VALLEY FORGE, PA, April 6, 2015 – Charles M. Honart, Kirsten McAuliffe Raleigh and Daniel J. Hennessey of Stevens & Lee presented at the Pennsylvania Bar Institute’s 21st Annual Health Law Institute held March 12-13, 2015 in Philadelphia, PA.
In “Taxing Exempt Organizations: A 2015 Update,” Messrs. Honart and Hennessey discussed developments in federal income tax law affecting tax-exempt health care organizations. The presentation included information on developing compliant hospital billing, collection and charity care policies under Section 501(r) of the Internal Revenue Code; analyzing tax issues affecting multi-entity health care joint ventures, affiliations and acquisitions; reviewing new IRS guidance on accountable care organizations and tax-exempt bonds; and analyzing new IRS forms, rulings and enforcement activity.
Ms. Raleigh co-presented “The Current Status of Provider-Based Status,” in which she helped attendees to distinguish between provider-based status and outpatient hospital services provided “under arrangement.” The presentation also covered documentation requirements for an acceptable provider-based attestation and upcoming changes in the Medicare Administrative Contractors’ review process, as well as the provider-based implications of operating an acquired hospital as a remote location, and shared space arrangements. Attendees also learned about the Office of the Inspector General’s recent focus in its Work Plans on the impact of provider-based status on Medicare billing and the uncertain future of the provider-based payment differential.
Mr. Honart is Co-Chair of Stevens & Lee’s Health Care Department. He represents health care providers, including health care systems, managed care organizations, integrated delivery systems and physician groups in a wide range of matters, including mergers and acquisitions, joint ventures, affiliations and reorganizations, exempt organization tax planning and tax-exempt financing, health care contracting, compliance and medical staff and reimbursement matters. He also handles Medicare and Medicaid billing and related regulatory matters, licensure matters and health care antitrust matters.
He lectures on health care, tax and antitrust issues affecting nonprofit organizations and health care providers before numerous organizations and is the author of various articles on tax and health care subjects. He was also an adjunct professor at the Temple University School of Law Graduate Tax Program. Mr. Honart has a J.D., magna cum laude, from University of Pennsylvania Law School and a B.A., magna cum laude, Phi Beta Kappa, from Cornell University, B.A.
Ms. Raleigh, a Shareholder with Stevens & Lee, provides regulatory and compliance advice to clients in the health care industry, advising on Medicare and Medicaid enrollment, coverage and reimbursement issues, provider-based restructuring considerations, licensure and certification of providers and health care services, EMTALA compliance and tax-exempt issues. She helps clients understand and apply the wide variety of regulatory requirements with which health care businesses must comply.
Ms. Raleigh also assists clients in developing and implementing corporate compliance programs and in handling internal regulatory investigations, and advises on the implementation of corrective action plans, including self-reporting overpayments and regulatory violations to appropriate governmental agencies. Her work often arises in connection with mergers, acquisitions, restructuring and other business transactions entered into by entities that own and operate health care providers and suppliers. Ms. Raleigh holds a J.D., cum laude, from Widener University School of Law and a B.A. from Bucknell University.
Mr. Hennessey, an Associate with Stevens & Lee, focuses his practice on health care matters including tax, regulatory, corporate and transactional issues, and has represented health care systems, hospitals, managed care organizations, accountable care organizations, clinically integrated provider networks, post-acute care providers, medical laboratories, physician practices and other health care providers. He advises clients on a variety of issues involving fraud and abuse laws, exempt organization matters, state and federal licensure and regulation of health care entities, corporate transactions, mergers and acquisitions, joint ventures, health care contracting and physician compensation.
Mr. Hennessey has presented and written on various health care and tax issues affecting nonprofit health care organizations including, among others, health care reform initiatives and new payment models, accountable care organizations and the Medicare Shared Savings Program, and new tax exemption requirements for Section 501(c)(3) hospital facilities under Section 501(r) of the Internal Revenue Code. He has a J.D., summa cum laude, from George Mason University School of Law, and a B.A. and B.S., high distinction, with honors, from The Pennsylvania State University, Schreyer Honors College.
