Tenet Healthcare Corporation (Tenet) operates as a diversified healthcare services company.
The company operates its nationwide care delivery network through direct and indirect subsidiaries, as well as downstream partnerships and joint ventures.
Segments
The company operates through two separate reporting segments: Hospital Operations and Services, and Ambulatory Care.
Hospital Operations and Services (‘Hospital Operations’): This segment includes acute care and specialty hospitals, a netwo...
Tenet Healthcare Corporation (Tenet) operates as a diversified healthcare services company.
The company operates its nationwide care delivery network through direct and indirect subsidiaries, as well as downstream partnerships and joint ventures.
Segments
The company operates through two separate reporting segments: Hospital Operations and Services, and Ambulatory Care.
Hospital Operations and Services (‘Hospital Operations’): This segment includes acute care and specialty hospitals, a network of employed physicians and ancillary outpatient facilities, including urgent care centers (each, a UCC), imaging centers, off-campus hospital emergency departments and micro-hospitals. In addition, the company’s Hospital Operations segment provides revenue cycle management and value-based care services to hospitals, health systems, physician practices, employers and other clients through its Conifer Health Solutions, LLC joint venture.
Ambulatory Care: This segment includes the operations through the company’s USPI Holding Company, Inc. subsidiary (USPI), held ownership interests in ambulatory surgery centers (each, an ASC), and surgical hospitals. USPI’s facilities offer a range of procedures and service lines, including among other specialties: orthopedics, total joint replacement, and spinal and other musculoskeletal procedures; gastroenterology; pain management; otolaryngology (ear, nose, and throat); ophthalmology; and urology.
Hospital Operations and Services segment
In 2024, the company continued to pursue advantageous opportunities to grow its portfolio of hospitals and other healthcare facilities. In July, the company opened the newly constructed, 92-bed Westover Hills Baptist Hospital in San Antonio, and in September, it acquired a majority ownership interest in a 36-bed rehabilitation hospital in El Paso. In addition, the company continued construction in 2024 on a new medical campus located in Port St. Lucie, which will include the 54-bed Florida Coast Surgical Hospital, as well as medical office space. The company expects to complete construction of the Port St. Lucie medical campus in late 2025.
As of December 31, 2024, the company’s subsidiaries operated acute care and specialty hospitals serving primarily urban and suburban communities in eight states. The company’s general hospitals offer acute care services, operating and recovery rooms, radiology services, respiratory therapy services, clinical laboratories and pharmacies; in addition, most have: intensive care, critical care and/or coronary care units; cardiovascular, digestive disease, neurosciences, musculoskeletal and obstetrics services; and outpatient services, including physical therapy. Many of its hospitals provide tertiary care services, such as cardiothoracic surgery, complex spinal surgery, neonatal intensive care and neurosurgery, and its Children’s Hospital of Michigan also offers pediatric quaternary care through its heart, kidney, and liver transplant programs. Moreover, a number of the company’s hospitals offer advanced treatment options for patients, including limb-salvaging vascular procedures, acute level 1 trauma services, comprehensive intravascular stroke care, minimally invasive cardiac valve replacement, cutting-edge imaging technology, surgical robotic capabilities and telemedicine access for select medical specialties.
All of the hospitals in the company’s Hospital Operations segment are licensed under appropriate state laws, and each is accredited by The Joint Commission or, in the case of The Hospitals of Providence Rehabilitation Hospital East, with the Center for Improvement in Healthcare Quality. With such accreditation, its hospitals are deemed to meet the Medicare Conditions of Participation and Conditions for Coverage, and they are eligible to participate in Medicare, Medicaid, and other government-sponsored provider programs.
The company’s Hospital Operations segment also included 135 outpatient centers as of December 31, 2024, primarily freestanding UCCs (nearly all of which are jointly owned with and managed by NextCare in Arizona), provider-based and freestanding imaging centers, off-campus hospital EDs and micro-hospitals. Approximately 72% of the outpatient centers in itsHospital Operations segment as of December 31, 2024, were in Arizona and Texas.
In addition to the hospitals and outpatient facilities discussed above, the company’s Hospital Operations segment includes physician practices and other associated healthcare businesses, as well as its Conifer JV’s revenue cycle management and value-based care service offerings. As of December 31, 2024, the company owned 76.2% of the Conifer JV, and CommonSpirit Health held a 23.8% ownership position.
The revenue cycle management solutions the company offers consist of: patient services, including: centralized insurance and benefit verification; financial clearance, pre certification, registration and check in services; and financial counseling services, including reviews of eligibility for government healthcare or financial assistance programs, for both insured and uninsured patients, as well as qualified health plan coverage; clinical revenue integrity solutions, including: clinical admission reviews; coding; clinical documentation improvement; coding compliance audits; charge description master management; and health information services; and accounts receivable management solutions, including: third party billing and collections; denials management; and patient collections. All of these solutions include ongoing measurement and monitoring of key revenue cycle metrics, as well as productivity and quality improvement programs. In addition, the company provides customized communications and engagement solutions to optimize the relationship between providers and patients. It also offers value based care services, including clinical integration, financial risk management and population health management, all of which aim to assist clients in improving the cost and quality of their healthcare delivery, as well as their patient outcomes.
As of December 31, 2024, the company provided one or more of the business process services described above to approximately 620 Tenet and non-Tenet hospitals and other clients nationwide. Tenet and CommonSpirit Health facilities represented approximately 43% of these clients, and the remainder were unaffiliated health systems, hospitals, physician practices, self-insured organizations, health plans, and other entities.
Ambulatory Care segment
As of December 31, 2024, USPI held indirect ownership interests in 518 ASCs and 25 surgical hospitals in 37 states.
USPI’s facilities offer a range of procedures and service lines, including among other specialties: orthopedics, total joint replacement, and spinal and other musculoskeletal procedures; gastroenterology; pain management; otolaryngology (ear, nose, and throat); ophthalmology; and urology. It focuses on opportunities to expand its Ambulatory Care segment through acquisitions, organic growth in physician relationships and service lines, construction of new outpatient centers and strategic partnerships.
Operations of USPI—USPI acquires and develops its facilities primarily through the formation of joint ventures with physicians and/or health system partners. USPI’s subsidiaries hold ownership interests in the facilities directly or indirectly, and it operates the facilities on a day-to-day basis through management services contracts. The company structures its joint ventures and adopt staffing, scheduling, and clinical systems and protocols with the goals of increasing physician productivity and satisfaction.
Real Property
The company leases the majority of its outpatient facilities in both its Hospital Operations segment and its Ambulatory Care segment, and its physician practices also lease space in medical office buildings. These leases typically have initial terms ranging from five to 10 years, and most of the leases contain options to extend the lease periods. In addition, the company’s subsidiaries own some medical office buildings located on, or nearby, its hospital campuses.
Healthcare Regulation and Licensing
The Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act of 2010 (the Affordable Care Act), extended health coverage to millions of uninsured legal U.S. residents through a combination of private sector health insurance reforms and public program expansion.
The expansion of health insurance coverage under the Affordable Care Act resulted in an increase in the number of patients using the company’s facilities with either private or public program coverage and a decrease in uninsured and charity care admissions, along with reductions in Medicare and Medicaid reimbursement to healthcare providers, including the company.
A number of federal statutes, and the regulations implementing them, govern the company’s participation in the Medicare and Medicaid payment programs, including:
The anti-kickback and antifraud and abuse amendments codified under Section 1128B(b) of the Social Security Act (the Anti-kickback Statute), which prohibit the knowing and willful remuneration of anything of value intended to induce or reward patient referrals or the generation of business involving any item or service payable by federal healthcare programs, subject to certain government-established safe harbor exceptions;
The False Claims Act (FCA), which prohibits the submission of claims for payment to government programs that are known to be, or should be known to be, fraudulent;
The Stark law, which generally restricts physician referrals of Medicare or Medicaid patients to entities the physician or an immediate family member has a financial relationship with, regardless of any intent to violate the law, unless one of several exceptions applies; and
The Civil Monetary Penalties Law, which authorizes the Secretary of the U.S. Department of Health and Human Services (HHS) to impose civil penalties for various forms of fraud and abuse involving the Medicare and Medicaid programs.
The company regularly enters into financial arrangements with physicians and other providers in a manner complies with the Anti-kickback Statute, the Stark law, and other applicable antifraud and abuse laws.
The company has developed an expansive set of policies and procedures in its efforts to comply with HIPAA, and similar state privacy laws, under the guidance of its ethics and compliance department. The company’s compliance officers and information security officers are responsible for implementing and monitoring enterprise-wide compliance with its HIPAA privacy and security policies and procedures. It has also created an internal web-based HIPAA training program, which is mandatory for all employees.
Under HIPAA, the company is required to report breaches of unsecured PHI to affected individuals without unreasonable delay, but not longer than 60 days following discovery of the breach. It is also required to notify HHS, and in certain situations involving large breaches, the media. The company is also subject to any federal or state privacy-related laws that are more restrictive than the privacy regulations issued under HIPAA.
Laws and Regulations Affecting Revenue Cycle Management Services
The federal Fair Debt Collection Practices Act (FDCPA) regulates persons who regularly collect or attempt to collect, directly or indirectly, consumer debts owed or asserted to be owed to another person. Certain of the accounts receivable handled by Conifer’s third-party debt collection vendors are subject to the FDCPA, which establishes specific guidelines and procedures that debt collectors must follow in communicating with consumer debtors, including the time, place, and manner of such communications.
Conifer is also subject to laws under which both federal and state regulatory agencies have the authority to investigate consumer complaints relating to unfair, deceptive and abusive acts and practices, as well as a variety of consumer protection laws, including but not limited to the Telephone Consumer Protection Act and all applicable state equivalents.
Laws, Regulations and Other Matters Affecting GBC
The company’s GBC operations in the Philippines are subject to certain U.S. healthcare industry-specific requirements, as well as the U.S. and foreign laws applicable to businesses generally, including anti-corruption laws. One such law, the Foreign Corrupt Practices Act (FCPA), regulates the U.S. companies in their dealings with foreign officials, prohibiting bribes and similar practices, and requires that they maintain records that fairly and accurately reflect transactions and appropriate internal accounting controls. FCPA enforcement actions continue to be a high priority for the SEC and the U.S. Department of Justice.
History
Tenet Healthcare Corporation was founded in 1967. The company was incorporated in the state of Nevada in 1975.