Christine Clements is a partner in the Governmental Practice and a Co-Managing Partner of the firm’s Washington, D.C. office. She is also a Deputy Team Leader of the firm’s Healthcare Team.

Areas of Practice

With more 30 years of experience in managed care law issues, Christine's practice includes federal healthcare government contract programs such as the Medicare Advantage Program, the Medicare Prescription Drug Benefit, the Federal Employees Health Benefits Program and Medicaid managed care. She advises health plan clients on the issues most important to them, including contract applications and service area expansions; responses to requests for proposals; rate development and bidding; medical loss ratio and other financial and reporting requirements; risk adjustment; Star Ratings; sales and marketing strategies and compliance; benefit design; employer/union group offerings; provider and vendor contracting and payment; internal audits; novations and contract consolidations; fraud and abuse, including the discount and managed care safe harbors; and compliance programs.

Christine advises clients undergoing government audits and investigations. She also represents clients in administrative appeals including appeals of Centers of Medicare and Medicaid Services application denials, assessments of civil money penalties, intermediate sanctions and Star rating/quality bonus payment determinations.

In addition, Christine advises clients on state law requirements such as insurance and HMO licensure requirement, net worth and other financial requirements, market conduct and other audits, state mandates and extraterritoriality requirements.

Further, Christine advises healthcare providers and suppliers including accountable care organizations and pharmacies, as well as intermediaries such as management service organizations. She also advises healthcare industry clients in connection with mergers and acquisitions, strategic alliances and joint ventures, value-based contracting matters, and other strategic planning issues.

Previously, Christine served as Chief Medicare Counsel at Aetna Inc., where she was responsible for the company's Consumer Segment. In this role, she was the lead attorney for the company's Medicare Advantage and Medicare Prescription Drug Benefit businesses, Medicare Supplement products and other retiree plans.

Christine has written and presented on the Medicare Advantage and Medicare Prescription Drug Benefit programs, the Federal Employees Health Benefits Program, Star Rating issues, value-based contracting arrangements and the HIPAA Privacy Rule, among other topics.



Recommended Lawyer - Healthcare, Legal 500 US, 2019-2021, 2023

  • Legal500 US Recommended Attorney



Healthcare Law Blog Posts

Speaking Engagements

  • Presenter, "Policy Update #2: The Latest Activity in Washington, D.C. and Why It Matters," Health Plan Alliance, May 29, 2020
  • Presenter, "MA and PDP CY2021 – 2022 Proposed Rule," Health Plan Alliance 2020 Fly in: Medicare Advantage Product Design and Implementation, February 10-11, 2020
  • Presenter, "Federal And State Regulatory Updates Impacting Drug Pricing And Pharmacy Benefit Management Programs," Health Plan Alliance Pharmacy Summit, May 29-30, 2019
  • Presenter, "CMS’ Medicare Advantage Overpayment Rule Takes a Permanent Vacation: What’s Next for Payors and Providers Alike," Sheppard Mullin Healthcare Webinar, October 16, 2018
  • Presenter, "Medicare Part C and Part D Quality Star Ratings: What Plan Lawyers Should Know and Care About," Blue Cross Blue Shield National Summit, Orlando, Florida, May 1-4, 2018



Member, American Bar Association

Member, American Health Lawyers Association

Digital Media


J.D., American University Washington College of Law

B.A., George Washington University


  • District of Columbia
  • Maryland
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