Authors: Alyse Bentz, JD, MPH and Kevin Obletz, J.D., CVA Download the PDF A recent Advisory Opinion[1] (“AO”) offers clarification on the group practice definition for purposes of Section 1877(h)(4) of the Social Security Act and 42 CFR §411.352 (collectively, the...
Author: Fred M. Lara, CFA, ASA, CVA Download the PDF On April 29, 2021, the Office of Inspector General (the “OIG”) posted Advisory Opinion No. 21-02, which addressed a request from a health system and management company (the “Requestors”) for review of a proposed...
Authors: Kevin Obletz, JD and Alyse Bentz, JD, MPH Download the PDF INTRODUCTION Prior to the COVID-19 pandemic, many hospitals had begun to expand their outpatient service offerings, as a result of an increasing number of unoccupied inpatient beds.[1] Furthermore,...
Authors: Jeffrey A. Piehl, MAI; Jeffrey Doyle, ASA; Nicholas J. Janiga, ASA; and Luis A. Argueso Download the PDF As hospitals and health systems prepare for all possibilities during the novel coronavirus (“COVID-19”) pandemic, a key recurring issue is preparation for...
Authors: Fred Lara, CFA, ASA, CVA, Kristina Kheyfets and David W. Sands, CVA Download the PDF A recent ruling by the U.S. Court of Appeals for the Eleventh Circuit may put new focus on the importance of documenting fair market value (“FMV”) in transactions between...
Author: Jacob Jones, Senior Associate From a real estate standpoint, relatively little is needed in the way of space build-out for telemedicine providers to administer care besides four walls, a reception area, a secure internet connection, and enhanced A/V...
