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Ivy K. Miller provides counsel on the full spectrum of health law matters to health care organizations, including health systems, physician groups, hospitals, and other health care providers and suppliers. Ivy regularly advises clients on corporate and transactional matters, privacy and security issues, and federal and state health care fraud and abuse compliance, helping them navigate a complex and ever-evolving legal and regulatory environment.

Ivy contributes to the firm’s Health Care and Life Sciences blog Health Law Diagnosis, highlighting health care market issues within the legislative landscape, as well as to scholarly and public interest publications. She has a proven ability to synthesize complex legal constructs and policy issues and has research experience with reproductive rights and health care access issues. Previously, as a health law intern at Robinson+Cole, Ivy conducted research on compliance issues, including HIPAA, 42 CFR Part 2, and provider licensure and tracked state-level legislation affecting health care providers.

In law school, Ivy was a legal intern for the Honorable Judge Margaret R. Guzman of the U.S. District Court for the District of Massachusetts, and she interned in health and reproductive justice initiatives in Boston, Minneapolis, and New York. Ivy holds dual degrees (J.D. and Master of Public Health) that allow her to draw on a strong health policy background to advise clients on new legislative initiatives and regulatory priorities.

  • Northeastern University School of Law (Juris Doctor)
    • Rappaport Center for Law and Public Policy, Fellow
    • Northeastern University Law Review
    • Massachusetts Supreme Judicial Court Pro Bono Honor Roll
  • Tufts University School of Medicine (Masters)
    • Public Health
  • University of California, Irvine (Bachelors)
    • B.A., Public Health Policy, Sociology Minor

  • Commonwealth of Massachusetts

Massachusetts Bar Association
 

Health Law Section Council

Publications


March/April 2026

How PBM Reform Suddenly Got Rolling

Massachusetts Bar Association Section Review
Massachusetts HPC Proposes to Update Material Change Reporting Requirements to Align with Newly Expanded Oversight Authority teaser
March 5, 2026

Massachusetts HPC Proposes to Update Material Change Reporting Requirements to Align with Newly Expanded Oversight Authority

Health Law Diagnosis
March/April 2024

Implications of Biden’s Proposed LTC Nurse Staffing Rule

Massachusetts Bar Association Section Review

The article covers proposed staffing standards for long-term care (LTC) facilities, potential added staff compensation reporting and compliance implications, and the impact the proposed rule would have on Massachusetts and Connecticut LTC facilities, if enacted. “The Proposed Rule would establish national, quantitative minimum nurse staffing standards for all LTC facilities,” they write. “CMS cites the link between consistent nurse staffing and quality and safety metrics as the driver for establishing these standards, with the ultimate goal of decreasing nationwide variability in nurse staffing and increasing quality and safety overall.” To read the article in full, click here.

March/April 2026

How PBM Reform Suddenly Got Rolling

Massachusetts Bar Association Section Review
Massachusetts HPC Proposes to Update Material Change Reporting Requirements to Align with Newly Expanded Oversight Authority teaser
March 5, 2026

Massachusetts HPC Proposes to Update Material Change Reporting Requirements to Align with Newly Expanded Oversight Authority

Health Law Diagnosis
March/April 2024

Implications of Biden’s Proposed LTC Nurse Staffing Rule

Massachusetts Bar Association Section Review

The article covers proposed staffing standards for long-term care (LTC) facilities, potential added staff compensation reporting and compliance implications, and the impact the proposed rule would have on Massachusetts and Connecticut LTC facilities, if enacted. “The Proposed Rule would establish national, quantitative minimum nurse staffing standards for all LTC facilities,” they write. “CMS cites the link between consistent nurse staffing and quality and safety metrics as the driver for establishing these standards, with the ultimate goal of decreasing nationwide variability in nurse staffing and increasing quality and safety overall.” To read the article in full, click here.

April 2024

HHS Proposes to Combat Abortion Bans by Protecting Reproductive Health Records

Northeastern University Law Review Online Forum

Read the article. 



April 2024

HHS Proposes to Combat Abortion Bans by Protecting Reproductive Health Records

Northeastern University Law Review Online Forum

Read the article. 

Health Law Diagnosis


Below is an excerpt of the Health Law Diagnosis blog posts authored by Ivy.

How PBM Reform Suddenly Got Rolling

Below is an excerpt of an article published in the Massachusetts Bar Association’s Section Review. Recent months have seen a significant shift in how pharmacy benefit managers (PBMs) are regulated at both the state and federal levels. PBMs are hired by health plans to manage administrative and other duties, while also serving as intermediaries by... Continue Reading

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Massachusetts HPC Proposes to Update Material Change Reporting Requirements to Align with Newly Expanded Oversight Authority

On February 5, 2026, the Massachusetts Health Policy Commission (HPC) published proposed amendments to its Material Change regulations at 958 CMR 7.00 (the Proposed Amendments). Among other things, the Proposed Amendments broaden the HPC’s market review authority by subjecting more transactions to the HPC’s Material Change Notice (MCN) process and provide the HPC greater latitude... Continue Reading

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HRSA Requests Comments on Second Iteration of 340B Rebates

On February 17, 2026, the Health Resources and Services Administration (HRSA) issued a Request for Information (RFI) regarding the use of rebates within the 340B Program. After an unsuccessful first attempt at deploying a rebate model late last year (as we previously wrote about here and here), HRSA is now seeking “input from interested parties... Continue Reading

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Government Withdraws Appeal in 340B Rebate Pilot Program Litigation, Signaling Shift

The recent litigation concerning the government’s 340B Rebate Model Pilot Program (the Rebate Program), as further described below, took an unexpected turn as the federal government recently signaled that it intended to revise its approach to the Rebate Program. This change in strategy was previewed by the government in a letter filed with the Court... Continue Reading

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Court Issues Nationwide Preliminary Injunction of the 340B Rebate Model Pilot Program

On December 29, 2025—just three days before the 340B Rebate Model Pilot Program (the Rebate Program) was set to begin—the U.S. District Court for the District of Maine issued an order granting a preliminary injunction to block the government’s implementation of the Rebate Program on January 1, 2026, after determining that the Health Resources and... Continue Reading

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CMS Adds New Requirements to Hospital Price Transparency Reporting

On November 21, 2025, the Centers for Medicare & Medicaid Services (CMS) published the CY 2026 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Final Rule (the Rule), which includes several significant changes to hospital price transparency regulations. The changes follow from Executive Order 14221, entitled “Making America Healthy Again by Empowering Patients with... Continue Reading

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Appeals Dropped of Decision Vacating HIPAA Reproductive Health Privacy Rule, Confirming Apparent End of the Rule and Attestation Requirement

On September 10, 2025, the U.S. Court of Appeals for the Fifth Circuit dismissed an appeal of the federal court ruling vacating key provisions of the HIPAA reproductive health care regulations, which appears to signal the end of the Purl case (previously discussed here) and to confirm the end of provisions of the HIPAA reproductive... Continue Reading

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OIG Shines Spotlight on Billing for Remote Patient Monitoring

This post is co-authored by Seth Orkand, co-chair of Robinson+Cole’s Government Enforcement + White-Collar Defense Team. On August 25, 2025, the Department of Health and Human Services Office of Inspector General (OIG) issued a new report (Report) highlighting trends in remote patient monitoring (RPM) Medicare billing, recommending stronger oversight to ensure compliance in billing for RPM services. The... Continue Reading

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Appellate Court Gives Go-Ahead for 340B Contract Pharmacy Insulin Pricing Suit to Proceed

This post was co-authored with Antitrust + Trade Regulation lawyer Jennifer Driscoll. On August 6, 2025, the U.S. Court of Appeals for the Second Circuit issued an opinion allowing a case challenging drug pricing changes to proceed. The case, an antitrust action brought by health centers against certain insulin manufacturers, arises from alleged anticompetitive actions taken... Continue Reading

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New York Streamlines CON Requirements for Medical Facility Construction Projects

On August 6, 2025, the New York Department of Health finalized and made effective significant changes to the Certificate of Need (CON) review process for health facility construction projects. The changes amend § 710.1 of Title 10 of the New York Codes, Rules, and Regulations (NYCRR), streamlining regulatory review and raising cost thresholds to reflect... Continue Reading

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