Biography

Health care regulatory attorney Jason Christ extends his successful defense strategies in False Claims Act (FCA) actions by the government to safeguard clients’ Medicare Part C plan risk adjustment payment programs. As one of the first and few attorneys focused on risk adjustment in Medicare Advantage (MA) plans, Jason has transformed how clients organize, monitor, and ultimately defend their programs. He creates new business opportunities and best practices for risk-bearing provider groups, plans, and vendors.

As enforcement and regulation of risk adjustment and the FCA escalates, Jason anticipates threats. He devises balanced and compliant approaches that address his clients’ greatest exposures: coding fidelity, clinical effectiveness, oversight, and consistency in best industry practices. From program assessment to testing and corrective actions, Jason shows clients how to close the compliance gap.

Should government investigations, audits, or litigation arise, Jason reduces the damage clients face. He has negotiated scores of settlements with the U.S. Department of Justice (DOJ) and the Centers for Medicare & Medicaid Services (CMS) involving anti-kickback, false billing, civil monetary penalties, and other fraud and abuse laws. Jason’s all-in commitment has helped clients avoid program exclusions, corporate integrity agreements, penalties, and disclosures.

Jason’s range of health care clients spans from new entrants to MA and established regional and Fortune 500 payors to multispecialty physician groups, hospitals, vendors, and providers of vision care, dermatology, and other medical specialties. Committed to keeping clients ahead of health care regulations, Jason speaks about fraud and abuse issues to law students and industry groups.

Experience

  • Performed a “top to bottom” assessment of numerous regional insurers/MA organizations relating to risk adjustment policies, procedures, and compliance. Using his experience with the DOJ and CMS on investigations and risk adjustment data validation and other enforcement and audit matters, Jason led his team in providing operational and practice legal advice.  
  • Represented three MA health plans in connection with internal investigations and voluntary disclosures to CMS related to overpayments. The disclosures did not result in an assessment of additional penalties. In one instance, Jason assisted the MA organization with litigation to recoup amounts from a vendor whose services were central to the overpayment.
  • Served as external health regulatory counsel for Oak Street Health during its growth to a national platform through its successful IPO. Jason provided ongoing counsel and handled state and federal health regulatory matters, including risk adjustment audits, advice on payment arrangements, and Medicare compliance work.
  • Provided comprehensive response, strategy, and defense to a DOJ subpoena for Medi-Lynx, Inc., related to independent diagnostic testing facility (IDTF) remote cardiac monitoring services. During the investigation, Jason helped the client navigate its purchase of another IDTF (AMI Monitoring, Inc. dba Spectocor), which was also under investigation for similar alleged conduct. Jason’s strategy led to a comprehensive $13.5 million settlement.   
  • Operated as chief health care defense counsel on behalf of the former owners of HealthCare Partners, a multistate physician management company and medical practice that was purchased by DaVita. Jason defended claims against a $700+ million escrow and, most significantly, a DOJ investigation into risk adjustment practices that resulted in a $270 million FCA settlement.
Education
  • University of Maryland School of Law (J.D., with honors)
  • Pennsylvania State University (B.A., with distinction)
    • Phi Beta Kappa, Political Science
Court Admissions
  • U.S. District Court, District of Columbia
Bar Admissions
  • District of Columbia
  • Maryland
  • Pennsylvania
Memberships
  • American Health Lawyers Association
  • Penn State Alumni Association
Languages
  • Arabic
Recognition
  • The Legal 500 United States, Healthcare: Service Providers (2016, 2018, 2019), Next Generation Lawyers (2018, 2019)