Other fields do this regularly - hospitals often organize their physicians into a distinct staffing org, for instance. It’s entirely legal. So is this anything other than a feel good law that will push some minor corporate restructuring?
Hospitals do this in the opposite direction. If you're in the suburbs a metro area (where cost indexes are higher, so Medicare reimburses at a higher rate), you try to make your own expenses look higher to convince CMS to include your hospital into the same cost index as the metro area itself. One tool to do this is to separate out unskilled workers (housekeeping and the like) into a separate corporation, thus moving the average pay rate higher.
Source: wife managed Medicare and Budget at a large hospital just outside of the NYC area, and did exactly this.
FYI, this is already a common practice.
Clearly, accountants and lawyers can engage in fuckery as they did at Enron. But the law is fully capable of calling out a sham, even it it has recently become reluctant to do so.
[1] https://www.pwc.com/us/en/cfodirect/publications/accounting-...
Yes.
> Do you really need a 10 page long comma separated list of every possible situation?
Yes.
> Yes.
That's not correct, although it doesn't seem like it to everyone because there is so much abuse. Intent matters. Lots of cases have been brought against abuses to circumvent existing laws, which have been successfully litigated.