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Change of Ownership in Healthcare Transactions With Medicare Provider Agreement Assignment

Identifying When a CHOW Occurs, Navigating Medicare Rules, Weighing Benefits and Risks for Buyers and Sellers

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Monday, November 20, 2023

Recorded event now available

or call 1-800-926-7926

This CLE course will guide healthcare counsel on navigating a change of ownership (CHOW) in healthcare transactions when Medicare provider agreements are involved. The panel will discuss the factors to consider when determining whether to accept or reject the assignment of the provider agreement and offer best practices for overcoming the challenges involved.


Does an asset purchase or merger result in a CHOW? Not all healthcare transactions trigger CHOW rules, but when they do, the Center for Medicare and Medicaid Services (CMS) is interested. Both parties in healthcare transactions need to understand the implications of CHOW when there is a Medicare provider agreement in place. There is an automatic assignment of the provider agreement; however, the buyer can choose to reject the assignment. The parties must recognize the potential impact of each option.

CMS encourages automatic assignment of Medicare provider agreements when a CHOW occurs. If a new owner rejects the assignment and later decides to participate in the Medicare program, CMS will consider that owner an "initial" applicant and, as such, will likely be subject to a lengthy gap in Medicare reimbursements.

Counsel for healthcare providers must carefully weigh the benefits and risks when determining whether to accept or reject the automatic assignment of a Medicare provider agreement.

Listen as our authoritative panel examines the factors to consider when there is the potential for a CHOW involving a Medicare provider agreement, including when a CHOW is triggered and the implications of assignment or rejection of the Medicare provider agreement. The panel will offer best practices for buyers and sellers in overcoming the challenges of a CHOW when a Medicare provider agreement is involved.



  1. CHOWs vs. changes of control and their implications
  2. Factors to consider when there is a CHOW
  3. Best practices in overcoming challenges of a CHOW/Medicare provider agreement


The panel will review these and other high priority issues:

  • What constitutes a CHOW for Medicare purposes?
  • What is the effect of a CHOW in a healthcare transaction?
  • What are the implications of accepting or rejecting the assignment of a provider agreement?


Bombalier , Lanchi
Lanchi Nguyen Bombalier

Arnall Golden Gregory

Ms. Bombalier focuses her practice on providing regulatory counseling for a variety of clients in the healthcare and...  |  Read More

Grozine, Jessica
Jessica Grozine

Arnall Golden Gregory

Ms. Grozine focuses her practice on federal and state healthcare regulatory matters, representing nursing homes,...  |  Read More

Rubinger, Hedy
Hedy Rubinger

Arnall Golden Gregory

Ms. Rubinger focuses her practice on the representation of healthcare. She counsels clients on issues related to...  |  Read More

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