HHS to Close 6 of 10 Regional OGC Offices, With Potentially Significant Impacts on Providers and Suppliers

On Tuesday, March 11, 2025, the U.S. Department of Health and Human Services (“HHS”) announced plans to close six of the nation’s 10 regional offices for the HHS Office of the General Counsel (“OGC”). These closures, which impact OGC offices in Boston, New York, Chicago, Dallas, San Francisco, and Seattle, represent a significant restructuring of legal operations that support the Centers for Medicare & Medicaid Services (“CMS”) and other HHS agencies at the regional level. Indeed, the closures may reduce the OGC staff by more than 100 attorneys across all offices.

OGC regional offices provide essential legal counsel to CMS regional offices and operations — supporting enforcement, compliance, and administrative functions across Medicare, Medicaid, and other federal healthcare programs (“FHCPs”). Historically, the OGC regional structure (below) has mirrored that of CMS regional offices, serving the same geographic areas to facilitate coordinated legal and regulatory oversight. Given OGC’s role and the critical operations supported, the decision to consolidate OGC regional offices into four remaining locations raises obvious questions regarding the potential downstream impacts on providers and suppliers.

HHS has not announced an official closure date for affected OGC offices. Once implemented, office closures and the repatterning of agency support may have significant implications for the day-to-day administration of the Medicare program and other FHCPs and, correspondingly, affect providers and suppliers across the industry. In some circumstances, cases will be redirected to the CMS Division of OGC in Washington, D.C., which has shrunk since the beginning of the new administration. In other circumstances, regional cases will be distributed as national capacity is available, which may mean cases will be handled by attorneys in offices remote from the originating location.

Possible Implications for Healthcare Providers and Suppliers

1. Delays in Administrative Compliance and Enforcement Actions
   OGC regional counsel manage a massive docket of administrative compliance and enforcement actions, including those that involve immediate jeopardy determinations and program exclusions that threaten provider enrollment. With regional offices closing, delays in such actions are possible. Delays would create uncertainty for hospitals, health systems, and other Medicare-participating providers ad suppliers, as we saw with the Medicare appeals backlog.
2. Disruptions to Change of Ownership (“CHOW”) Approvals
   Regional OGC counsel for CMS manage challenges to CHOW determinations, which are vital in healthcare transactions and provider acquisitions. The consolidation of regional legal oversight could lead to prolonged timelines for obtaining necessary approvals, potentially delaying mergers, acquisitions, and reorganizations.
3. Shifts in Regulatory Oversight and Legal Support
   CMS regional offices oversee state survey and certification activities, administrative contractor disputes, and reimbursement issues. The realignment of legal support services may lead to changes in enforcement approaches across jurisdictions, with some regions potentially seeing increased administrative bottlenecks.
4. Impacts on Medicare Administrative and Integrity Contractors
   The restructuring may affect the geographic distribution and workflow of Medicare Administrative Contractors (“MACs”) and program integrity contractors (e.g., Unified Program Integrity Contractors (“UPICs”)), which rely on regional-legal guidance to navigate complex payment disputes and fraud investigations. This is true even for providers in the four remaining offices.

What Comes Next?

HHS has not yet publicly provided an official timeline for the closures, nor has it clarified how existing OGC attorneys and workloads in the affected regions will be reassigned. Given that the impacted offices include those serving four of the five largest Medicare beneficiary populations (New York, California, Texas, and Illinois), the reallocation of legal resources will be critical for providers and suppliers seeking a smooth transition.

Healthcare providers and suppliers, particularly those with significant Medicare and FHCP business, could see potential delays in regulatory processes, including compliance actions, provider enrollment reviews, and appeals of adverse determinations. Providers with ongoing or anticipated legal matters involving CMS should take proactive steps to assess how these changes may impact case resolution and reimbursement operations.

These restructuring plans have been announced in a dynamic environment, and more questions remain regarding attorney reassignments and workload distribution across the remaining OGC offices. AGG anticipates continued developments as the new administration advances its restructuring efforts and policy changes.

AGG’s Healthcare & Life Sciences Team Can Help

AGG is closely monitoring policy and agency changes and their impact on healthcare provider reimbursement, transactions, compliance and operations. Our Healthcare & Life Sciences team, which includes former senior attorneys from CMS and HHS, offers deep insight into federal healthcare regulatory processes and the evolving landscape.