If you have two separate tax ID numbers, then you are two different practices, and you will require two different AC programs with licenss for each.
It would also seem like a logistical nightmare to have different practices in the same EMR not to mention HIPAA compliance. When I go to my doctor I expect her and those with a "need to know" in that office to know my health records. It would seem as though many patients would object to this setup even if they signed a release unless they are unaware of the situation.
I suppose if everyone covered for each other, then the confidentiality issue would be moot, but the licensing issue would still be a problem.
