Department of Health and Human Services Office of General Counsel Statement of Organization Suggests Potential Consolidation, Expansion of Authority

The Department of Health and Human Services (HHS) has issued a revised Statement of Organization for the Office of the General Counsel (HHS-OGC). Changes include a return to an organizational structure more like the early days of the first Trump administration for the lawyers advising the Food and Drug Administration (FDA), as well as the closing of certain regional HHS-OGC offices. Additional changes could potentially signal an effort to consolidate and expand HHS-OGC’s authority, especially with respect to matters currently opined upon by lawyers advising the HHS Office of Inspector General (HHS-OIG). Stakeholders should consider opportunities to engage with HHS in light of the changes announced in the Statement of Organization.