Establishing Fair Market Value of Compensation Arrangements
Since 2000, we have provided thousands of FMV and commercial reasonableness opinions for a variety of healthcare compensation transactions. Our compensation valuation experts are certified in the valuation field and credentialed through numerous professional valuation associations, including the National Association of Certified Valuators and Analysts, and the American Society of Appraisers. Utilizing a variety of resources, including proprietary valuation methodologies that take into consideration relevant guidance provided by the OIG, CMS commentary, and case law, we carefully consider the particularities of each compensation arrangement and understand the nuanced Stark Law and Anti-Kickback concerns that may be implicated.
With our exclusive commitment to the healthcare industry, we provide objective, independent, and defensible FMV opinions that cover nearly every type of compensation arrangement, for clients in every state.
Telemedicine (or telehealth) represents a new treatment modality that is transforming the delivery of healthcare services. In recent years, due to technological advances, telemedicine has become a viable patient care option, allowing physicians of various specialties to provide high quality, affordable healthcare services to patients in remote areas.
With this ability to improve access to care, enhance the quality of value-based care and patient interaction, as well as offer substantial cost and time savings, many hospitals, health systems, physician practices, and outpatient facilities enter into telemedicine services arrangements as a means to secure affordable coverage or supplement existing coverage. As the number of telemedicine services arrangements continues to increase, so, too, does the need for reliable, defensible FMV opinions to ensure that the arrangements are in compliance with applicable state and federal laws.
As a relatively new healthcare delivery model, valuing telemedicine services arrangements presents distinct challenges. HealthCare Appraisers’ team of valuators possess the knowledge and experience to navigate these challenges, understanding not only the legal and regulatory issues surrounding telemedicine arrangements, but also the key service components associated with these arrangements, such as telemedicine equipment and software, telemedicine program start-up costs, and reimbursement considerations.
As hospitals and health systems continue to purchase independent practices and organically grow their workforce, the trend of hospital- and health system-employed physicians is becoming more prevalent. The resulting employment arrangements frequently implicate numerous healthcare fraud and abuse laws, including the Stark Law and Anti-Kickback Statute, and therefore benefit from review by a knowledgeable, unbiased valuation expert. Our team of compensation valuation professionals draw from hundreds of years of combined experience to produce FMV support for all types of employment arrangements. From FMV opinions for standard, single provider arrangements, to those for complex employment transactions involving multiple providers, varying payment mechanisms, and diverse service offerings, we can assist with any type of employment valuation need.
Upon recognizing the need for healthcare executives to operate more quickly than the valuation industry could allow, HealthCare Appraisers developed an easy-to-use, web-based FMV solution known as the Physician Employment Calculator™. This Calculator generates customized FMV opinions to aid in physician recruitment and retention and provide defensible support for a wide range of employment transactions.
Learn more about the Physician Employment Calculator™.
For more than 15 years, HealthCare Appraisers has utilized a proprietary methodology to value on-call arrangements, through which we consider a variety of factors that we believe have an impact on the burden to the provider performing the call coverage. In numerous Advisory Opinions since our proprietary methodology was developed and implemented, the Office of Inspector General (OIG) has cited to a similar set of factors, effectively confirming the validity and relevance of our proprietary methodology.
Our proprietary methodology has been refined over time, ensuring we continually produce objective and defensible FMV opinions for the hundreds of on-call coverage arrangements we value each year. For a customized call coverage application that utilizes our proprietary methodology and delivers almost immediate conclusions, we offer an easy-to-use, web-based solution referred to as the On-Call Calculator™.
Recognizing the need for alignment strategies that more effectively promote cooperation with medical staff physicians, hospitals and health systems have begun shifting their reimbursement strategies from volume to value. Similar to the trend in physician professional services arrangements, value-based administrative arrangements are designed to reward the achievement of specific quality metrics and operational efficiencies, as opposed to payment based on hours worked.
One emerging arrangement, centered on this value-based model, involves the management – either exclusively by physicians or jointly by physicians and hospital members – of an entire hospital service line. Unlike traditional medical director arrangements, these service line management arrangements can (i) facilitate working relationships with physicians across several disciplines (who may be unaffiliated with each other), and (ii) potentially offer more lucrative compensation, in the form of monies for achievement of specific outcomes, in addition to a base management fee.
Given the potential to implicate numerous healthcare laws and regulations, including the Stark Law, Anti-Kickback Statute, Civil Monetary Penalty Statute, and IRS private inurement, coupled with relatively lucrative payments, these arrangements require an intricate knowledge of the key regulatory issues and detailed understanding of the valuation process. HealthCare Appraisers’ team of experts possesses the knowledge and experience to meet these challenges, having valued over 2,000 service line management and co-management arrangements to date, including the arrangement mentioned in favorable OIG Advisory Opinion 12-22, the sole advisory opinion addressing service line co-management.
Your Compensation Valuation expertise is here.
Our compensation valuation experts are available to speak with you at your convenience. With an exclusive focus on healthcare valuation and transactions, we offer highly specialized and targeted insight into each engagement, and we utilize the latest valuation guidance and industry trends in performing our work.
Authors: Ciara A. Pocino, David Y. Lo, CFA, and Nicholas J. Janiga, ASA Download the PDF OVERVIEW Evolving healthcare regulations in the United States are incentivizing healthcare providers to deliver more cost-effective care while simultaneously commanding attention...
Authors: Matthew J. Muller, ASA and Nicholas J. Janiga, ASA Download the PDFThe urgent care sector has been a quickly growing segment of the healthcare industry over the last several years, and HealthCare Appraisers has observed growth in transactions in this highly...
Authors: Nicholas A. Newsad, MHSA Download the PDF OVERVIEW Chief Medical Officers (CMOs) play a critical role in the success of healthcare organizations, tasked with standards of care, quality improvement, and medical staff affairs. Accordingly, CMOs often rank...
Authors: Erica Jacobovits, JD and Kevin Obletz, JD Download the PDF In the aftermath of the determination by the Secretary of Health and Human Services, Alex M. Azar II (the “Secretary”), that COVID-19 represents a public health emergency, the Centers for Medicare...
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. Furthermore,...
Healthcare Appraisers is proud to serve as the Program Sponsor for the AHLA Fraud and Compliance Forum. This program brings together legal counsel, compliance officers, and government representatives for an invaluable learning and networking opportunity. This program...
HealthCare Appraisers will serve as a Platinum Sponsor for the 32nd Annual Health Law Forum. This forum will take place virtually via live webcast. Recognized as one of the premier health law programs in the country, this annual forum addresses key issues impacting...