On March 11, 2025, the U.S. Department of Health and Human Services (HHS) announced plans for a “reorganization of the Office of the General Counsel” (OGC) “[a]s part of the department’s ongoing efforts to advance the Secretary Kennedy’s mission to Make America Healthy Again.” As part of this reorganization, the OGC plans to consolidate the number of regional offices from 10 to four, resulting in the closure of six regional offices in Boston, New York City, Chicago, Dallas, San Francisco and Seattle. Regional offices in Philadelphia, Atlanta, Denver and Kansas City will remain open, which, according to the announcement, “will provide the same geographic support for regional HHS offices at lower operating costs.” As part of the impact of these closures, Medicare, Medicaid and other federal health care program providers and suppliers can anticipate changes and potential delays in regulatory, enforcement and compliance actions.
The OGC is the legal team for HHS and “supports the development and implementation of HHS programs by providing the highest quality legal services to the Secretary of HHS and the organization’s various agencies and divisions,” including the Centers for Medicare & Medicaid Services (CMS). OGC’s regional offices provide legal counsel to CMS regional offices and support enforcement, compliance and administrative functions across Medicare, Medicaid and other federal health care programs. Historically, coordinated legal and regulatory oversight was facilitated by having both an OGC and CMS regional office serve the same geographic area. The decision to close six of the 10 regional OGC offices will likely impact this coordination with a repatterning of agency support, thus potentially impacting Medicare, Medicaid and other federal health care program providers and suppliers. While the announcement provides that the remaining four regional OGC offices “will provide the same geographic support for regional HHS offices,” the announcement does not indicate how the agency support will be redirected or redistributed to those regions affected by the OGC regional office closures.
Although HHS has not yet announced an official timeline or closure date for the affected OGC offices, Medicare, Medicaid and other federal health care program providers and suppliers should prepare for the potential downstream impacts. Such consolidation of regional legal oversight could result in delays in regulatory processes, including compliance actions, provider enrollment reviews and appeals of adverse determinations. In addition, providers and suppliers should expect shifts in regulatory oversight and legal support such as changes in enforcement approaches across jurisdictions.
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