Our client is a physician-owned health system providing general acute care services, graduate medical education, and individually tailored wellness and preventive health programs across 70 subspecialties to more than 1.3 million residents. It represents one of approximately 250 physician-owned hospitals in the United States. The hospital engaged Applied Policy to provide ongoing regulatory monitoring, policy expertise, and strategic guidance on how changes in the political and regulatory environment could affect its operations and long-term growth.
When the client sought opportunities for expansion, it was constrained by the statutory and regulatory framework governing physician-owned hospitals. Specifically, Section 6001 of the Affordable Care Act (ACA) prohibited the development of new physician-owned hospitals and significantly limited the ability of existing physician-owned hospitals to expand. Applied Policy was engaged to navigate the applicable statute and Centers for Medicare & Medicaid Services (CMS) regulations to identify a viable pathway for the hospital to pursue growth despite these restrictions.
Drawing on our knowledge of the Affordable Care Act (ACA) and the Medicare and Medicaid regulatory framework, Applied Policy guided the client through the two pathways available to it as a physician-owned hospital to seek an exception from the prohibition on facility expansion: qualification as an applicable hospital or as a high Medicaid facility. We evaluated the client’s eligibility, developed the appropriate strategy, and successfully guided the hospital through the application process, addressing issues that arose during the federal review process.
As a result of Applied Policy’s work, the hospital became one of only five physician-owned hospitals nationwide to receive approval for expansion during the two-year period in which it applied.
