Hospitals and hospital systems in Connecticut must file annual reports by January 15, 2018 describing (1) the activities of their group practices (e.g., medical foundations or faculty practice plans), and (2) their respective affiliations with other hospitals or hospital systems.
Under Section 19a-486i of the Connecticut General Statutes, hospitals and hospital systems in Connecticut are obligated to file the separate reports in writing on an annual basis with the Connecticut Attorney General (AG) and Department of Public Health (DPH). Previously, the reports had been due by December 31 each year, but legislation passed last fall to implement the state budget revised the deadline. As a result, the current reporting deadline is January 15, 2018. The respective reports are to be submitted via email to the AG and DPH simultaneously, as described in the links provided below.
- DPH has published guidance concerning the group practice reporting requirement, including forms for reporting and filing instructions, at the following website: http://www.ct.gov/dph/cwp/view.asp?a=3902&q=556534.
- DPH has also published guidance concerning the affiliate filing requirement, including forms for reporting and instructions for filing the report, at the following website: http://www.ct.gov/dph/cwp/view.asp?a=3902&q=590610.
- Please note that the above websites do not appear to have been updated following the change to the reporting deadline enacted during the 2017 legislative session, so the deadline in those forms and instructions is not accurate.
In addition to the above reporting requirements applicable to hospitals and hospital systems, under Section 19a-486i(h) any group practice in Connecticut comprised of 30 or more physicians that is not already the subject of a written report filed by a hospital or hospital system must file a written report concerning the group practice with the AG and DPH. The report must include the same information as that provided by a hospital or hospital system, except that a group practice reporting under this provision need not include a description of the nature of the relationship between the hospital or hospital system and the group practice.
For purposes of Section 19a-486i:
- The term “group practice” is defined as:
Two or more physicians, legally organized in a partnership, professional corporation, limited liability company formed to render professional services, medical foundation, not-for-profit corporation, faculty practice plan or other similar entity (A) in which each physician who is a member of the group provides substantially the full range of services that the physician routinely provides, including, but not limited to, medical care, consultation, diagnosis or treatment, through the joint use of shared office space, facilities, equipment or personnel; (B) for which substantially all of the services of the physicians who are members of the group are provided through the group and are billed in the name of the group practice and amounts so received are treated as receipts of the group; or (C) in which the overhead expenses of, and the income from, the group are distributed in accordance with methods previously determined by members of the group. An entity that otherwise meets the definition of group practice under this section shall be considered a group practice although its shareholders, partners or owners of the group practice include single-physician professional corporations, limited liability companies formed to render professional services or other entities in which beneficial owners are individual physicians.
- The term “primary service area” is defined to mean “the smallest number of zip codes from which the group practice draws at least 75% of its patients.”
- In guidance, the AG has explained that the primary service area is calculated by aggregating zip codes until the group practice accounts for 75% or more of its patient volume for a service location, and the zip codes are derived from where the patients reside.
- Finally, the term “hospital system” refers to “a parent corporation of one or more hospitals and any entity affiliated with such parent corporation through ownership, governance or membership; or a hospital and any entity affiliated with such hospital through ownership, governance or membership,” and the term “hospital” includes any short-term acute care general or children’s hospital licensed by DPH.