Extract to table

The CMS-855 enrollment applications (Form CMS-855B for each clinic facility) reflecting the change of ownership must be filed with Keystone MAC promptly following execution of the APA

Pennsylvania's Medicaid enrollment process is generally less complex than New York's and does not require a separate certificate of need or establishment action prior to enrollment; however, enrollment changes cannot take effect retroactively and must be coordinated with the facility license transfer discussed in Section VI below

Failure to satisfy a safe harbor does not necessarily mean that an arrangement violates the AKS, but it does mean that the arrangement must be evaluated on its facts and circumstances

Petrosian must be analyzed under the investment interest safe harbor for small entity investments (42 C

These post-closing consulting agreements must be carefully structured to satisfy both the Stark Law personal services exception (42 C

The three existing medical directorship and administrative services agreements must be reviewed for compliance with the AKS personal services and management contracts safe harbor