Federal Law Update: Ancillary Joint Ventures After ... - Honigman

Redlands: Why Not Exempt?
• High returns vs. losses at RCH outpatient dept.
• SCA subsidiary as manager with broad authority
– 25 year no cut management contract
– Compensation: 6% of collectable revenues + expenses
– No clear incentive for charity care/Medicaid services
• Arbitration with no requirement to consider
community benefit
• No pure charity care (as opposed to bad debt)
• Negligible Medicaid (