CMS recently issued a Stark Advisory Opinion, which may offer additional flexibility for physician practices in growth mode, write attorneys with Hall Render Killian Heath & Lyman.
CMS-AO-2021-01 concerns a group practice’s proposal to furnish designated health services through two wholly owned subsidiary entities that do not, themselves, qualify as group practices. CMS concluded the proposed structure did not preclude the group practice from qualifying as a “single legal entity” as required by the Stark group practice definition. This structure offers certain benefits for private equity and other groups looking to quickly expand and acquire other practices, as well as other strategic opportunities. Read more.
