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Update on CMS’s Process for Approving Provider Transactions Structured as Equity Transfers (CHOI)

By Alison Hollender & Mackenzie Wortley on July 29, 2020
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Healthcare Providers

Recently, CMS changed its process for approving provider transactions structured as equity transfers – which in Medicare’s eyes is generally classified as a change of information (“CHOI”).  Previously, the process for approving such a transaction was for the provider to submit the applicable 855 Enrollment Application as CHOI to the provider’s assigned Medicare Administrative Contractor (“MAC”) and the MAC would then approve the CHOI.  With this prior process, a provider only needed MAC approval for CHOIs. The CMS Regional Office only reviewed initial enrollments and changes of ownership (“CHOWs”).

But CMS has changed this process.  Now, after the MAC’s review of the 855 Enrollment Application, all transactions involving equity transfers are then sent to the provider’s respective CMS Regional Office to verify that the transaction truly constitutes an equity transfer instead of a CHOW.  If the transaction is truly a stock transfer, the provider will receive an approval letter from its CMS Regional Office stating that its transaction is in fact a CHOI and not a CHOW.  This is an additional step in the transaction’s regulatory process that we believe will add 1-2 months to obtain regulatory approvals for transactions structured as equity transfers.

Photo of Alison Hollender Alison Hollender

Alison knows the legal issues of healthcare transactions backwards and forwards—and she also knows the concerns and goals of the organizations involved. Before pursuing a law career, Alison worked at Cook Children’s Healthcare System and earned a master’s in healthcare administration. Both experiences…

Alison knows the legal issues of healthcare transactions backwards and forwards—and she also knows the concerns and goals of the organizations involved. Before pursuing a law career, Alison worked at Cook Children’s Healthcare System and earned a master’s in healthcare administration. Both experiences gave her an inside view of healthcare organizations.

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Photo of Mackenzie Wortley Mackenzie Wortley

Mackenzie offers practical legal advice so healthcare clients can focus on patient care. Mackenzie helps healthcare organizations remain compliant with a complex and changing web of federal and state regulations.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    Healthcare Law Insights
  • Organization:
    Husch Blackwell LLP
  • Article: View Original Source

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