UPDATE: New Reporting Requirements Deadline for Physician-Owned Hospitals Extended to March 1

Healthcare Alert

Client Alert


The Centers for Medicare & Medicaid Services (CMS) has extended the deadline for physician-owned hospitals seeking to avail themselves of the “whole hospital” exception or “rural provider” exception to the Stark Law to report ownership and investment information. The old deadline was December 1, 2013. (Visit http://www.bradley.com/december-1-deadline-for-new-reporting-requirements-for-physician-owned-hospitals-approaching-fast-11-19-2013/ for our previous health care alert on the subject.) The new deadline is March 1, 2014.

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 CMS an annual report containing ownership and investment information at such a time and in such a manner as specified by CMS.

To satisfy the above 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. Hospitals that submitted the information on or after December 1, 2012, on Form CMS-855A will be considered to have met the March 1, 2014, 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 updated CMS release and additional references at the following link: https://www.cms.gov/Medicare/Fraud-and-Abuse/PhysicianSelfReferral/Physician_Owned_Hospitals.html