Crowell & Moring LLP is pleased to announce that Teresa D. Miller has joined the firm’s Health Care Group as a partner in Washington, D.C. Most recently, Miller served as the acting director for both the State Exchanges Group and the Oversight Group, at the Center for Consumer Information and Insurance Oversight (CCIIO), Centers for Medicare & Medicaid Services (CMS), Department of Health & Human Services (HHS). At CMS, Miller held leadership positions in matters related to the implementation and enforcement of the Affordable Care Act (ACA) and federal insurance regulations in the health care industry. Before working at CMS, Miller served as the administrator of the insurance division for the Oregon Department of Consumer and Business Services (DCBS).
“As both a former state and federal regulator, Teresa brings an impressive combination of government, legal, and industry skills and experience to our firm. Her extensive background implementing and advising on critical issues under the Affordable Care Act on a state and federal level, and her experience working with federal regulators, strengthen our ability to provide soup-to-nuts counsel to our clients in this ever-changing health care reform landscape,” said Arthur N. Lerner, co-chair of the firm’s Health Care Group. “Teresa’s addition to Crowell & Moring builds upon our Health Care Group’s continued growth in the regulatory and public policy arenas.”
As Oregon’s insurance administrator, Miller helped implement the early stages of the ACA at the state level. In the role of Oregon's top insurance regulator, she was also responsible for making significant changes to Oregon’s health insurance rate review process. While at CMS, Miller helped the agency roll out regulations and guidance for implementing the private market reforms of the ACA and helped develop and implement the policies and rules governing state-based exchanges. She was instrumental in putting key provisions of the ACA into practice, including preventing issuers from discriminating against individuals with pre-existing conditions, and working closely with states and issuers to ensure compliance with all of the new market reforms, including market rating reforms.
In her practice at Crowell & Moring, Miller will draw upon her extensive government experience to provide counseling related to the ACA’s impact on insurance companies and other health care payers. She will also help clients navigate through the complex areas of ACA compliance. Additionally, Miller will use her experience overseeing the federal Rate Review Program, the Medical Loss Ratio (MLR) Program, and the implementation of the market rules and transitional policy to assist clients in understanding and complying with policy and regulatory requirements.
“One of the toughest hurdles clients are facing is the duality of the significant increase in federal regulation under the Affordable Care Act, while states continue to have a primary role in regulating health plans. I look forward to drawing on my background and unique state and federal regulatory perspective to counsel and advise clients on how best to analyze and adhere to state and federal rules, regulations, and laws. In particular, I am eager to work with clients as they are trying to understand the interplay of both levels of ACA enforcement,” said Miller. “My broad understanding of the ACA, coupled with Crowell & Moring’s banner health care practice, is a perfect fit for me at this time in my career and a terrific asset for the firm’s clients. I am very excited about working with the Group’s deep bench of skilled attorneys to collaborate in counseling clients throughout the health care industry at this challenging time.”
During her tenure as a state regulator, Miller was a leader at the National Association of Insurance Commissioners (NAIC) when the organization was heavily involved in the early stages of ACA implementation. She received her B.A., magna cum laude, from Pacific Lutheran University and her J.D. from the Willamette University College of Law.
The arrival of Miller continues the expansion of Crowell & Moring's capabilities for providing services to health industry clients. Her practice compliments that of Health Care Group partner Troy Barsky, who joined the firm from CMS in 2013. His practice focuses on counseling and advising clients on risk and economic issues arising under the ACA, shaping innovative care delivery transactions, working with accountable care organizations (ACOs), assessing and ensuring compliance, and handling fraud and abuse defense work.
