Our Client is one of the largest hospital health delivery systems in the country. The hospitals in the system are managed by a ‘Management Group’ specifically created for this purpose and with a complex set of affiliations with the hospitals and institutions of higher education. Medical Residents are hired by the Management Group to work at various hospitals in the system. The California Service Center began demanding documentation to establish ‘affiliation’ based on a very restrictive interpretation of the regulations. The Service stated, a relationship to or affiliation with the institution of higher education can exist only if one of the following relationships could be documented: (1) shared ownership or control by the same board or federation or, (2) by operation by the University or, (3) that the petitioning organization is attached to the University as a member, branch, cooperative, or subsidiary.

To complicate matters, our Client underwent substantial restructuring and a new ‘Management Group (II)’ was created as a successor in interest to the existing organization. The Firm was able to use an Interim Memo to successfully petition for Medical Residents avoiding disruptions to the massive program and continue servicing the needs of the various hospitals involved in the system.