Overview

Health care providers, payers, digital health companies, and investors call on attorney Christine Burke Worthen for legal and strategic advice as they navigate complex regulatory and business challenges in the continuously evolving health care delivery and reimbursement landscape.

Her practical guidance enables clients across the health care ecosystem—health systems, hospitals, physician practices, digital health companies, behavioral health providers, third-party administrators, health plans, and investors—to implement both short- and long-term strategies that align with their organizational goals.

Christine possesses a wealth of experience working on matters concerning Medicare reimbursement, Medicare Advantage, participation in CMS Innovation Center payment models, managed Medicaid, managed care contract negotiations, and value-based payment arrangements with commercial payers, self-insured employers, and Medicare Advantage plans. She provides counsel on the regulatory, operational, and financial considerations necessary for maneuvering through the changing payment environment, including various forms of risk-based payment models, price transparency, revenue cycle and payment integrity, clinically integrated network development and value-based enterprise models, risk adjustment, and provider compensation arrangements.

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New market entrants rely on Christine for assistance in establishing compliant care delivery models across markets, whether through traditional brick-and-mortar models, home-based models, or virtual models of care, and transforming innovative ideas into reimbursable strategies. Investors rely on Christine for assistance with evaluating the opportunities for optimizing payer contracts and network relationships to achieve sustainable financial performance and regulatory due diligence in transactions.

Christine also advises on other areas of concern for payers, investors, and providers, such as health care fraud and abuse compliance, HIPAA/Part 2 compliance, licensing, mental health parity compliance, and payer disputes.

Beyond her health care practice, Christine provides ERISA counsel to employers regarding their defined benefit and defined contribution retirement plans, as well as self-insured and fully insured welfare benefits plans. She has represented clients in government audits conducted by the IRS and the U.S. Department of Labor.

Before joining Epstein Becker Green, Christine was a partner in the health care practice of a national law firm. She previously served as Vice President and Senior Counsel at a health system in Maine. Earlier in her career, Christine was a partner and chair of the Healthcare Services Practice Group in a regional law firm's Portland (Maine) and Boston offices.

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Focus Areas

Experience

Representative Health Care Matters

  • Advise regional and multistate health systems on designing and deploying multiyear managed care contracting strategy to optimize fee-for-service reimbursement, evaluate and negotiate risk arrangements, advise on chargemaster and price transparency, standardize quality programs across payers, and resolve payment disputes.
  • Assist providers and plans with day-to-day Medicare Advantage regulatory compliance, operations, and claims issues, and advise on joint venture models and co-branded product development.
  • Provide counsel on the design and negotiation of specialty care reimbursement models for women’s health, oncology, pulmonary, sickle cell anemia, bariatric, orthopedics, and cardiology, including the design and negotiation of quality measures, physician compensation, and telehealth considerations.
  • Advise investors of due diligence and financial performance opportunities for acquisition targets, including physician practices, digital health platforms, and post-acute care providers.
  • Assist with the design and development of value-based enterprises as part of risk assumption and clinical integration strategy for health systems; independent provider groups, including specialty care providers; and post-acute care providers.
  • Serve as outside general counsel for a ground-and-air ambulance company for ongoing regulatory counsel, including managed care contracts and No Surprises Act issues.
  • Represented a digital health company in network development, licensing, and payer negotiations to deploy a multistate bundled payment specialty care model.
  • Represented a health system in the reorganization of its clinically integrated network and provider relationships to optimize fee-for-service and value-based care strategy and integrate community-based services.
  • Represented a digital health company and specialty care provider on corporate practice of medicine issues, network development, licensing, risk-bearing entity considerations, and payer negotiations to deploy a care management model for patients with complex care needs in multiple markets.
  • Assisted with the negotiation of outsourced revenue cycle arrangements for a multistate health system.
  • Advised a start-up on the design and implementation of a care management program that integrates behavioral health with primary care and provides home visits for chronic care patients.

Representative ERISA and Other Benefit Plan-Related Matters

  • Provide advice to plan sponsors of self-insured health plans on network development and alternative payment models, including risk-based payments, bundled payments, and gainsharing arrangements with third-party administrators.
  • Counsel plan sponsors of self-insured health plans and insurance companies on compliance with the Mental Health Parity and Addiction Equity Act, including providing assistance with comparative analyses for nonquantitative treatment limitations and audit support.
  • Provide ongoing ERISA advice and counsel to large employers related to health and welfare as well as retirement plans, including support with IRS and U.S. Department of Labor investigations.
  • Advise new entrants in the third-party administrator market on state licensing issues, ERISA issues, network design/development, utilization management and credentialing programs, mental health parity compliance, and digital health offerings.

Credentials

Education

  • Boston University School of Law (LL.M in Taxation)
  • New England Law – Boston (J.D.)
  • Boston University (B.A., cum laude)

Bar Admissions

  • District of Columbia
  • Florida
  • Maine
  • Massachusetts
  • Rhode Island

Court Admissions

  • U.S. Tax Court

Professional & Community Involvement

  • American Bar Association
    • Health Law Section on Employee Benefits, Vice Chair (2017)
    • Health Law Section on Tax and Accounting, Vice Chair (2013 to 2017)
  • American Health Law Association
    • ACO Tax Force, Vice Chair of Publications (2016 to 2019)
    • Delivery and Payment Reform Affinity Group, Chair (2020 to July 2022)
    • Regulation, Accreditation and Payment Practice Group, Special Topics Vice Chair (July 2022 to July 2023)
    • Payers, Plans, and Managed Care Practice Group, Vice Chair of Publications (July 2023 to  Present)
  • Portland Recovery Community Center, Board Member (2020 to May 2024)

Events

Insights

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