Phyllis D. Thompson has been a partner in the law firm of Covington & Burling since
1989 and has practiced in the area of State health and welfare programs since shortly
after her arrival at the firm in 1982. She regularly advises and represents state and local
agencies and human services consulting firms with respect to issues that arise in
connection with federally-funded health and welfare programs, including Medicaid, Title
IV-E foster care, and various block grant programs.
Ms. Thompson’s experience with Medicaid program matters has been broad, and
includes advice relating to State plan amendments and plan interpretation;
reimbursement, rate appeals and cost-finding for hospitals, nursing facilities, intermediate
care facilities for the mentally retarded (ICFs/MR) and pharmacies; upper payment limits,
hospital disproportionate share payments; intergovernmental transfers and State matching
funds; home-and-community based services and waivers; institutions for mental disease
(IMDs) and psychiatric residential treatment facilities; assignment of claims; schoolbased services and educational records privacy; anti-kickback provisions; and tribal
health services. In connection with the Title IV-E program, Ms. Thompson has advised
clients on issues such as training-cost allocation, claiming of administrative costs, kinship
homes, eligibility and candidacy, voluntary placement agreements, and “reasonable
efforts” determinations. She has provided advice on cost allocation plan issues and
timely claims-filing issues in the context of a number of programs. Among other clients,
Ms. Thompson has worked with State agencies in Alaska, California, Connecticut,
Hawaii, Kansas, Louisiana, Maryland, Michigan, Mississippi, Missouri, Nebraska, New
Jersey, New York, North Carolina, Texas, and Washington. Ms. Thompson has
represented State agencies and coalitions of States in federal courts and in litigation
before administrative law judges of the U.S. Department of Health and Human Services
and the HHS Departmental Appeals Board.
Ms. Thompson is a graduate of the George Washington University (B.A. with distinction,
1974), holds a master’s degree from Princeton University (Religious Ethics, 1976), and
received her J.D. with high honors in 1981 from the George Washington University
National Law Center, where she was an editor of the George Washington Law Review.
From 1977 to 198 1, she taught ethics in the Department of Theology at Georgetown
University. She has been a member of the D.C. Bar Board of Governors, was Vice-Chair
of the D.C. Board of Appeals and Review, is Vice-Chair of the D.C. Court of Appeals
Committee on Admissions, and serves on the boards of a number of community
DC: 1568760- 1 -c3-
Home: 1362 Monroe Street, N.E. Work: Covington & Burling
Washington, D.C. 20017 1201 Pennsylvania Avenue, N.W.
Washington, D.C. 20004-2401
B.A. in Anthropology (With Distinction), 1974, Columbian College,
George Washington University
Honors: Phi Beta Kappa (elected junior year)
Dean’s List all semesters; Senior Class valedictorian
M.A. in Religion (concentration in ethics), 1976,
Princeton University
Princeton University Fellowship; Teaching Assistant to Professors
Paul Ramsey and Benjamin Ray
J.D. (with High Honors), 198 1, National Law Center, George Washington University
Notes Editor, The George Washington Law Review
Order of the Coif
October, 1989 – present: Partner, Covington & Burling, Washington, D.C.
Primary practice areas are federal health and welfare
programs, Medicare and Medicaid reimbursement, and
administrative law.
March – October, 1984: Staff lawyer, Neighborhood Legal Services Program (on loan from
Covington & Burling)
January 1982 – September, 1989: Associate, Covington & Burling, Washington, D.C.
September 1977 – May, 198 1 : Instructor (1 977-78) and Lecturer (part-time 1979-8 l),
Department of Theology, Georgetown University, Washington, D.C. Taught
courses in ethics and introduction to religious thought.
Summers, 1980 and 198 1 : Summer Associate, Covington & Burling, Washington, D.C.
Summer, 1 979: Research Assistant to Professor James Chandler,
DC: 167 1787- 1
National Law Center, George Washington University, Washington. D.C.
Have presented numerous speeches and seminars on federal health
and welfare program topics before various groups, including the
Conference of State Medicaid Directors, the American Association of
Public Welfare Attorneys, the National Case Mix Conference, the
National Association of Reimbursement Officers, the National
Association of State Mental Health Program Directors, the National
Academy of State Health Policy, and the Pharmaceutical Research
and Manufacturers Association.
D.C. Court of Appeals Committee on Admissions, April 2003 –
present; Vice-Chair since December 2003
D.C. Board of Appeals and Review, Vice-Chair and Legal Member,
200 1-2004
Board of Governors, D.C. Bar, 1998-2004; Member, D.C. Bar
Finance Committee and Governance Advisory Committee
Co-chair, D.C. Bar Public Service Activities Corporation LandlordTenant Task Force (1999 D.C. Bar award for “Best Bar Committee”)
Member, Steering Committee, District of Columbia Affairs Section,
D.C. Bar, 1985-86
Board of Trustees, the Washington International School
Board of Directors, Atlas Performing Arts Center
Board of Directors, Washington Legal Clinic for the Homeless
Board of Directors, Covington & Burling Public School Project, Inc
Board of Directors, Woodley House, Inc.
Board of Directors, Council for Court Excellence
Adjunct Professor, Georgetown University Law Center, Spring 1997
Member, D.C. Fellows of the American Bar Foundation
Born October 1, 1952, in Washington, D.C.