Skip to main content

Tara E. Dwyer

Member

[email protected]

+1.202.585.3504

Share:

Tara enjoys working with managed care organizations, pharmaceutical services providers such as PBMs, and integrated delivery systems, and companies that invest in them, on matters relating to compliance with federal health care program regulations, federal and state fraud, waste and abuse laws and plan benefits.

She works closely with Medicare Advantage Organizations (MAOs) and Medicare Part D Plan Sponsors, including Employer Group Waiver Plans (EGWPs), and first tier and downstream entities to address regulatory and compliance matters that arise as a result of participating in Medicare Parts C and D.  Tara often advises clients on matters relating to plan bids, medical loss ratio reporting, drug pricing in both Medicare Part B and Part D and direct and indirect remuneration (DIR) reporting.  She regularly counsels clients regarding risk adjustment systems and practices needed to support them. Tara also actively engages with CMS on behalf of clients on many matters.

She also works closely with discount medical and pharmacy plan operators (DMPOs) on matters relating to compliance with state laws and provider contracting.

Tara uses her substantive day-to-day compliance experience to assist clients in litigation matters and transactions. 

Tara has extensive experience preparing and negotiating complex services agreements for and between MAOs, providers, PBMs, pharmacies, wholesalers, manufacturers, and DMPOs.     

viewpoints

IRA Update Viewpoints Thumbnail

Mintz IRA Update — Fourth Edition: Q1 2025

February 13, 2025 | Article | By Rachel A. Alexander, Theresa Carnegie, Tara E. Dwyer, Lauren Moldawer, Hassan Shaikh, Stephnie John, Madison Castle, Mitchell Clough, Xavier Hardy, Samantha Hawkins, Alexander Hecht, Abdie Santiago

Mintz’s Pharmacy Benefits and PBM Contracting Practice is pleased to present the ‘Fourth Edition: Q1 2025’ of our Mintz IRA Update, a regular publication that delves into developments of the Inflation Reduction Act of 2022 (IRA) and their impact on pharmaceutical supply chain stakeholders.

Read more

PBM Policy and Legislative Update — Winter 2025

February 10, 2025 | Blog | By Theresa Carnegie, Tara E. Dwyer, Rachel A. Alexander, Lauren Moldawer, Bridgette Keller, Priyanka Amirneni, Madison Castle, David Gilboa, Xavier Hardy, Samantha Hawkins, Stephnie John, Alison H. Peters, Pamela Polevoy, Abdie Santiago, Hassan Shaikh, Sophia Temis

The PBM Policy and Legislative Update — Winter 2025 edition builds upon prior PBM Policy and Legislative Updates and summarizes activity from October through December (2024) that affects the PBM industry. It highlights (i) federal activities, (ii) state activities, and (iii) other noteworthy events and trends affecting the PBM industry.

Read more

Health Law Diagnosed – New Year's Gratitude

February 3, 2025 | Podcast | By Bridgette Keller, Alison H. Peters, Samantha Kingsbury, Theresa Carnegie, Joanne Hawana, Abdie Santiago, Stephnie John, Pamela Polevoy, Karen Lovitch, Jean D. Mancheno, Deborah Daccord, Rachel A. Alexander, Jane Haviland, David Gilboa, Kathryn Edgerton, Hassan Shaikh, Madison Castle, Laurence Freedman, Priyanka Amirneni, Samantha Hawkins, Tara E. Dwyer, Rachel Yount, Sophia Temis, Xavier Hardy

Host Of Counsel Bridgette Keller invites the Mintz Health Law team to reflect on what they’re grateful for as they prepare for the year ahead. Hear from a dynamic group of Members, Of Counsel, and Associates as they share their perspectives on what’s coming up over the horizon.

Read more

PBM Update: Special Edition - FTC Releases Second Interim Staff Report in PBM Inquiry

January 23, 2025 | Alert | By Rachel A. Alexander, Theresa Carnegie, Tara E. Dwyer, Joseph Miller, Lauren Moldawer, Bridgette Keller, Samantha Hawkins, Payton Thornton

In this Special Edition of the PBM Policy and Legislative Update, the Mintz Health team partnered with our Antitrust colleagues to analyze the FTC’s Second Report titled Specialty Generic Drugs: A Growing Profit Center for Vertically Integrated Pharmacy Benefit Managers.

Read more

Health Care Enforcement Trends & 2025 Outlook

January 17, 2025 | Blog | By Karen Lovitch, Samantha Kingsbury, Keshav Ahuja, Eoin Beirne, Grady Campion, Daniel Cody, Tara E. Dwyer, Laurence Freedman, Hope Foster, Jane Haviland, Nicole Henry, Caitie Hill, Robert Kidwell, Nick A. LaPalme, Scott Lashway, Kevin McGinty, Payton Thornton, Matthew Stein, Rachel Yount

Our 2025 edition of EnforceMintz reflects on health care enforcement trends, predicts how health care enforcement may evolve, and offers practical guidance about what these trends and predictions mean for health care providers, payors, and other stakeholders.

Read more

EnforceMintz — Medicare Advantage and Part D Programs to Remain in the Enforcement Spotlight in 2025

January 16, 2025 | Blog | By Tara E. Dwyer, Nicole Henry, Caitie Hill

In 2024, the Department of Justices and Centers for Medicare & Medicaid Services intensified enforcement in Medicare Advantage and Part D, with a focus on risk adjustment audits and Star Ratings disputes. Key developments, including litigation and regulatory changes, signal heightened scrutiny for MAOs, PDP Sponsors, and their vendors in 2025.

Read more

PBM Policy and Legislative Update — Fall 2024

November 22, 2024 | Blog | By Rachel A. Alexander, Tara E. Dwyer, Theresa Carnegie, Bridgette Keller, Madison Castle, David Gilboa, Xavier Hardy, Samantha Hawkins, Stephnie John, Lauren Moldawer, Alison H. Peters, Abdie Santiago, Hassan Shaikh, Sophia Temis

Building upon prior issues and summarizing activity from July through September, the Fall 2024 PBM Update highlights federal legislative activity and oversight, state legislative activity and oversight, and other noteworthy events and trends affecting the PBM industry.

Read more

PBM Policy and Legislative Update — Summer 2024

July 31, 2024 | Blog | By Theresa Carnegie, Tara E. Dwyer, Rachel A. Alexander, Bridgette Keller, Madison Castle, David Gilboa, Xavier Hardy, Samantha Hawkins, Stephnie John, Pat Ouellette, Alison H. Peters, Abdie Santiago, Hassan Shaikh, Sophia Temis

Read more

Mintz IRA Update — The Consequences and Costs of Redesigning the Part D Program

July 15, 2024 | Blog | By Tara E. Dwyer, Lauren Moldawer, David Gilboa, Samantha Hawkins, Stephnie John, Matthew Tikhonovsky

Read about the 2025 redesign of the Medicare Part D program pursuant to the Inflation Reduction Act of 2022 and how those changes impact Medicare Part D plan sponsors, beneficiaries, and manufacturers.

Read more

Mintz IRA Update — Third Edition: Q2 2024

July 15, 2024 | Blog | By Rachel A. Alexander, Theresa Carnegie, Madison Castle, Mitchell Clough, Tara E. Dwyer, David Gilboa, Xavier Hardy, Samantha Hawkins, Stephnie John, Bridgette Keller, Lauren Moldawer, Abdie Santiago, Hassan Shaikh

In ‘Third Edition: Q2 2024’ of the Mintz IRA Update, we cover updates to the Medicare Drug Price Negotiation Program being considered by CMS, developments in litigation challenging the program, the consequences and costs of redesigning the Part D program, opposition to the use of march-in rights to lower drug prices, and the growing use of state prescription drug affordability boards.

Read more
Read less

News & Press

Press Release Thumbnail Mintz

187 Mintz attorneys have been recognized by Best Lawyers® in the 2025 edition of The Best Lawyers in America©. Notably, three Mintz attorneys received 2025 “Lawyer of the Year” awards, and 64 firm attorneys were included in the 2025 edition of Best Lawyers: Ones to Watch.

Press Release Thumbnail Mintz

Mintz announced today that 42 of its practices and 83 of its attorneys earned recognition in the 2024 edition of Chambers USA, a guide to the country’s leading law firms. Of those included in the guide, 18 attorneys and seven practice areas were awarded Chambers’ highest ranking, Band 1. The firm obtained new listings in three practice areas and 10 of its lawyers were recognized for the first time.

News Thumbnail Mintz

The Cigna Health Group signed a deal selling its Medicare businesses to Health Care Service Corporation (HCSC) for $3.7 billion. A Mintz team led by Tara Dwyer and Lauren Moldawer acted as regulatory counsel to The Cigna Group on the sale. In the deal, which is expected to close in the first quarter of 2025, HCSC will acquire Cigna’s Medicare lines including Medicare Advantage, Medicare supplement, and Medicare drug plans, as well as CareAllies, a unit that works with physician groups and other healthcare providers.

News Thumbnail Mintz

Member Tara Dwyer spoke to Bloomberg Law and discussed potential roadblocks delaying Medicare's plans for negotiating lower drug prices.

Press Release Thumbnail Mintz

Mintz is pleased to announce that 120 firm attorneys have been recognized as leaders by Best Lawyers® in the 2024 edition of The Best Lawyers in America©.

News Thumbnail Mintz

Mintz Member Tara Dwyer was quoted in Law360 examining the release of a Health and Human Services rule which prompted backlash and predictions of litigation.

News Thumbnail Mintz
Mintz Member Tara Dwyer was quoted in a Bloomberg Government article on the passage of the bipartisan infrastructure package and reconciliation bill, which would be paid for in part by delaying a controversial rebate rule – a rule which pharmacy benefit managers and insurers are in stiff opposition to.
News Thumbnail Mintz
Mintz Member and Chair of the firm’s Employee Benefits & Executive Compensation Practice Alden J. Bianchi and Member Tara E. Dwyer co-authored an article published by Bloomberg Tax & Accounting’s Compensation Planning Journal examining the U.S. Supreme Court’s recent decision in Rutledge v. Pharmaceutical Care Management Association, holding that the Employee Retirement Income Security Act of 1974 (ERISA) does not preempt an Arkansas statute that regulates reimbursement levels paid by Pharmacy Benefit Managers (PBMs) to local pharmacies, and its impact on employer-sponsored group health plans.
News Thumbnail Mintz
In an article published by Bloomberg Law, Mintz Member Tara E. Dwyer was quoted on the Trump administration’s proposed final rule, which is currently under review by the Office of Management and Budget, that would end legal shields for drug rebates.
Press Release Thumbnail Mintz
In the latest guide, Mintz garnered rankings as a top national firm in eight practice areas, and 32 firm attorneys were individually recognized.
This feature article discusses a potentially significant change proposed to Medicare Advantage audits by the Centers for Medicare & Medicaid Services (CMS). Health Law Member Tara Dwyer is among the industry sources quoted in the story providing commentary.
Mintz is pleased to announce that eight attorneys have been named Washington, D.C. Super Lawyers for 2018 and three others have been named Washington, D.C. Rising Stars. The annual publication identifies lawyers who have attained a high degree of peer recognition and professional achievement.
Press Release Thumbnail Mintz
Mintz is advising a consortium of investors led by TPG Capital and Welsh, Carson, Anderson & Stowe in their acquisition of Kindred Healthcare, Inc. The definitive agreement totals approximately $4.1 billion in cash including the assumption or repayment of net debt.
Eight Mintz attorneys have been named Washington, D.C. Super Lawyers for 2017 and four have been named Washington, D.C. Rising Stars. The list will be published in a special advertising supplement in The Washington Post Magazine and in a stand-alone magazine, Washington D.C. Super Lawyers Magazine.
Seven Mintz attorneys have been named Washington, D.C. Super Lawyers for 2015 and five have been named Washington, D.C. Rising Stars. The list will be published in a special advertising supplement in Washington Post Magazine and in a stand-alone Washington D.C. Super Lawyers Magazine.
Read less

Recognition & Awards

  • Best Lawyers in America: Health Care (2024, 2025)

  • Chambers USA: District of Columbia – Healthcare (2024)

  • Included on the Washington DC Super Lawyers Rising Stars: Health Care list (2016 - 2021)

  • The Legal 500 United States for Healthcare: Service Providers (2019-2020, 2024)

  • Order of the Coif

  • ABA-BNA Award for Excellence in the Study of Health Law

Read less