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Rachel Irving Pitts


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Rachel's practice primarily involves transactional and regulatory matters, including mergers and acquisitions, regulatory compliance review, telemedicine issues, and provider and service contracting matters for various health care providers, administrative organizations, payors, and health systems. She works with hospital systems, dialysis, long-term care, and retail providers, individual providers and practice groups, management companies, independent practice associations, and third-party administrators and payors.

Rachel has represented a variety of pro bono clients at the firm, including counseling a small business through start-up, advocating for a tenant in housing court, and successfully arguing for a client’s Social Security Disability Insurance benefits.

Prior to joining Mintz, Rachel was a law clerk for the Illinois Attorney General and worked for the Massachusetts Medical Society in its Membership and Legal Departments. While a student prosecutor at Boston University School of Law, she successfully briefed and argued against a motion to suppress evidence in a criminal hearing.


  • Boston University School of Law (JD)
  • University of Illinois - Urbana-Champaign (BS)


  • Member, Massachusetts Bar Association
  • Member, Boston Bar Association
  • Member, American Health Lawyers Association
  • Executive Board, Boston University Law Young Alumni Council
  • Vice Chair, BHCHP Emerging Leaders Board
  • Member, 2011 – 2012 Women’s Leadership Program, Greater Boston Chamber of Commerce


At Long Last, OIG Issues Final Rule for Beneficiary Inducement Safe Harbors

December 12, 2016 | Blog | By Rachel Irving Pitts, Carrie Roll, Ellyn Sternfield

More than two years since issuing the proposed rule, the HHS Office of the Inspector General (OIG) issued the long-awaited and highly anticipated final rule (the Final Rule) that provides amendments to the Anti-Kickback Statute (AKS) regulatory safe harbors and adds protections for certain payment practices and business arrangements under the beneficiary inducement provisions of the Civil Monetary Penalty Law (CMP).
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Updates on Privacy and Security in the EU

October 20, 2016 | Blog | By Rachel Irving Pitts

If you missed the Mintz Levin Privacy and Security Practice Webinar last week, you can still get it! The current Privacy Webinar Series is focusing on the EU General Data Protection Regulation (GDPR), which will impact how US businesses handle and process personal data from the EU, including possible changes to business processes.
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FTC Enforcement and Hershey Hospital Merger - Webinar this Friday

September 28, 2016 | Blog | By Rachel Irving Pitts

Join us this Friday at 1:30 pm EDT for a webinar with two of our Antitrust colleagues, Robert Kidwell and Bruce Sokler. They will discuss recent events in the Hershey Hospital merger and their impact on FTC's hospital merger enforcement program. Learn more about these recent updates from the comfort of your computer in our one-hour webinar.
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Mintz Highlights Legal Updates and Trends in Monthly TCPA Digest

August 25, 2016 | Blog | By Rachel Irving Pitts

Mintz TCPA & Consumer Calling Practice team has issued its first monthly newsletter with legal updates and trends in this area.  As we have pointed out before, the healthcare industry is not immune from litigation and enforcement based on the Telephone Consumer Protection Act (TCPA).
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OCR to Increase Investigations of Smaller HIPAA Breaches

August 19, 2016 | Blog | By Rachel Irving Pitts

HHS Office for Civil Rights will cast a wider net and increase its investigations into smaller HIPAA privacy breaches starting this month. OCR announced a new initiative to increase its efforts examining breaches that affect fewer than 500 individuals.
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NIH Signals “Paradigm Shift” with Policy on Multi-Site Studies

June 23, 2016 | Blog | By Rachel Irving Pitts, Dianne Bourque

Federally-funded clinical trials conducted at multiple sites will move to a single Institutional Review Board (IRB) review scheme under a new National Institutes of Health (NIH) Policy.The NIH has finalized its policy to have a single IRB (sIRB) of record conduct the required ethics review for multi-site studies.
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CMS Increases Oversight of Medicaid Managed Care Contracts

April 28, 2016 | Blog | By Rachel Irving Pitts

As noted in a post published yesterday, CMS issued the final rule regarding Medicaid managed care earlier this week. With this rule, CMS is taking a much more active role in overseeing states’ Medicaid managed care contracts.
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Opioids, FDA and Medicare Advantage Spending on the List for Congress

February 24, 2016 | Blog | By Rachel Irving Pitts

As Congress is back to Washington for its next work period, ML Strategies has published an Advisory outlining health care issues on the radar for the upcoming weeks. Highlights include: legislative initiatives on opioid abuse, mental health access, chronic care and a group of innovation bills; the FDA Commissioner nomination; and Medicare Advantage (MA) lobbying efforts.
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Safety of Both Devices and Drugs Need to Be Better Tracked, FDA Hears from Oversight Bodies

January 26, 2016 | Blog | By Joanne Hawana, Rachel Irving Pitts

FDA lacks the appropriate data to effectively conduct post market surveillance and safety tracking activities, according to two reports released earlier this month.
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Congressional Hearing Examines Competition in the PBM Industry

November 23, 2015 | Blog | By Theresa Carnegie, Rachel Irving Pitts

Last week, pharmacy benefit manager (PBM) and independent pharmacy representatives provided testimony to the House Judiciary Subcommittee on Regulatory Reform, Commercial and Antitrust Law in a congressional hearing examining the state of competition in the pharmacy and PBM marketplace.
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