization on policy options for providing District of Columbia low-income seniors with home accessibility modifications.
- Represented local non-profit organization in administrative proceeding concerning the community health reinvestment obligations of a not-for-profit insurer.
Previous Experience
- U.S. Senator John Breaux, Legislative Assistant
- U.S. Senator Tom Carper, Legislative Assistant
- WellPoint, Inc., Federal Health Policy Manager
- Federal Trade Commission, Charles H. March Fellow
- U.S. Office of Management and Budget, Intern
May 15, 2020, Covington Alert
On May 7, 2020, the Centers for Medicare & Medicaid Services (“CMS”) announced that it had finalized the Notice of Benefit and Payment Parameters for 2021 (“2021 NBPP Final Rule”). The final rule, which will go into effect on July 13, 2020, expressly allows certain health plans to determine, to the extent permitted by state law, whether to count pharmaceutical ...
May 6, 2020, Covington Digital Health
On April 21, 2020, the Department of Health and Human Services (“HHS”) announced that, as a response to the COVID-19 public health emergency, it will exercise enforcement discretion to “permit compliance flexibilities” regarding the implementation of the interoperability final rules issued on March 9th, 2020. This joint announcement was made by the Office of ...
March 17, 2020, Covington Digital Health
On March 9, 2020, the Department of Health and Human Services (HHS) issued two final rules aimed at improving patient access to electronic health information (EHI), as well as the standardization of modes of exchange for EHI. The rules, which were issued by the Office of the National Coordinator for Health Information Technology (ONC) and...… Continue Reading
February 1, 2019, Covington Alert
The Department of Health and Human Services (HHS) Office of Inspector General (OIG) released a new rule yesterday proposing to revise the Anti-Kickback Statute safe harbor at 42 C.F.R. § 1001.952(h) to explicitly exclude manufacturer rebates and other price reductions on prescription drugs paid to Part D plans, Medicaid managed care organizations (MCOs), or ...
November 12, 2018
WASHINGTON—Covington is advising private equity firm Veritas Capital on healthcare and other regulatory aspects of its recently announced deal to acquire athenahealth for approximately $5.7 billion. athenahealth is a leading provider of network-enabled services for hospital and ambulatory customers nationwide. Rujul Desai and Ian Brekke are leading the Covington ...
December 11, 2017, Covington Alert
On November 28, 2017, the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register a proposed rule touching on a range of issues under the Prescription Drug Benefit (Part D) and Medicare Advantage (MA) programs, and implementing certain provisions of the Comprehensive Addiction and Recovery Act (CARA) and of the 21st Century Cures Act. 82 ...
February 7, 2017, Covington Digital Health
The full Senate could vote as early as this week on the nomination of Rep. Tom Price (R-GA) to be Secretary of the U.S. Department of Health and Human Services (HHS). In January, two Senate Committees held hearings on Rep. Price’s nomination. These hearings focused largely on Rep. Price’s stance on repeal of the Affordable...… Continue Reading
September 30, 2016, Covington Digital Health
Earlier this week the Government Accountability Office released a report critiquing the U.S. Department of Health and Humana Services’ (HHS) oversight of and guidance related to health information security and privacy. (The report is available here.) GAO cited the increasing incidence of hacking and other breaches, which affected over 113 million health records ...
July 28, 2016, Inside Privacy
Today we published a post on the Covington eHealth blog regarding a recent report by the U.S. Department of Health and Human Services (HHS), Office of the National Coordinator for Health Information Technology (ONC). The ONC report highlights “large gaps” in policies and oversight surrounding access to and security and privacy of health information held by...… ...
July 28, 2016, Covington Digital Health
Earlier this month the U.S. Department of Health and Human Services (HHS), Office of the National Coordinator for Health Information Technology (ONC), released a report to Congress highlighting “large gaps” in policies and oversight surrounding access to and security and privacy of health information held by certain “mHealth technologies” and “health social ...
April 19, 2016, Inside Government Contracts
On Monday, April 18th, the Health Resources and Services Administration (“HRSA”) and the Department of Health and Human Services (“HHS”) reopened the comment period for their proposed rule “340B Drug Pricing Program Ceiling Price and Manufacturer Civil Monetary Penalties Regulation” (“Proposed Rule”). Originally issued on June 17, 2015, the Proposed Rule sought ...
April 7, 2016, Covington Digital Health
Yesterday, the Senate Health, Education, Labor and Pensions (HELP) Committee held a final mark-up of legislation comprising the Committee’s counterpart to the House-passed 21st Century Cures Act. The HELP Committee approved five bills including S. 2713 to advance the development of “precision medicine” through research and data sharing. We have reported on the ...
October 23, 2015, Covington Digital Health
On October 20, 2015, the U.S. Food and Drug Administration (FDA) Center for Devices and Radiological Health (CDRH) released its top ten Regulatory Science Priorities for FY 2016 to facilitate improvements in the safety and effectiveness of medical devices and accelerate innovation. Several of the priorities would harness health information technology or health ...
September 15, 2015, Covington Digital Health
Today, we published a post on our InsidePrivacy blog regarding a proposed rule to amend federal Common Rule requirements. The proposal includes a number of changes related to privacy and data security and other changes relevant to entities seeking to conduct secondary research using collected data.… Continue Reading
September 15, 2015, Inside Privacy
On September 8, 2015, sixteen federal agencies published a long-awaited Notice of Proposed Rulemaking (NPRM) to modernize the Federal Policy for the Protection of Human Subjects, known as the “Common Rule.” The proposal, available here, includes a number of changes related to privacy and data security and other changes relevant to entities seeking to conduct...… ...
August 12, 2015, Covington Digital Health
Last week, the U.S. Senate unanimously approved a bill that would ease federal requirements that professionals seeing patients at ambulatory surgery centers (ASCs) “meaningfully use” certified electronic health records (EHRs). The measure would sunset after certified EHR technology is applicable to the ASC setting. The meaningful use program requires certain ...
June 22, 2015, Inside Government Contracts
On June 17, 2015, the Health Resources and Services Administration (HRSA) published a proposed rule to clarify how manufacturers should calculate the ceiling price for covered outpatient drugs under the 340B program, and to provide for civil monetary penalties (CMPs) on manufacturers that “knowingly and intentionally” overcharge 340B covered entities.[1] The ...
June 11, 2015, Covington Digital Health
Last week, the Centers for Medicare & Medicaid Services (CMS) made additional Medicare data publicly available and expanded the permissible uses of other data. For the third consecutive year, CMS released hospital-specific data on inpatient and outpatient charges, Medicare payments, and utilization for common Medicare procedures. CMS also released similar data ...
May 12, 2015, Inside Privacy
As we discussed in two prior posts (here and here), the April 29, 2015, draft House 21st Century Cures bill would make several changes to federal health privacy law. This post focuses on provisions that would relax limitations on payment for PHI disclosed for research purposes and that would expand the purposes for which covered...… Continue Reading
May 8, 2015, Inside Privacy
As we discussed in a prior post, the April 29, 2015, draft House 21st Century Cures bill would make several changes to federal health privacy law. This post focuses on provisions that would allow remote access to PHI for purposes preparatory to research and that would permit individuals to make a one-time authorization of the...… Continue Reading
May 6, 2015, Inside Privacy
On April 29, 2015, the U.S. House Energy and Commerce Committee released a revised discussion draft of the 21st Century Cures Act (“Cures”). The Cures bill would make several changes to existing federal privacy regulations promulgated under the Health Insurance Portability and Accountability Act (HIPAA) and the Health Information Technology for Economic and ...
December 2, 2014, Inside Privacy
In response to the recent Ebola outbreak and other events, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) has released guidance regarding the use and sharing of patient information in emergency situations. The guidance emphasizes that HIPAA requirements are not suspended during an emergency. However, the Privacy Rule ...
November 21, 2014, Global Policy Watch
In what many consider to be an unusual move, the Supreme Court agreed to hear a high-stakes case about the legality of premium subsidies for low- and moderate-income individuals enrolling in health coverage offered under the Affordable Care Act (ACA). The Court will review a unanimous decision by a Fourth Circuit panel in King v....… Continue Reading
November 18, 2014, Global Policy Watch
The mid-term election brings an historic changing of the guard in the health care leadership in Congress. Republicans will take control of the Senate in January and gain key chairmanships. Senior Democrats like Senators Harkin and Rockefeller, and Representatives Dingell and Waxman, who have been leaders on health policy issues for decades, are retiring. ...
Practices
Education
University of Texas School of Law, J.D., 2012
- With honors
- Order of the Coif
- Texas Law Review, Articles Editor
- Student Attorney, Criminal Defense Clinic
The Lyndon B. Johnson School of Public Affairs, The University of Texas at Austin, M.P.Aff., 2012
- Graduate Research Assistant, Health Policy
- Elected Member, Graduate Public Affairs Council
Duke University, B.S.
- Major in Biology, Minor in Chemistry
- magna cum laude