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Richard P. Church

Fax +1.919.516.2077
Fax +1.312.827.8000
Resident in Research Triangle Park and Chicago, Mr. Church focuses his practice on health law regulatory issues and health care joint ventures, clinical integration and mergers and acquisitions. Mr. Church handles complex 340B structuring, enrollment and compliance matters, Medicare and Medicaid enrollment and reimbursement issues, and health care operational matters. He also handles complex affiliations and transactions between health care providers, including legal compliance, change of ownership filings, and development of post-transaction reimbursement structures. He is listed in Chambers USA 2014, 2015, and 2016 for Healthcare – North Carolina.

Professional Background

Mr. Church served as law clerk to the Honorable John T. Noonan, Jr., United States Court of Appeals for the Ninth Circuit. He also holds a Ph.D. in theological ethics from Duke University and previously taught medical ethics as an Assistant Professor of Religion at Wingate University.


  • Listed in Chambers USA for Healthcare - North Carolina, 2014, 2015, 2016, and 2017
  • Nightingale Healthcare News' Outstanding Transaction Lawyer, 2009

Professional/Civic Activities

  • American Health Lawyers Association
  • North Carolina Society of Health Care Attorneys

Speaking Engagements

  • Health Information at the Crossroads: New Uses and Challenges for Integrated Clinical Records, presented to the Physicians and Hospitals Law Institute, February 2019
  • More Data, More Problems: Big Data Issues for the Research Enterprise, presented to the National Association of College and University Attorneys, June 26, 2018
  • Expanding the Scope of Integrated Health Information Records into the Clinical Research Arena: Lessons Learned (HIT), presentation to Physicians and Hospitals Law Institute, sponsored by the Health Lawyers Association, February 7, 2018
  • Building a Compliant and Resilient 340B Program in the Midst of Regulatory Uncertainty, presented to the American Health Lawyers Association, National Association of College and University Attorneys, and Association of American Medical Colleges, January 26, 2018
  • The Tail That Wags the Dog? How Different ACO Governance Structures Affect Operational Decision-Making, presentation to the Business Law and Governance Practice Group and the Accountable Care Organization Task Force, American Health Lawyers Association, January 11, 2017
  • 340B Mega-Guidance, presentation to the NC Bar Health Law Section Annual Meeting, April 29, 2016
  • Changes to the 340B Program: What Covered Entitles Must Know, Lorman webinar, March 3, 2016
  • 340B Program Omnibus Guidance, webinar presented to the North Carolina Society for Health Care Attorneys, October 16, 2015
  • Stark Compliance Advanced Discussion Group, Health Care Compliance Association’s 17th Annual Compliance Institute, Washington, DC, April 2013
  • Threat or Opportunity: The New Frontier of ACOs, North Carolina Hospital Association, September 2011
  • Hostage to His Own Cure: Insights into American Medicine From What Wasn’t in the Health Care Reform Bill, East Carolina University Brody School of Medicine Inaugural Lecture in Medical Jurisprudence, April 2011
  • Privacy and Security Issues for Hospice, Carolinas Center for Hospice and End of Life Care, Hospice Administrative Team Conference Program, September 2009

Additional Information


  • New Law Excludes New Provider-Based Off-Campus Outpatient Hospital Locations from OPPS, Health Care alert, December 8, 2015
  • CMS and OIG Issue Final Fraud and Abuse Waivers in Connection With the Medicare Shared Savings Program, Health Care Alert, 16 November 2015
  • 340B Program Omnibus Guidance: Mega-Changes on the Horizon?, American Health Care Lawyers Association Rap Sheet, November 2015
  • 340B Orphan Drug Interpretive Rule Struck Down by D.C. District Court: HHS and HRSA Lose In Second Round of Litigation Over 340B Orphan Drug Rules, Health Care Alert, 22 October 2015
  • HRSA Issues 340B Program Omnibus Guidance, Health Care Alert, 3 September 2015
  • Preparing for Successful Medicare Shared Savings Program Enrollment, co-authored with Darlene Davis and Steve Pine, AHLA Connections, July 2015
  • 340B Update: HRSA Proposes Penalties for Drug Manufacturers that Overcharge Covered Entities, Health Care Alert, 22 June 2015
  • CMS Releases Final Medicare Shared Savings Program Rule, Health Care Alert, 11 June 2015
  • Federal Court Enjoins Texas Medical Board from Enforcing More Stringent Telemedicine Rules, 9 June 2015
  • CMS Announces the Next Generation of Accountable Care Organizations Aimed at Increased Risk Sharing and Program Sustainability, Health Care Alert, 9 April 2015
  • ACOs Continue to Expand in Both Public and Private Health Care Arenas, K&L Gates Global Government Solutions® 2015 Annual Outlook, April 2015
  • 60 Day Rule, Health Care Alert, 2 March 2015
  • Potential Revisions to North Carolina Medical Board Telemedicine Position Statements on the Horizon, Health Care Alert, 3 October 2014
  • Health Care Program Compliance Guide, Hospice and Nursing Home Relationships chapter, BNA, 2012
  • Inside the Minds Managing Health Care Transactions  “Enrollment Strategies for Managing Successor  Liability in Health Care Transactions”,  Chapter Author, Aspatore Books, 2012
  • Health Care Reform Client Alert Series: CMS Issues Proposed Regulations on Liability for Failure to Disclose and Return “Identified” Overpayments in 60 Days, Health Care Alert, March 7, 2012
  • What Hospitals and Physicians Should Know About CMS's Proposed Regulations for Disclosure and Reporting Requirements of Manufacturers and GPOs, Health Care Alert, February 3, 2012
  • CMS Issues Proposed Regulations on New Disclosure and Reporting Requirements Related to Manufacturers and GPOs, Health Care Alert, January 25, 2012
  • Easing the Burden of Medicare Regulations: Round-Up of New Final and Proposed Rules, Health Care Alert, December 6, 2011
  • CMS Bundled Payments Initiative, Health Care Alert, October 4, 2011
  • CMS Finalizes New Rules Related to Enrollment, Payment Suspensions, and Termination, Health Care Alert, July 14, 2011
  • Final Rule Revises Home Health Agency Ownership Changes Provision, Health Care Alert, January 25, 2011
  • Global Government Solutions 2010 Mid-Year Outlook: “Health Care: A Brave New World of Reform”, K&L Gates Publication, July 2010
  • Health Care Reform Client Alert Series: Revisions to Medicare and Medicaid Provider/Supplier Enrollment & Billing Requirements, Health Care Alert, July 14, 2010
  • Health Care Reform Client Alert Series: New Disclosure and Reporting Requirements Related to Manufacturers and GPOs Payments to Teaching Hospitals and Physicians, Health Care Alert, May 17, 2010
  • Health Care Reform Client Alert Series: New Inducements to Beneficiaries Exceptions, Health Care Alert, May 13, 2010
  • CMS Update: New Rules for Home Health Agencies Undergoing Ownership Changes, Health Care Alert, February 18, 2010
  • HIPAA Update: Breach Notification — Are You Prepared?, Healthcare Alert, November 6, 2009
  • Hurdles to Health Care Reform, National Law Journal, September 2009
  • Of the Good That Has Been Possible in This World: Lawyering in Port William, Chapter in Wendell Berry and Religion: Heaven’s Earthly Life, The University Press of Kentucky, 2009
  • First Be Reconciled: Challenging Christians in the Courts, Herald Press, 2008
  • Engaging Robert Rodes, 22 Journal of Law and Religion 433, 2006-2007
  • Answering the Dispersed Self and Nation: A Response to Jed Rubenfeld's Freedom and Time: A Theory of Constitutional Self Government, 21 Journal of Law and Religion 349, 2005-2006
  • The Art of Description: How John Noonan Reasons, 76 Notre Dame Law Review 849, 2001
  • The Breakdown of the Constitutional Tradition: MacIntyrian and Theological Responses, 14 Journal of Law and Religion 351, 1999-2000
  • The Rhetoric of Neutrality and the Philosophers' Brief: A Critique of the Amicus Brief of Six Moral Philosophers in Washington v. Glucksberg and Vacco v. Quill, 61 Duke Journal of Law and Contemporary Problems 233, 1998
  • Represented numerous academic medical centers, health systems, clinical laboratories, pharmacies, long-term care facilities and other post-acute providers in acquisitions, affiliations, and joint ventures.
  • Represented academic medical centers and health systems in formation of clinically integrated networks for population health management, including enrollment in Medicare accountable care programs and private payor negotiations.
  • Conducted regulatory review of physician contracting arrangements and joint ventures for academic medical centers under state and federal fraud and abuse provisions.
  • Advised providers and suppliers on complex reimbursement, Medicare and Medicaid enrollment, licensure and 340B enrollment matters, including implications related to restructuring of free-standing provider-based locations.
  • Advised clients on numerous 340B drug diversion, duplicate discount, and GPO prohibition compliance reviews, including representation and resolution of numerous Health Resources Services Administration audits.
  • Represented health care providers in the creation of numerous complex data sharing arrangements, including compliance with the the Health Insurance Portability and Accountability Act, the Common Rule, and Part 2.