American Shared Hospital Services's Comment on Supply Chain
The Company’s proton beam radiation therapy (PBRT) services, utilizing its PBRT system, are reimbursed on a fee-for-service basis and are not included in the Radiation Oncology Model (ROCR Act), which primarily covers external beam radiation therapy (EBRT) for common cancer types. The Company’s Gamma Knife units, a specialized form of EBRT, are expected to fall under the ROCR Act program. Payment models discussed include bundled payments for cancer care episodes under the ROCR Act. Regulatory compliance considerations include adherence to the Stark II law and the Physician Ownership and Referral Act of 1993, which restrict certain physician self-referrals. The Centers for Medicare & Medicaid Services (CMS) Final Rule prohibits per-click payments to physician lessors for referred patients, with exceptions for radiation oncologists referring patients for radiation therapy or ancillary services such as Gamma Knife treatments. GK Financing’s majority-owned subsidiaries, AGKE and JGKE, have minority ownership interests held exclusively by radiation oncologists, which are exempt from the referral prohibitions. The Company states it believes it complies with these regulatory requirements.
American Shared Hospital Services's Comment on Supply Chain
The Company’s proton beam radiation therapy (PBRT) services, utilizing its PBRT system, are reimbursed on a fee-for-service basis and are not included in the Radiation Oncology Model (ROCR Act), which primarily covers external beam radiation therapy (EBRT) for common cancer types. The Company’s Gamma Knife units, a specialized form of EBRT, are expected to fall under the ROCR Act program. Payment models discussed include bundled payments for cancer care episodes under the ROCR Act. Regulatory compliance considerations include adherence to the Stark II law and the Physician Ownership and Referral Act of 1993, which restrict certain physician self-referrals. The Centers for Medicare & Medicaid Services (CMS) Final Rule prohibits per-click payments to physician lessors for referred patients, with exceptions for radiation oncologists referring patients for radiation therapy or ancillary services such as Gamma Knife treatments. GK Financing’s majority-owned subsidiaries, AGKE and JGKE, have minority ownership interests held exclusively by radiation oncologists, which are exempt from the referral prohibitions. The Company states it believes it complies with these regulatory requirements.
Sources:
American Shared Hospital Services's official press releases and regulatory filings; CSIMarket.com's supply-chain research; and the financial filings and press releases of other companies cited in this report.
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