Denise Webb Glass

Office Administrative Partner, Dallas
Norton Rose Fulbright US LLP

Dallas
United States
T:+1 214 855 8063
Dallas
United States
T:+1 214 855 8063
Denise Webb Glass

Denise Webb Glass

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Biography

Denise Glass, a partner in the Health Care Transactional group of the Dallas location, joined in 1997. Her practice is devoted to operational, business and related regulatory issues affecting the health care services industry.

As reimbursement methodologies have evolved and managed care contracting has become more complex, Denise represents health care providers in the development and negotiation of various types of managed care and/or value-based care arrangements for both commercial and government products, including Medicare Advantage, Medicaid and TRICARE, as well as bundled payment, performance-based, and risk contracting arrangements.  She also has significant experience in the development, organization and operation of various types of managed care and insurance-related entities, including accountable care organizations and clinically integrated networks. She provides advice on managed care compliance matters, including issues related to participation in state managed Medicaid programs, the Medicare Advantage program and the various CMS Innovation Center models. Denise has also handled numerous matters involving pharmacy benefit management companies, group purchasing organizations and the development and management of employer on-site and retail health clinics. 

In addition, Denise regularly advises health care providers and business associates on issues relating to health information technology and HIPAA compliance, including matters involving data breaches, incident response and cybersecurity issues.  She has advised multiple clients regarding the development of or participation in health information exchanges and information blocking compliance. 

Denise also has broad experience handling transactions involving physicians and hospitals, including advising on compliance aspects arising under the federal anti-kickback statute and the Stark law, formation, acquisition and disposition considerations, corporate practice of medicine and joint venture arrangements. She frequently handles operational issues affecting both for-profit and tax-exempt hospitals, ambulatory surgery centers, and other health care providers including, but not limited to, licensure, credentialing, medical staff, marketing, offshoring, price transparency and billing matters. 

Denise serves as the Administrative Partner for the Dallas Office and recently completed a two-year term as the Chair of the Diversity & Inclusion Committee for Norton Rose Fulbright US LLP.

Professional experience

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JD, cum laude, University of Houston Law Center, 1996
BA, cum laude, French, The University of Texas at Austin, 1993

Denise has also completed the course work for a Masters of Public Health from the University of Texas Health Science Center in Houston. She was admitted to practice law in Texas in 1996.

  • Texas State Bar
  • Formation of and contracting with accountable care organizations
  • Structuring bundled payment, risk and value-based payment relationships
  • Negotiation of pharmacy benefit management and administrative services agreements for self-funded employee health benefit plans
  • Development of employer on-site and retail health clinics and pharmacies
  • Negotiation of managed care contracts
  • Advising on HIPAA compliance and breach notification matters
  • Development of regional health information exchanges
  • Chambers USA, Texas: Healthcare, Chambers and Partners, 2015 – 2024
  • Fellow, American Bar Foundation, 2014
  • Outstanding Young Healthcare Lawyer, Nightingale's Healthcare News, 2009
  • The Best Lawyers in America, Dallas: Lawyer of the Year, Health Care Law, Best Lawyers, 2025
  • The Best Lawyers in America, Health Care Law, Best Lawyers, 2009 - 2025
  • BTI Client Service All–Star, The BTI Consulting Group, 2019
  • Lawyer of the Year, Dallas: Healthcare Law, Best Lawyers, 2015, 2017
  • Texas Women Lawyers, Best Lawyers, 2014, 2015
  • Outstanding Physician Practice Lawyer, Nightingale's Healthcare News, 2006
  • Texas Rising Star, health law, Thomson Reuters, 2005 – 2006, 2008, 2010 – 2012
  • Texas Super Lawyer, Healthcare, Thomson Reuters, 2013 – 2020, 2022
  • Who's Who in America, Marquis
  • Co-Author with Jeff Wurzburg and Joseph Keillor, "The Transformative Possibilities of the Value-Based Fraud & Abuse Reforms," AHLA Briefing, January 14, 2021
  • "Little mistakes can lead to big consequences: HIPAA Right of Access Initiative," Norton Rose Fulbright Health Law Check-up, December 2020
  • Co-Author with Megan Engel and Rick Robinson, "Selling to and Negotiating with Payors," Chapter 4-8 of Bringing Your Pharmaceutical Drug to Market, Food and Drug Law Institute, 2015
  • Co-author, "HHS Releases Long-Awaited HIPAA Omnibus Regulations," Fulbright Briefing, January 22, 2013
  • Co-author with Thomas E. Dowdell and Mark Faccenda, "Telehealth Technology Opportunity for Certain Rural Providers," Fulbright & Jaworski L.L.P. Briefing, March 4, 2011
  • "Managed Care and the Litigation Landscape," Chapter 1, Managed Care Litigation, Bureau of National Affairs, Health Law Section, American Bar Association, 2005, 2007 Supplement, 2009 Cumulative Supplement, 2010 Cumulative Supplement, 2011 Cumulative Supplement, 2012 Cumulative Supplement, 2016 Cumulative Supplement, 2017 Cumulative Supplement
  • "The Lowdown on HITECH Breach Notification Requirements," ABA Health eSource, Vol. 6, No. 8, April 2010
  • "Legal Implications of Creating Patient Cost-Sharing Parity by Out-of-Network Providers," ABA Health eSource, Vol. 4, No. 6, February 2008
  • "Making P4P as Easy as 1, 2, 3," ABA Health eSource, Vol. 3, No. 7, March 2007
  • "Health Benefits Plans Shift Gears," Dallas Bar Association Headnotes, January 1, 2007
  • Contributor, Fifty State Survey on Balance Billing Laws, American Health Lawyers Association, December 2006
  • "Hospital Pricing Practices Under Scrutiny," Dallas Bar Association Headnotes, January 1, 2005
  • "The Impact of the Corporate Practice of Medicine Doctrine on the Formation of Integrated Delivery Systems in Texas," State Bar Section Report, State Bar of Texas Health Law Section, Winter 1997

Denise has given numerous speeches on various health care topics, including discounting practices, legislative and regulatory developments, managed care issues, and HIPAA/health information technology matters. Her recent speeches include:

  • Co-presenter, "Risky business: The evolution of clinically integrated networks," 20th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 25, 2024
  • Co-presenter, "88thTexas Legislature - 2023 Healthcare Legislative Update," Norton Rose Fulbright webinar, August 2, 2023
  • Co-presenter, "Under a microscope: Tips and best practices for handling increased reviews and audits by third party payors," 19th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 26, 2023
  • Co-presenter, "Navigating a post-Dobbs world: Operational issues impacting healthcare providers," Norton Rose Fulbright webinar, October 18, 2022
  • Co-presenter, "Behavioral health: The post-pandemic transactional landscape," Norton Rose Fulbright webinar, December 3, 2020
  • Co-presenter, "State of the Union: COVID-19 now," Norton Rose Fulbright web seminar, (recurring)
  • Co-presenter, "Healthcare data sharing: What's mine isn't necessarily yours and what's your came from what's mine," 16th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 23, 2020
  • Co-presenter, "The Threat Actor Landscape: Developments in attacker tactics, techniques and procedures, and associated legal issues," 15th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 24, 2019
  • Co-presenter, "Third Party Payor and Governmental Payment and Reimbursement Trends," 36th Annual National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Snowmass, Colorado, January 2, 2019
  • "Privacy and data security: Concerns for Life Sciences and Healthcare Companies," webinar presentation sponsored by Norton Rose Fulbright, February 15, 2018
  • "Potential arrangements to improve quality and drive profits: Payor-provider collaborations," 14th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 26, 2018
  • "The best defense is a good offense: Technical and legal insights from recent ransomware responses," 14th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 25, 2018
  • "What are Payors Up To? Collaboration, Coordination and Our Crystal Ball," 35th Annual National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Snowmass, Colorado, January 5, 2018
  • "The growth of population health within CINs and ACOs," webinar presentation sponsored by Norton Rose Fulbright, May 11, 2017
  • "First 100 Days Under President Trump: How Has American Health Care Changed Direction?," 2017 Healthcare Finance Institute, Austin, Texas, April 30, 2017
  • "Cybersecurity and PCI Compliance," panel presentation Healthcare Treasurers' Roundtable, Phoenix, Arizona, April 27, 2017
  • "Data Privacy and Security 2.0," 13th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 26, 2017
  • "ACO and CIN Developments," 13th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 27 2017
  • "Delivered from their Distress: Acquisition Challenges and Opportunities of Distressed Hospitals," 34th Annual National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Snowmass, Colorado, January 8, 2017
  • "Privacy and data security: Concerns for life sciences and healthcare companies," webinar presentation sponsored by Norton Rose Fulbright, November 9, 2016
  • "Perspectives on data use--Now that we've got it, what do we do with it?," Women's Life Sciences Summit sponsored by Norton Rose Fulbright, New York, New York, October 27, 2016
  • "Provider network risk arrangements," webinar presentation sponsored by Norton Rose Fulbright, September 29, 2016
  • "Demystifying Reference Based Pricing and Determining Whether It Will Work for Your Client," State Bar of Montana - Health Law Section, April 12, 2016
  • "From Cloud 9 to Dark Clouds: Managing Big Data and Cloud Security Issues," 12th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 28, 2016
  • "Straight Outta Network: Legal Risks Associated with Provider or Payer-Driven Out of Network Strategies," 33rd Annual National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Vail, Colorado, January 8, 2016
  • "Cybersecurity: Don't Let Breach Exceed Your Grasp!," Norton Rose Fulbright Women's Initiative Conference Series November 11, 2015
  • "Healthcare Legislative Update," webinar presentation sponsored by Norton Rose Fulbright, September 30, 2015
  • "Preventative Privacy Risk Management: Just What the Doctor Ordered," 11th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 29, 2015
  • "Accountable Care Turns 3: ACOs as Toddlers and Emerging Private Sector Initiatives," 32nd Annual National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Vail, Colorado, January 9, 2015
  • "ACO Development: Lessons Learned," Healthcare Landscape 2014--South Texas Annual Joint Healthcare Conference co-sponsored by American College of Healthcare Executives, Healthcare Financial Management Association and Greater San Antonio Healthcare Foundation, San Antonio, Texas, January 31, 2014
  • " Road to Success or Highway to Hell?  Lessons Learned in the Development of ACOs and Clinically Integrated Networks," 10th Annual Health Law Symposium sponsored by Norton Rose Fulbright, Austin, Texas, January 30, 2014
  • "Is Accountable Care the Answer?  What was the Question?," 2014 National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Vail, Colorado, January 8, 2014
  • "83rd Texas Legislative Session Health Care Update," webinar presentation co-sponsored by State Bar of Texas Health Law Section and Texas Hospital Association, July 30, 2013
  • "Legislative Update 2013: The Texas Legislature and Healthcare," State Bar of Texas Health Law Section Annual Meeting, Dallas, Texas, June 21, 2013
  • "Implementation of the HIPAA/HITECH Omnibus Rule: Is your Hospital Ready?," webinar presentation sponsored by the Texas Hospital Association, April 9, 2013
  • "HIPAA Omnibus Regulations: They're Here (Finally), Now What?,"  webinar presentation sponsored by Fulbright & Jaworski L.L.P., January 25, 2013
  • "Managing More Managing in Managed Care," 2013 National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Snowmass, Colorado, January 2, 2013
  • "The Marriage of Quality and Reimbursement," Health Law Symposium sponsored by the Louisiana Hospital Association, Baton Rouge, Louisiana, November 7, 2012
  • "The Marriage of Quality and Reimbursement: A Match Made in Heaven or a Shotgun Wedding?," 13th Annual Emerging Issues in Healthcare Law sponsored by the American Bar Association Health Law Section, San Diego, California, February 23, 2012
  • Moderator, "Transactions: How to Avoid Potholes in the Road to a Value-Driven Delivery System," 8th Annual Health Law Symposium sponsored by Fulbright & Jaworski L.L.P., Austin, Texas, February 2, 2012
  • Panelist, "Privacy/HITECH," 8th Annual Health Law Symposium sponsored by Fulbright & Jaworski L.L.P., Austin, Texas, February 2, 2012
  • "Quality of Care Issues," 2012 National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Snowmass, Colorado, January 5, 2012
  • "Managing More Managing in Managed Care," 2011 Texas Health Law Conference co-sponsored by the Health Law Section of the State Bar of Texas and the Texas Hospital Association, Austin, Texas, October 10, 2011 
  • "Hospital Public Relations on the Frontline: Health Care Privacy...What Every Hospital PR Professional Should Know," webinar presentation sponsored by the Texas Hospital Association, August 11, 2011
  • "Texas Health Care Legislative Summary," Dallas Bar Association Health Law Section, July 20, 2011
  • "82nd Texas Legislative Session Health Care Update," webinar co-provided by the Texas Hospital Association and the Health Law Section of the State Bar of Texas, July 19, 2011
  • "Accountable Care Organizations: Risk Sharing and Licensure Implications under State Law," webinar presentation sponsored by Fulbright & Jaworski L.L.P., June 1, 2011
  • "Accountable Care Organizations and Provider Integration," 7th Annual Health Law Symposium sponsored by Fulbright & Jaworski L.L.P., Houston, Texas, February 3, 2011
  • "Health Care Reform in Practice: Implications for Employers and Managed Care Plans," 2011 National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Vail, Colorado, January 7, 2011
  • "Legal Issues Associated with EHRs and Meaningful Use," presentation sponsored by the Executive Healthcare Network, November 10, 2010
  • "Insurance Market Reform: New Ways of Providing Coverage, New Considerations for Employer-Sponsored Benefit Plans," teleconference presentation sponsored by the ABA Health Law Section, May 26, 2010
  • "Meaningful Use," presentation to the Women's Healthcare Executive Network, Dallas, Texas, May 19, 2010
  • "Health Care Reform - Opportunities: Re-thinking Health Care Delivery," webinar presentation sponsored by Fulbright & Jaworski L.L.P., May 5, 2010
  • "Legal, Privacy and Security Issues for Hospitals," Texas Health IT Summit sponsored by the TMF Health Quality Institute and the Texas Health Institute, Dallas, Texas, April 23, 2010
  • "Legal Challenges," webinar presentation sponsored by the Texas Society for Healthcare Human Resources Administration and Education, March 4, 2010
  • "Employer Sponsored Health Plans and Managed Care: Avoiding Past Bad Experiences in Planning for Health Care Reform?," 2010 National Health Law CLE Conference sponsored by the Law Education Institute and Colorado Bar Association, Vail, Colorado, January 8, 2010
  • "HITECH Act Provisions Affecting Privacy and Security," webinar sponsored by the Texas Hospital Association, December 10, 2009 
  • "For Better or For Worse, Healthcare Reform from Washington," panel presentation sponsored by the Dallas Regional Chamber, Dallas, Texas, October 16, 2009
  • "Legislative Updates and Health Care Reform: Change is Afoot!," 2009 Texas Health Law Conference co-sponsored by the Health Law Section of the State Bar of Texas and the Texas Hospital Association, Austin, Texas, October 12, 2009
  • "2009 Texas Legislative Session in Review," Dallas Bar Association Health Law Section, Dallas, Texas, July 15, 2009
  • "Show Me the Money: The Distribution of Healthcare IT Funds under the Obama Plan – Promise v. Reality," moderator for panel presentation sponsored by the Health Industry Council of the Dallas-Fort Worth Region, Dallas, Texas, May 11, 2009
  • "Where Are We Headed with Managed Care," 26th Annual National Health Law Conference sponsored by the Law Education Institute and Colorado Bar Association, Vail, Colorado, January 5, 2009
  • "Managed Care Litigation – Same Song, Different Verse?," teleconference presentation sponsored by the ABA Health Law Section, December 9, 2008
  • "Managed Care Update," 2008 Texas Health Law Conference co-sponsored by the Texas Hospital Association and the Health Law Section of the State Bar of Texas, Austin, Texas, November 3, 2008
  • "The New Interactions Between Payors and Providers: The Emerging Battlefield and Cost-Efficiency Tactics," 9th Annual Emerging Issue Conference sponsored by the American Bar Association Health Law Section, San Diego, California, February 22, 2008
  • "Managing Managed Care: How to Contract for Prompt Payment and Enforce the Bargain," 4th Annual Health Law Symposium sponsored by Fulbright & Jaworski L.L.P., Austin, Texas, February 7, 2008
  • "Health Care Hot Topics," Greater Dallas Chamber of Commerce, Dallas, Texas, October 3, 2007
  • "Employing Clinically Integrated Networks to Boost Quality Cost Efficiently," Optimizing Provider Network Development and Management Conference sponsored by the Institute for International Research, Dallas, Texas, September 25, 2007
  • "How to Handle the Disruptive Practitioner," Annual Conference sponsored by the Texas Society for Healthcare Human Resources Administration and Education, Corpus Christi, Texas, September 19, 2007
  • "Medical/Legal/Economic Issues," Spring Break Meeting sponsored by North American Spine Society, Phoenix, Arizona, March 15, 2007
  • "Managed Care Contracting," Winter Meeting sponsored by Healthcare Financial Management Association McMahon-Illini Chapter, Peoria, Illinois, January 25, 2007
  • "Charity Care Compliance Issues," 2nd Annual Health Law Symposium sponsored by Fulbright & Jaworski L.L.P., Austin, Texas, June 8-9, 2006
  • "Provider Outlook: A Tale of Two Health Plans," 18th Annual Health Law Conference sponsored by The University of Texas School of Law, Houston, Texas, April 20, 2006
  • "Fundamentals of Managed Care: Everything You Always Wanted to Know About Managed Care But Were Afraid to Ask," teleconference presentation sponsored by the ABA Health Law Section, October 27, 2005
  • "Managed Care 2005: Products, Politics and Privatization," 17th Annual Health Law Conference sponsored by The University of Texas School of Law, Houston, Texas, April 7, 2005
  • "Compliance Guidance for Hospitals: Self-Pay Patient Discounts," South Texas Annual Joint Healthcare Conference sponsored by Healthcare Financial Management Association, American College of Healthcare Executives, and Greater San Antonio Hospital Council, San Antonio, Texas, January 28, 2005
  • "Antitrust Compliance in the Managed Care Context," Managed Care Executives conference sponsored by VHA Southwest, Plano, Texas, December 3, 2004
  • "Aetna Health Inc. v. Davila and Cigna Healthcare of Texas, Inc. v. Calad: Implications for Litigators and Health Plans," moderator for teleconference presentation sponsored by the ABA Health Law Section, June 30, 2004
  • "Managed Care Contracting: Encountering Challenges and Exploring Solutions," Texas Association for Healthcare Financial Administration Annual Meeting, San Antonio, Texas, April 29, 2002
  • "Medicaid Managed Care: Under New Management," panel presentation at the ABA Health Law Section 5th Annual Managed Care Law Summit, Washington, D.C., April 8, 2002
  • Health Law Exam Commission, Texas Board of Legal Specialization (2014 - 2024)
  • Health Law Advisory Commission, Texas Board of Legal Specialization (2008 - 2014)
  • University of Texas Southwestern Medical School, "Medical Law" course, Co-Instructor, Spring 2007
  • American Bar Association - Health Law Section
    • Budget Officer (2021-2024)
    • Budget Officer Elect (2020-2021)
    • Health Law Section Governing Council (2012 - 2015)
    • Chair, Finance Committee (2021-2024)
    • Co-Chair, Publications Book Editorial Board (2018-2020)
    • Chair, Coordinating Committee on Diversity (2015 - 2017)
    • Co-Chair, Programs Executive Committee (2015 - 2018)
    • Co-Chair, 2012 and 2013 Emerging Issues Conferences
    • Vice Chair, Diversity & Inclusion Committee (2024-2025)
    • Vice Chair, Membership Committee (2024-2025)
    • Vice Chair, Strategic Solutions Committee (2024-2025)
    • Vice Chair, Partnerships & Collaboration Committee (2023-2024)
    • Vice Chair, Sponsorship Committee (2018 - 2023)
    • Vice Chair, Leadership Meeting Planning Committee (2016 - 2018)
    • Vice Chair, Interest Group Leadership Team (2011 - 2012)
    • Vice Chair, Programs Executive Committee (2011 - 2013)
    • Managed Care & Insurance Interest Group, Chair (2010 - 2011)
    • Managed Care & Insurance Interest Group, Vice Chair (2008 - 2010)
  • State Bar of Texas - Health Law Section
    • State Bar of Texas Health Law Council Immediate Past Chair (2015 - 2016)
    • State Bar of Texas Health Law Council Chair (2014 - 2015)
    • State Bar of Texas Health Law Council Chair Elect (2013 - 2014)
    • State Bar of Texas Health Law Council Vice Chair (2012 - 2013)
    • State Bar of Texas Health Law Council Secretary (2011 - 2012)
    • State Bar of Texas Health Law Council Treasurer (2010 - 2011)
    • State Bar of Texas Health Law Council (2008 - 2010)
  • Dallas Bar Association
    • Health Law Section - Immediate Past Chair (2006), Chair (2005), Vice-Chair (2004), Treasurer (2003)
  • American Health Lawyers Association
  • Certified in Health Law, Texas Board of Legal Specialization (2002 - present)
  • Cook Children's Health Care System
    • Institutional Review Board Member (2009 - Present)
  • The Episcopal Church of St. Thomas the Apostle
    • Vice Chancellor (2000 - 2003)
    • Chancellor (2003 - 2020)
  • Multilingual Open Door Preschool
    • Board of Directors (2001 - 2004)
    • Chair (2002 - 2004)
  • French

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