CMS recently published a notification on its website in response to inquiries regarding the annual reporting requirement for physician-owned hospitals. In the notification, CMS expressed concerns about the quality of the data collected for the CY 2014 annual report and noted that it would further examine the details of the report prior to publication. Because of this, the notice indicated that CMS has decided to delay the collection of data for the 2015 annual report until further notice. Finally, the notice indicated that physician-owned hospitals should continue to monitor the CMS website as well as other CMS communication channels for updates related to the annual reporting requirement. 
Physician-owned hospitals that rely on the Stark Law whole hospital exception or rural provider exception should continue to review and prepare ownership and investment information in order to be prepared to submit the appropriate filing upon further notice from CMS. In addition, as a best practice, it is recommended that physician-owned hospitals continue to update the information specific to ownership on CMS Form 855 on at least an annual basis and/or when such hospitals add new members or redeem members.If you have any questions or would like additional information on this requirement, please contact:
- Andrea Impicciche at 317.977.1578 or andreai@hallrender.com;
- Alyssa James at 317.429.3640 or ajames@hallrender.com; or
- Your regular Hall Render attorney.
Please visit the Hall Render Blog at http://blogs.hallrender.com/ for more information on topics related to health care law.
