Cozen O’Connor: Raphaely, R. Christopher

R. Christopher Raphaely

Co-Chair, Health Law

Philadelphia

(215) 665-2099

(215) 665-2013

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.

Chris was an adjunct professor at Widener University School of Law from 2008-2014, where he taught health care finance, and 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

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.

Healthcare Antitrust Reviews Likely to Remain Strong Under Trump

November 11, 2016

Chris Raphaely discusses the potential impact of a Trump administration on antitrust enforcement in the health care industry.

Appeals Court Overturns Pa. Hospital Merger

September 28, 2016

Chris Raphaely discusses a recent decision by the U.S. Court of Appeals for the Third Circuit.

Press Ganey Purchased by Private Equity Firm for $2 Billion

August 09, 2016

Christopher Raphaely discusses Press Ganey’s acquisition by Swedish private equity firm EQT.

Chris Raphaely Discusses SMARTER Act in Modern Healthcare

April 08, 2016

Chris Raphaely discusses a house-passed bill that may impact hospital decisions on mergers in Modern Healthcare.

Christopher Raphaely Discusses Moving to a Law Firm from In-House

June 08, 2015

Christopher Raphaely discusses the challenges faced when moving from an in-house position to private practice with The Legal Intelligencer.

Christopher Raphaely Discusses Issues Facing Health Care Industry with Philadelphia Business Journal

August 25, 2014

Raphaely discusses the Affordable Care Act, ACOs and other issues facing in house counsel working in the health care industry.

Jefferson Health System Legal Counsel, Raphaely, Joins Cozen O’Connor as Co-Chair of Health Care Practice Group

July 09, 2014

Cozen O’Connor continues to strengthen its focus on health care with the recent hiring of R. Christopher Raphaely, who will serve as co-chair of the firm’s Health Care Practice Group. Previously deputy general counsel for the Jefferson Health System, and general counsel to the system’s accountable care organization and captive professional liability insurance companies, Raphaely will be resident in the Philadelphia office.

Publications

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...

Repeal Efforts Fail (for now): Can Obamacare Survive? [Health Law Informer Blog]

March 28, 2017

With the House GOP pulling the American Health Care Act (AHCA) due to lack of sufficient support even within its own party, Obamacare is not out of the woods. The ACA's two pillars, the individual marketplaces and Medicaid expansion, remain vulnerable and could be used as political bargaining...

Minnesota Federal Court Says Cross-Plan Offsets Are Unlawful; Certifies Case for Immediate Appeal [Health Law Informer Blog]

March 23, 2017

The U.S. District of Minnesota has ruled in Peterson v. Unitedhealth Grp. Inc., No. 14-CV-2101 (PJS/BRT), 2017 WL 991043 (D. Minn. Mar. 14, 2017) that ERISA does not permit United Healthcare (“United”) to claw back alleged overpayments related to patients from one plan by reducing or eliminating...

Trump Takes First Step Toward Dismantling ACA and Buys Time with an Executive Order: Is it Substantive or Merely Symbolic? [Hot Button Blog]

February 01, 2017

Hours after taking the oath of office President Donald Trump signed a broadly worded executive order (“Order”) intended to minimize if not eliminate the impact of the ACA’s least popular provisions. With the Order President Trump can claim immediate action towards fulfilling a major campaign pledge...

Trump Takes First Step Toward Dismantling ACA and Buys Time with an Executive Order: Is it Substantive or Merely Symbolic? [Health Law Informer Blog]

January 23, 2017

Hours after taking the oath of office President Donald Trump signed a broadly worded executive order (“Order”) intended to minimize if not eliminate the impact of the ACA's least popular provisions. With the Order President Trump can claim immediate action towards fulfilling a major campaign pledge...

Pennsylvania Issues Grower/Processor and Dispensary Permit Applications for Medical Marijuana Program [Health Law Informer Blog]

January 23, 2017

On January 17, 2017, the Pennsylvania Department of Health (“DOH”) released grower/processor and dispensary permit applications (“Applications”), which can be found on Pennsylvania’s Medical Marijuana Program website. DOH will accept Applications from February 20 – March 20, 2017, and will begin...

Futures in Doubt of CMS’ New Mandatory Bundled Payment Models and Medicare Shared Savings Program Track 1+ [Health Law Informer Blog]

December 23, 2016

Word spread quickly Monday (December 20, 2016) about CMS’ issuance of final regulations (to be published in the Federal Register on January 3, 2017) rolling out new mandatory bundled payments models for Acute Miocardial Infarction (AMI), Coronary Artery Bypass Graft (CABG), Surgical Hip and Fracture...

House Passes 21st Century Cures Act [Hot Button Blog]

December 05, 2016

On November 30, 2016, the House overwhelmingly passed (392-26) the 21st Century Cures Act (“Bill”). The Bill moves on to the Senate next week and it is projected to pass in the Senate as well. Notably, the Bill seeks to improve upon the federal regulatory structure regarding Federal Drug...

House Passes 21st Century Cures Act [Health Law Informer Blog]

December 02, 2016

On November 30, 2016, the House overwhelmingly passed (392-26) the 21st Century Cures Act (“Bill”). The Bill moves on to the Senate next week and it is projected to pass in the Senate as well. Notably, the Bill seeks to improve upon the federal regulatory structure regarding Federal Drug...

Third Circuit Puts Penn State Hershey/Pinnacle Merger on Hold [Health Law Informer Blog]

October 04, 2016

Last week, the Third Circuit Court of Appeals held that the merger between Penn State Hershey Medical Center and PinnacleHealth System, the two largest hospitals in Harrisburg, Pennsylvania, may not move forward at this time. The Court of Appeals overturned the District Court’s (Middle District of...

New Grower/Processor Regulations Released [Health Law Informer Blog]

August 22, 2016

On August 18, 2016, the Secretary of Pennsylvania’s Department of Health (“DOH”), Dr. Karen Murphy, announced that the DOH has posted draft temporary regulations (“Regulations”) focusing on the 25 medical marijuana grower/processor permits that will become available under Pennsylvania’s Medical...

Medical Marijuana in Pennsylvania: What Physicians Should Know [Health Law Informer Blog]

May 09, 2016

On April 17, 2016, Governor Wolf signed Act 16 of 2016, making Pennsylvania the 24th state (plus the District of Columbia) to legalize marijuana for medical use. The full text of the act is available here. Physicians, not surprisingly, will play a vital role in making medical marijuana available...

Health Law Year in Review [Health Law Informer Blog]

December 17, 2015

On Tuesday, December 8 Cozen O’Connor’s Health Care practice and industry team hosted the Health Law Year in Review, an annual discussion of hot topics facing those in the health care industry. Presentation topics included: Update from Washington, DC – Havi Glaser discussed the Affordable...

Executives in the Crosshairs: DOJ Increases the Focus on Individuals to Combat Corporate Wrongdoing [Health Law Informer Blog]

September 22, 2015

Earlier this month, the Deputy Attorney General of the Department of Justice (“DOJ”) released a memorandum (“Guidance”) setting forth six key steps to which DOJ attorneys should adhere in the investigation of corporate misconduct. At the same time, the Guidance underscores the importance of having...

NLRB’s Joint Employer Ruling Threatens to Reorder Employment Relations in the Health Care Industry

September 16, 2015

Hospitals and nursing homes may find themselves pulled into union elections or collective bargaining with staffing agencies, outside service providers and hitherto independent contractors.

The Time is Right for Hospitals to Ensure 501(r) Compliance [Health Law Informer Blog]

September 14, 2015

Updated requirements for hospitals to maintain their tax-exempt status under Section 501(r) of the Internal Revenue Code are nothing new. They were enacted as part of the Affordable Care Act in 2010. However, at the end of 2014, the IRS issued a final rule (“Final Rule”) interpreting, clarifying and...

Ignorance Is Not Bliss: The Clock under the ACA’s “60 Day Rule” Can Start Ticking Well Before the Exact Amount of Overpayment is Identified [Health Law Informer Blog]

August 05, 2015

On August 3, 2015, a federal judge in the Southern District of New York ruled that the United States’ and state of New York’s complaints in intervention can move forward against a group of hospitals, under the federal False Claims Act (“FCA”) and New York’s FCA corollary. The hospitals allegedly...

Next Generation ACOs: CMMI Doubles Down on the Two-Sided Risk ACO Model [Health Law Alert]

March 16, 2015

While one part of the Affordable Care Act, exchange subsidies, hangs in the balance with the Supreme Court’s upcoming decision in King v Burwell, CMS is moving forward aggressively with the evolution of a less controversial ACA-created innovation, the Medicare ACO.

Events & Seminars

Past Events

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

ACCGP's Health, Biotech & Pharma Law CLE Institute

May 18, 2017 - King of Prussia, PA

23rd Annual Health Law Institute

March 07, 2017 - Philadelphia, PA

Health Law Year in Review Regional CLE

February 03, 2017 - Miami, FL

7th Annual Health Law Year in Review

December 07, 2016 - Philadelphia, PA

PBI 22nd Annual Health Law Institute

March 15, 2016 - Philadelphia, PA

2015 Health Law Year in Review

December 08, 2015 - Philadelphia, PA

A Day On Health Law

October 08, 2015 - Philadelphia, PA

39th Annual Institute of the NJ Chapter of HFMA

October 07, 2015 - Atlantic City, NJ

PBI's 21st Annual Health Law Institute

March 12, 2015 - Philadelphia, PA

Health Law Year In Review

December 03, 2014 - Philadelphia, PA

8th Annual HFMA Fall Institute

September 18, 2014 - Philadelphia, PA

Education

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

Awards & Honors

Chambers USA 2016-2018

  • New Jersey
  • Pennsylvania