Christine Burke Worthen

"In health care, regulatory change never ceases. I translate those changes into practical strategic advice that ensures my clients’ operational readiness and financial sustainability." —Christine Burke Worthen

Health care providers, payers, digital health companies, and investors rely 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, such as MSSP, TEAM, LEAD; 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 issues. Her work includes assisting with outsourced arrangements, clinically integrated network development and value-based enterprise models, risk adjustment, and provider compensation arrangements. She helps guide clients as they navigate the opportunities and challenges associated with deploying AI solutions as part of their revenue cycle and managed care strategy and operations.

New market entrants turn to Christine for advice on 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 with regulatory due diligence in transactions, as well as assessing new models of health coverage, such as direct-to-employer models. She is also looked to as a resource for advice on non-traditional health insurance arrangements, including the use of direct primary care, captive and other types of reinsurance arrangements, Association Health Plans, and MEWAs.

In addition, Christine advises on other areas of concern for payers, investors, and providers, such as health care fraud and abuse 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.

In private practice, Christine previously served as a partner and chair of the Healthcare Services Practice Group in a regional law firm’s Portland (Maine) and Boston offices and later as a partner in the health care practice of a national law firm. Earlier in her career, she was the chair of the Tax and Employee Benefits/Executive Compensation Practice Groups of a Maine law firm—experience that continues to inform her counseling on employee benefits and compensation matters.

Christine will serve as a Professorial Lecturer in Law at The George Washington University Law School, teaching a fall 2026 course on managed care law.

What Christine Delivers for Clients

• Strategic Navigation of Payment Model Change: Christine works with clients to design and deploy contracting strategies that account for the regulatory and financial risks ahead. Clients emerge with a clear assessment of which payment models make sense for their business, as well as the compliance and operational infrastructure required to make those models work.
• Risk Assessment and Due Diligence for Investors: When investors evaluate health care and insurance targets, they need to understand not just what the company does today but what regulatory or payment landscape shifts could threaten its model. Christine conducts targeted due diligence that flags hidden compliance gaps and identifies the financial performance opportunities that regulatory change creates.
• Practical Compliance Infrastructure: Many of Christine's clients operate in multiple states and under multiple payers. Rather than treating each contract and jurisdiction separately, Christine helps clients build standardized processes and policies that span markets, reducing costs and risk while maintaining the flexibility to accommodate market-specific requirements, including the deployment of practical strategies to address payer policy changes to preserve revenue.
• Multi-Market Expansion Without Reinvention: When providers or digital health companies enter new markets, they should not have to reinvent their compliance and contracting playbook. Christine advises on licensing, network development, payer negotiations, and corporate practice of medicine issues in ways that build on existing infrastructure and scale efficiently.
• Direct to Employer/Consumer and Alternative Insurance Arrangements: Christine helps craft a compliant strategy for launching or pivoting emerging payment models, taking into account the various overlapping regulatory issues at the state and federal levels, including ERISA, state insurance regulation, licensing, risk assumption, and fraud and abuse laws.

Health Care Matters

• Advise regional and multistate health systems on designing and deploying a 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 on due diligence and financial performance opportunities for acquisition targets, including physician practices, digital health platforms, and post-acute care providers, as well as new models of health insurance delivery in the direct-to-employer or consumer market, including level-funded and captive arrangements.
• 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, providing 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 multistate and regional health systems.
• 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.

ERISA and Other Benefit Plan-Related Matters

• Advise plan sponsors of self-insured health plans on network development and alternative payment models, including risk-based payments, bundled payments, reference pricing, captive arrangements, and gainsharing arrangements.
• Provide advice to third-party administrators, investors, and brokers regarding alternative insurance models (including captives, level-funded plans, and non-network arrangements) and guidance on compliant models for both self-insured and fully-insured models.
• 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.

Education

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

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 July 2026)
• Florida Bar, Health Law Section
• Portland Recovery Community Center, Board Member (2020 to May 2024)