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CMS-1403-FC
physicians the flexibility to work for other physician
groups or health care entities or to work as a locum tenens
physician.
Comment: A commenter requested that, if Alternative 1
is finalized, we clarify that a physician employee would be
considered to be sharing a practice with a physician or a
physician group whether the physician is hired directly or
is a leased employee, whereas other commenters stated that
employment and contractual arrangements might not be enough
for determining whether a physician “shares a practice” as
this could be circumvented via shareholder, ownership, or
joint partnership arrangements.
A commenter asked that we consider including
physicians who are employed by affiliated (common
ownership) organizations. This would allow affiliated
organizations to share physician resources and expertise
when interpreting tests via teleradiology. The commenter
also noted a concern that employers may not have knowledge
of all independent physician and supplier contracts and may
not have sufficient mechanisms to ensure sole employment.
This commenter requested clarification on how to manage
independent physician and supplier contracts to ensure that
physicians are employed by only one organization.
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