Q: Does FinCEN consider a hospital or doctors office to be engaged in the practice of medicine and therefore ineligible for exemption as a non-listed business? 15
A: FinCEN interprets the term "the practice of medicine" broadly, rather than focusing on the technicalities of individual state laws governing the licensing of medical practitioners. Accordingly, any entity that derives more than 50% of its gross revenues by offering medical services is ineligible for exemption as a non-listed business. This interpretation would likely exclude most privately-owned hospitals, doctors' offices, or other medical practices from being eligible for exemption as non-listed businesses.
This FAQ was obtained from FinCEN’s issuance FIN-2012-G003 – Guidance on Determining Eligibility for Exemption from Currency Transaction Reporting Requirements, which may be found here: