Changes in Ownership: Medicare Rules and Other Issues

Reprinted with permission from The American Bar AssociationChanges in ownership : Medicare Rules and Other IssuesAri J. Markenson & Tammy Ward WoffendenReprinted with permission from The American Bar AssociationChanges in ownership : Medicare Rules and Other Issues 2 IntroductionWhen a healthcare provider or supplier is enrolled in Medicare , certain transactions, including an asset transfer to a new owner, are typically classified by the Centers for Medicare & Medicaid Services ( CMS ) as a change of ownership , or CHOW, which requires notification from both seller and buyer, and CMS Regional Office ( RO ) approval. Such a transaction often results in formal assignment of the Medicare number and, if applicable, Medicare provider agreement, to the new owner. In comparison, transactions involving stock or member-ship transfers or Other reorganizations that do not change the tax identification number ( TIN ) on file with CMS typically require the filing of an update of ownership information with CMS.

provide management services, subject to the owners’ general approval of operating decisions, is considered an agent of the owners rather than a partner or successor. This is the case even if the management company appears to have wide latitude in making decisions and even if the management fee is based on the net revenue or profit the

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  Rules, Company, Management, Change, Other, Medicare, Issue, Ownership, Management company, Changes in ownership, Medicare rules and other issues

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