Surgery Centers

Physician investment, joint ventures, operating agreements, and the requirements behind your center.

Surgery Centers

Physician investment, joint ventures, operating agreements, and the requirements behind your center.

Surgery Centers

Physician investment, joint ventures, operating agreements, and the requirements behind your center.

A new investor changes more than the cap table.

The proposed partner brings capital and a different view of the business. The agreement needs to address control, distributions, future funding and the circumstances in which an owner can leave.

We read those terms alongside the management, physician and property arrangements. The goal is a clear view of the relationship you are creating, including the questions that can become difficult once the center is operating and expectations diverge.

A new investor changes more than the cap table.

The proposed partner brings capital and a different view of the business. The agreement needs to address control, distributions, future funding and the circumstances in which an owner can leave.

We read those terms alongside the management, physician and property arrangements. The goal is a clear view of the relationship you are creating, including the questions that can become difficult once the center is operating and expectations diverge.

A new investor changes more than the cap table.

The proposed partner brings capital and a different view of the business. The agreement needs to address control, distributions, future funding and the circumstances in which an owner can leave.

We read those terms alongside the management, physician and property arrangements. The goal is a clear view of the relationship you are creating, including the questions that can become difficult once the center is operating and expectations diverge.

The setting determines the approval path.

The setting determines the approval path.

The setting determines the approval path.

Federal framework

The Centers for Medicare & Medicaid Services (CMS) certifies participating ASCs under the Conditions for Coverage in 42 CFR Part 416. Governing-body responsibilities, patient rights and facility operations form part of that framework. CMS ASC requirements.

Applications

Medicare enrollment and initial-certification work, including CMS-855B and CMS-377 as applicable. We distinguish enrollment, certification and any California licensure requirements. CDPH ASC application guidance.

Changes and survey response

Ownership changes, agency correspondence, survey deficiencies and plans of correction, considered with the transaction documents and operating responsibilities.

State regulator

California Department of Public Health (CDPH), Licensing and Certification. The surgical-clinic framework depends on ownership and operation; physician or dentist offices have a different statutory treatment. CDPH surgical-clinic definition.

Initial and ownership applications

HS 200, organizational disclosures and other applicable submissions. We connect the licensing record to the buyer, operating entity, lease and management arrangement. CDPH initial/CHOW checklist.

Premises and services

Facility leases, construction responsibilities, equipment arrangements and proposed service changes. The planned use and approval responsibilities belong in the property negotiations.

Accreditation framework

The Medical Board of California approves accrediting agencies for covered outpatient surgery settings. Accreditation, CDPH licensure and CMS certification are distinct routes with setting-specific requirements and exemptions. Medical Board guidance.

Operating agreements

Anesthesia services, professional coverage, transfer arrangements, credentialing responsibilities and management contracts, matched to the applicable setting.

Reporting and review

We assess applicable adverse-event, patient-transfer and related reporting questions, agency correspondence and corrective-action work. Medical Board reporting forms.

These categories can overlap. We identify the center's actual status before planning a transaction or operational change.

Put the ownership terms beside the referral analysis.

An investment can raise questions about compensation, referral relationships and decision-making. We assess the applicable Anti-Kickback Statute analysis and any relevant ASC investment safe harbor against the facts. Safe-harbor protection depends on satisfying its requirements. HHS OIG overview.

The operating agreement also needs to work commercially: capital calls, voting, distributions, transfer restrictions, valuation and exit. We address those provisions together so the regulatory and business terms support the same arrangement.

For the physician practice, see Medical Practices & Physician Groups. For system-level affiliations, see Hospitals & Health Systems.

Put the ownership terms beside the referral analysis.

An investment can raise questions about compensation, referral relationships and decision-making. We assess the applicable Anti-Kickback Statute analysis and any relevant ASC investment safe harbor against the facts. Safe-harbor protection depends on satisfying its requirements. HHS OIG overview.

The operating agreement also needs to work commercially: capital calls, voting, distributions, transfer restrictions, valuation and exit. We address those provisions together so the regulatory and business terms support the same arrangement.

For the physician practice, see Medical Practices & Physician Groups. For system-level affiliations, see Hospitals & Health Systems.

Put the ownership terms beside the referral analysis.

An investment can raise questions about compensation, referral relationships and decision-making. We assess the applicable Anti-Kickback Statute analysis and any relevant ASC investment safe harbor against the facts. Safe-harbor protection depends on satisfying its requirements. HHS OIG overview.

The operating agreement also needs to work commercially: capital calls, voting, distributions, transfer restrictions, valuation and exit. We address those provisions together so the regulatory and business terms support the same arrangement.

For the physician practice, see Medical Practices & Physician Groups. For system-level affiliations, see Hospitals & Health Systems.

Meet the people doing the work.

Meet the people doing the work.

Meet the people doing the work.

FAQ

FAQ

FAQ

Yes. Share the proposed ownership, expected role, financial terms and current agreements. We can identify the business and regulatory questions while there is still room to shape the deal.

Yes. Bring the governing agreements and the decisions or payments in dispute. We can assess the available options and agree on a fixed-fee scope for the next stage.

Your introduction to Cove

Start with a conversation about what you need.

If you decide to move forward, we’ll agree on the work and its fixed fee before we begin.

Have a particular matter in mind? Tell us about it.

Share what you’re working through or working toward.

Send relevant documents ahead of time so we can come prepared.

Your introduction to Cove

Start with a conversation about what you need.

If you decide to move forward, we’ll agree on the work and its fixed fee before we begin.

Have a particular matter in mind? Tell us about it.

Share what you’re working through or working toward.

Send relevant documents ahead of time so we can come prepared.

Your introduction to Cove

Start with a conversation about what you need.

If you decide to move forward, we’ll agree on the work and its fixed fee before we begin.

Have a particular matter in mind? Tell us about it.

Share what you’re working through or working toward.

Send relevant documents ahead of time so we can come prepared.