5 min read
2026-03-11
Adding an ASC means a separate legal entity, separate Medicare enrollment, and a different ownership group. Co-mingling its banking with the practice creates audit and partnership risk. Here is the structure to set up before opening day.
The economics of ophthalmology pull every growing group toward an ASC. Cataract volume justifies a dedicated facility. Surgeon time is more productive there. Facility fees on the ASC side are real money. So you start the conversation about a joint-venture ASC, or you buy into one, or you build your own. Then someone asks how the banking will work, and the conversation usually goes silent. Here is the checklist worth running before your ASC opens.
Why the Practice and the ASC Need Their Own Banking
The ASC and the practice are different businesses with different reimbursement models, different ownership groups, and different tax filings. Even when the same physicians own both, every regulator, auditor, and partner expects clean separation:
Practice (PC) bills professional fees through your usual payer mix.
ASC bills facility fees through a separate Medicare enrollment and separate commercial contracts.
Ownership of the ASC may include outside investors or a hospital partner, requiring distributions and waterfall logic.
CPOM and state ASC regulations require fund segregation in many jurisdictions.
A single co-mingled account for both is not just operationally messy. It creates risk in audits, tax filings, and partnership disputes.
The Right Banking Structure for an Ophthalmology Practice Plus ASC
The structure most multi-entity ophthalmology groups land on:
MSO root operating account, if you operate under an MSO-PC structure.
PC root operating account, separate per PC.
ASC root operating account, separate from the PC.
Virtual account: ASC facility fees by payer (Medicare, commercial, Medicare Advantage).
Virtual account: ASC supplies and IOL inventory.
Virtual account: PC professional fees, surgical.
Virtual account: PC professional fees, exam.
Virtual account: distributions reserve for ASC partners.
Virtual account: payroll reserves per entity.
Each entity has its own account, with virtual accounts beneath it that map to revenue and expense flows. The MSO holds shared services and management fees. Distributions flow through documented intercompany transfers with an audit trail.
Get the Payer Enrollments Started Months Early
ASC enrollments take longer than practice enrollments. Medicare ASC enrollment alone can run 60 to 120 days. Commercial ASC contracts vary by payer, but most take 6 to 12 weeks once submitted. Hospital JV contracts add their own paperwork.
Use the new ASC's account number from day one of the enrollment process. If you start with a temporary or shared account number, you will spend the first six months sorting out which deposits actually belong to the ASC.
Lemma onboards new entities in 5 minutes for the legal entity and 5 to 10 days for the full multi-entity structure. The banking is not the bottleneck. Payer enrollments are.
Decide How Money Moves Between the PC, the ASC, and the MSO
Daily and monthly money flows in a multi-entity ophthalmology group are real:
Daily sweeps from operating accounts to a yield-bearing reserve.
Monthly MSO management fee from each PC to the MSO, documented to support the management agreement.
Monthly distributions from the ASC to its owners (often physicians plus a hospital partner or capital partner).
Quarterly distributions from each PC to its owners.
Capital expenditure transfers (a femto laser, a new microscope, supply prepayments) timed against cash flow.
ACH transfers between accounts are $0 inside Lemma, so a tight monthly close does not introduce per-transaction fees. Wires are a flat $15 if a vendor or partner requires one. Operating cash earns 1.75% APY across the structure, with FDIC coverage up to $10M per entity through the IntraFi sweep network.
Lock Down Access by Role, Not by Person
An ASC opens up a wider stakeholder list: managing partner, ASC administrator, practice administrator, MSO CFO, and outside owners or capital partners. Set role-based access from the start:
ASC administrator: full ASC visibility and transfers up to a daily cap.
Practice administrator: full PC visibility and transfers up to a daily cap.
MSO CFO or finance lead: full visibility across MSO, PCs, and ASC.
Owners and capital partners: read-only visibility into the ASC entity.
PIN plus password, RFID badge, mobile MFA, and audit logging cover what most healthcare ASCs need without standing up a separate IAM project.
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