Satisfying Medicare’s “In Writing” Disclosure Requirement

Q. Under Medicare's ownership disclosure rules that go into effect June 8, 2009, can I satisfy the "in writing" requirement by posting a notice in my office, where patients can see it, of my ownership interest in a local hospital?

A. A Centers for Medicare & Medicaid Services representative verified for TMA that "in writing" in the ownership disclosure rules means you have to give patients a handout when you refer them for treatment to this hospital, or any other facility in which you have an ownership interest. A notice posted in your office is not an acceptable substitute for the handout, which lets patients know you have a financial stake in the facility to which you are referring them.

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