R. Christopher Raphaely

Co-Chair, Health Care

Philadelphia

(215) 665-2099

(215) 665-2013

Recent Publication:

CMS Releases Second Set of FAQs Regarding Good Faith Estimates to Uninsured and Self-pay Patients Under “No Surprises Act” [Health Law Informer Blog]

CMS continued to roll out guidance regarding the No Surprises Act. The latest guidance is the second set of FAQs regarding the Good Faith Estimate Requirement for uninsured and self-pay patients was issued on April 5, 2022. The FAQs address six questions regarding the requirement and can be found...

Chris provides sophisticated transactional and regulatory counsel to an array of hospitals, health systems, accountable care organizations, physicians, professional liability insurers, and other provider organizations. Prior to joining the firm in 2014, Chris served as deputy general counsel to Jefferson Health System and general counsel to the system’s accountable care organization and captive professional liability insurance companies.

Chris has worked in the health care industry for nearly three decades. His practice focuses on major transactions for health care clients and the comprehensive regulatory schemes requisite to doing business in the health care space. Chris handles matters involving payer negotiations, payment disputes and contract enforcement, accountable care organizations, clinically integrated networks, value based payment arrangements, pharmacy benefit management and third party administrator contracts for self-insured employers, digital health, organizational and governance structures, HIPAA, information privacy and security, tax exemption, Stark Law, fraud and abuse matters, clinical integration, provider acquisitions, divestitures, medical staff relations, facility and professional licensing, Pennsylvania's Medical Marijuana Act, and general compliance.

At Jefferson Health System, Chris served as a legal advisor to the system’s board of trustees and executive team and played key roles in Jefferson Health System’s largest and most complex transactions. During his tenure, Chris helped lead the system’s restructuring efforts in 2010 and the separation of its members in 2014, which resulted in the creation of three autonomous and agile health systems. As a result of his extensive in-house experience, Chris has a deeply ingrained understanding of health care clients’ governance structures, day-to-day operations, goals, and expectations.

Prior to joining Jefferson Health System, Chris spent 16 years in private practice representing health care clients in a wide array of transactional and regulatory matters, the last seven as a partner of an Am Law 100 law firm's health law practice group.

Previously, he served as an adjunct professor at Drexel University Thomas R. Kline School of Law and Widener University School of Law, where he taught health care finance. He serves as chairman of the board of The Rock School for Dance Education. He earned his J.D. from Temple University Beasley School of Law and his B.A. in economics from the University of Pennsylvania.

Experience

News

82 Cozen O’Connor Lawyers, 19 Practices Earn Top Recognition in Chambers USA 2021 Guide

May 26, 2021

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 82 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2021 edition; of those, 15 lawyers have been recognized nationally.

63 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2020 Guide

May 14, 2020

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 63 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2020 edition.

Hospitals Tackling Virus May Need More Than Brief Privacy Waiver

March 19, 2020

Chris Raphaely discussed with Bloomberg Law about HHS using a relax enforcement of the privacy requirements during the public health emergency.

57 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2019 Guide

April 25, 2019

Chambers USA, the leading annual guide to the top lawyers and law firms in the USA, has ranked 57 Cozen O’Connor lawyers as leaders in their respective fields in the Guide’s 2019 edition.

The ACA's Been Ruled Invalid. What's Next?

December 17, 2018

Christopher Raphaely, co-chair of Cozen O'Connor's Health Care practice group, spoke with Law360 about a Texas federal judge’s declaration that the entire Affordable Care Act is invalid.

Christopher Raphaely on The Business of Health Care

June 21, 2018

Chris Raphaely, co-chair of Cozen O'Connor's Health Care practice group, was a guest on SiriusXM's Wharton Business Radio.

Publications

CMS Releases Second Set of FAQs Regarding Good Faith Estimates to Uninsured and Self-pay Patients Under “No Surprises Act” [Health Law Informer Blog]

April 06, 2022

CMS continued to roll out guidance regarding the No Surprises Act. The latest guidance is the second set of FAQs regarding the Good Faith Estimate Requirement for uninsured and self-pay patients was issued on April 5, 2022. The FAQs address six questions regarding the requirement and can be found...

Compliance with the hospital price transparency law almost a year in: Where are we now? [Cosmos]

December 01, 2021

Christopher Raphaely and Danielle Sapega co-authored an article about the Centers for Medicare & Medicaid Services (CMS) hospital price transparency rule, which has been in effect since January 1, 2021.

Five Things Providers Need To Know About The New Interim Final Rule Under The “No Surprises” Act [Health Law Informer Blog]

October 05, 2021

On Thursday, September 30, 2021, The United States departments of Health and Human Services (“HHS”), Labor and Treasury released an interim final rule (“Rule”) that completes most of the regulatory framework under the federal No Surprises Act (“Act”). The Act largely bars balance billing of...

US and Tyler Texas Chambers of Commerce Sue Feds to Block Portions of the Health Plan Transparency Rule [Health Law Informer Blog]

August 12, 2021

Two chambers of commerce, the Chamber of Commerce the United States of America and the Tyler (TX) Area Chamber of Commerce, filed a lawsuit on August 10, 2021, in the US District Court for the Eastern District of Texas against the United States departments of Health and Human Services, Labor and...

HHS, Treasury and Labor Release First Set of Surprise Billing Rules [Health Law Informer Blog]

July 02, 2021

The United States Departments of Health and Human Services, Treasury and Labor released interim final rules (“Rules”) regarding the “No Surprises Act” (“Act”) yesterday. The Rules are effective beginning on January 1, 2022. They cover the requirements for the billing and payment of emergency and...

CMS Releases Final Stark Rules To Promote Value-Based Care [Health Law Informer Blog]

November 23, 2020

On Friday, November 20, 2020, the Centers for Medicare and Medicaid Services (“CMS”) released final regulations to remove certain barriers to the implementation of physician compensation arrangements under value-based payment arrangements posed by the “Stark” Physician Self-Referral law. The...

A Week After Pharma Price Disclosure Is Rule Struck Down, D.C. Judge Upholds Hospital Price Transparency Rule [Health Law Informer Blog]

June 24, 2020

As we indicated in last week’s blog post , the D.C. Circuit Court’s refusal to uphold HHS’ pharmaceutical price disclosure rule (“RX Rule”) was not a predictor of how the trial court might rule in the closely watched challenge to HHS’ hospital price transparency rule (“Hospital Rule”). In a June...

Pharma Price Disclosure Rule Struck Down: Will Hospital Price Transparency Rule Meet the Same Fate? [Health Law Informer Blog]

June 19, 2020

On June 16, the D.C. Circuit Court struck down the Centers for Medicare and Medicaid Services’ (“CMS”) rule issued in May 2019 requiring pharmaceutical companies to disclose the wholesale acquisition cost of drugs over $35 in their direct-to-consumer television advertisements (“RX Rule”). Similar...

Summary and Analysis of Key Provisions of the CARES Act

March 28, 2020

Members of Cozen O'Connor's Coronavirus Task Force provide analysis of the CARES Act and how it will impact small businesses, distressed industries, employers and employees, taxes, and the health care, real estates, and energy industries.

The Use of Telehealth During the COVID-19 Nationwide Public Health Emergency [Alert]

March 23, 2020

Greg Fliszar and Chris Raphaely explain the recent changes OCR and HHS made to make telehealth services more available.

5th Circuit Holds Individual Mandate is Unconstitutional, but Remands to District Court to Decide Severability [Health Law Informer Blog]

December 19, 2019

In a 2-1 decision published on December 18, 2019, a 5th Circuit panel upheld the Texas District Court’s decision ruling that the ACA individual mandate tax which, since January 2019, has had no monetary consequence, is unconstitutional. Citing the Supreme Court’s 2012 NFIB v. Sebelius opinion, the...

CMS Releases Final ACO Regulations [Health Law Informer Blog]

December 21, 2018

This morning CMS released a final rule regarding its most popular program for accountable care organizations (ACOs), the Medicare Shared Savings Programs. The final rule is based on the proposed rule for the program that was published in August.  The final rule adopts the major structural overhaul...

The Medicare Shared Savings Program and the New Glide Path to Risk [Health Law Alert]

August 22, 2018

Chris Raphaely discusses CMS's proposed rule regarding ACOs in the Medicare Shared Savings Program.

Governor Wolf Signs Amendment to PA Medical Marijuana Act [Health Law Informer Blog]

July 05, 2018

On June 22, 2018 Governor Wolf signed HB 2477 (“Amendment”) into law breathing new life into Chapter 20 of the Medical Marijuana Act (“Act”), the country’s first-of-its-kind law for cannabis research. This follows Commonwealth Court Judge Patricia McCullough’s May 22, 2018 issuance of a preliminary...

Hospital Tier Status in Payor Network Agreements [Health Law Informer Blog]

March 21, 2018

Bergen County Superior Court Judge Robert Contillo issued a recent decision deemed favorable by Horizon Healthcare Services Inc. (“Horizon”) in a case involving three healthcare providers (“Providers”) that challenged Horizon’s newer tiered health coverage plan for hospitals: OMNIA. The Providers...

DOH Finalizes Temporary Regulations for Clinical Registrants and Academic Clinical Research Centers [Health Law Informer Blog]

March 16, 2018

The Pennsylvania Department of Health (DOH) published the much anticipated final version of the temporary regulations under the Medical Marijuana Act applicable to Clinical Registrants and Academic Clinical Research Centers (ACRC) in Pennsylvania (“Temporary Regulations”). The Clinical...

The White House’s One-Two Punch to Obamacare: A Knockout Blow to the ACA? [Health Law Informer Blog]

October 16, 2017

In moves that stunned and alarmed insurers, providers, and consumers alike, on October 12, the White House issued an announcement and an Executive Order that appear to be purposefully designed to decimate the Health Insurance Marketplace (Exchange) under the ACA: The White House announced that...

Events & Seminars

Past Events

Spring Institute

March 18, 2022 - Philadelphia, PA

PBI Health Law Institute 2022

March 15, 2022 - Webinar

Health Law 2022

December 08, 2021 - Webinar

New Vaccine Mandates from Biden Administration

September 23, 2021 - Webinar

Telehealth in the New Administration

June 11, 2021 - Webinar

Price Transparency

March 16, 2021 - Webinar

Health Law 2021

December 07, 2020 - Webinar

PBI Health Law Institute 2020

March 11, 2020 - Philadelphia, PA

Health Law 2020

December 04, 2019 - Philadelphia, PA

Best Practices for Working with Your Outside Counsel

November 19, 2019 - Philadelphia, PA

PBI Health Law Institute 2019

March 12, 2019 - Philadelphia, PA

Health Law 2019

December 05, 2018 - Philadelphia, PA

PBI: A Day on Health Law

October 23, 2018 - Philadelphia, PA

Health, Biotech & Pharma Law CLE Institute

July 18, 2018 - King of Prussia, PA

PBI Health Law Institute

March 13, 2018 - Philadelphia, PA

2017 Health Law Year In Review

December 06, 2017 - Philadelphia, PA

Education

  • Temple University—James E. Beasley School of Law, J.D., 1990
  • University of Pennsylvania, B.A.

Awards & Honors

Selected to Chambers & Partners USA, 2016-2021. This award is conferred by Chambers & Partners. A description of the selection methodology can be found here. No aspect of this advertisement has been approved by the Supreme Court of New Jersey.

  • New Jersey
  • Pennsylvania