Attorney Jennifer Bolton’s experience includes:

  • Advising and counseling health care clients on federal and state anti-kickback and physician self-referral laws with respect to both structuring health care transactions and day-to-day operations
  • Counseling and structuring arrangements for health care providers to ensure compliance with regulatory matters, including the corporate practice of medicine, fee-splitting prohibitions, and Medicare and Medicaid compliance
  • Providing legal and regulatory counsel to hospitals and health systems, ambulatory surgery centers, physician groups, office-based surgery practices, practice management organizations, and other health care providers in connection with corporate transactions
  • Representing clients in a variety of contractual matters, including the preparation and negotiation of professional services agreements, administrative services agreements, and employment agreements
  • Negotiating and drafting purchase agreements, administrative services agreements, and employment agreements in connection with hospital acquisitions of practices and practice-to-practice acquisitions
  • Negotiating and preparing agreements relating to the delegation of management functions by managed care entities to third parties
  • Negotiating and advising hospitals, ancillary providers, accountable care organizations, and independent physician associations on managed care arrangements, including fixed fee, value-based, and shared savings models
  • Advising hospitals, ancillary providers, and physician groups on legal and regulatory matters arising under Medicare, Medicaid, and other third-party reimbursement programs

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In addition, Jennifer served as de facto outside associate general counsel to a large, expanding anesthesiology group. In this role, she worked on all manner of agreements for the client and analyzed highly complex proposed arrangements to ensure compliance with federal and state fraud and abuse regulations.

Prior to joining Epstein Becker Green, Jennifer was an attorney with a Global 100 law firm and has previous experience working in a health care facility. At a clinical and academic hospital on Long Island, New York, Jennifer worked on operational management projects and strategic initiatives focused on enhancing patient flow.

*Admitted in New York; application pending in Texas.

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Focus Areas



  • Columbia University Mailman School of Public Health (M.P.H., 1995)
  • Benjamin N. Cardozo School of Law (J.D., 1994)
    • Editor, Moot Court Honor Society
  • University of Michigan (B.A., cum laude, 1990)

Bar Admissions

Professional & Community Involvement

  • American Health Lawyers Association
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