December 1 Deadline for New Reporting Requirements for Physician-Owned Hospitals Approaching Fast

Healthcare Alert

Client Alert


Physician-owned hospitals that seek to avail themselves of the “whole hospital” exception or “rural provider” exception to the federal physician self-referral law, commonly known as the Stark Law, should carefully review their Medicare enrollment files to ensure compliance with a recently imposed reporting requirement with a fast approaching deadline.

The Stark Law prohibits a physician from referring Medicare patients for designated health services to an entity with which the physician (or the physician’s immediate family member) has a financial relationship, unless an exception applies. To qualify for either the “whole hospital” or “rural provider” exception, the regulations promulgated under the Stark Law require, among other things, that physician-owned hospitals submit to the Centers for Medicare & Medicaid Services (“CMS”) an annual report containing ownership and investment information at such a time and in such a manner as specified by CMS.

CMS has announced that to satisfy the above annual reporting requirement, physician-owned hospitals must report ownership and investment information by following the instructions set forth in the Medicare Enrollment Application (Form CMS-855A), which includes a special attachment for physician-owned hospitals, by December 1, 2013. Hospitals that submitted this information on or after December 1, 2012 on Form CMS-855A will be considered to have met the December 1, 2013 deadline. To continue meeting reporting requirements, physician-owned hospitals must either update their information or verify that the relevant ownership and investment information in the Medicare Provider Enrollment, Chain and Ownership System is correct on an annual basis.

Find the CMS release and additional references at the following link: