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Top 10 Column - HHS Restructuring: What It May Mean for Medicare Advantage and Part D Plans and Health Care Providers

Lauren Moldawer and Jeannie Mancheno

Top 10 Column - HHS Restructuring: What It May Mean for Medicare Advantage and Part D Plans and Health Care Providers
Twenty47studio via Getty Images

As spring arrived in the mid-Atlantic region, the Department of Health and Human Services (HHS) under Robert F. Kennedy, Jr. followed through with a previously announced Reduction in Force (RIF) that reduced the department’s workforce by a reported 10,000 employees and started the process of restructuring the organization as a whole. Among other department-wide restructuring plans, HHS is in the process of consolidating 28 different divisions into 15 divisions. As of April 4, 2025, it had also reduced the number of Regional Offices from ten to five. HHS also separately published an announcement about a reorganization with its Office of the General Counsel (HHS-OGC). 

The workforce RIFs and large-scale restructuring of HHS will impact the entire health care industry, with certain stakeholders such as Medicare Advantage (MA) plans and health care providers facing more of the brunt in the short term. We address each of those stakeholder groups briefly below.

Medicare Advantage and Part D Plans

As of the date of this post, we understand that most offices within the Centers for Medicare & Medicaid Services (CMS) responsible for Medicare Part C and Part D operations remain intact and were not impacted by the RIF. However, all Medicare Advantage plans’ account managers were located in the HHS Regional Offices, which as noted above have been cut in half. Many MA and Part D plans likely lost their account managers and will need to be assigned new ones. Remaining account managers may have increased caseloads, which may result in delays in communication with account managers.

Health Care Providers

The consolidation of the Regional Offices also could potentially impact provider enrollment processes, surveying, Change of Ownership (CHOW) determinations and approvals, and the processing of CMS-specific enforcement activities, including reasonable assurance determinations. While CMS had previously transitioned certain Regional Office enrollment and survey functions for some provider types to CMS's Center for Program Integrity and to the Medicare Administrative Contractors (MACs), the Regional Offices still play a role in enrollment, surveys, and CHOW functions.  Regional Offices also still process and determine reasonable assurance periods.  The consolidation of Regional Offices could create delays and bottlenecks for CHOW approvals, especially with more challenging CHOWs that require input from HHS-OGC whose footprint and staff have also been reduced.         

In addition, the Regional Office consolidation will impact provider audits performed by MACs, Unified Program Integrity Contractors, and other contractors. HHS-OGC provides oversight and training to these contractors and helps ensure uniformity in enforcement across regions. Consolidation and reduction in legal support to these entities may result both in delays in enforcement and inconsistent enforcement across providers. 

Submitted by Mintz