Healthcare Compensation Valuation
The healthcare regulatory landscape is complex, making it difficult to determine proper and compliant physician compensation for services. Laws and regulations are constantly evolving, causing greater scrutiny on financial arrangements.
LBMC’s Healthcare Compensation Valuation team combines an understanding of complex financial and regulatory matters with an ability to analyze voluminous financial operations information to deliver Fair Market Value (FMV) opinions to ensure maximum compliance. Each valuation analyzes the healthcare arrangement to determine Fair Market Value (FMV) compensation using the cost, income and market approaches, as applicable.
Healthcare Compensation Valuation Services include the following:
- Physician Employment and Independent Contractor Arrangements
- Physician On-Call Coverage Agreements
- Medical Directorship Agreements
- Management Service Agreements
- Joint Ventures and Leasing Arrangements
- Professional Services Arrangements
- Subsidy and/or Collection Guarantee Arrangements
- Physician Compensation Consulting/Planning
- Clinical Co-Management Arrangements
- Due Diligence
- Various Other Service Arrangements
Physician Employment Arrangements
Physician employment FMVs are approached by considering the unique facts and circumstances of the physician and the employer involved. LBMC considers the historical and projected production of the physician, published market surveys, and recruitment challenges, among other available and applicable information. The LBMC team leverages their expert knowledge to determine a compliant and defensible conclusion of FMV.
Independent Contractor Arrangement
Healthcare organizations utilize independent contractors when it is financially or operationally beneficial compared with employing a provider to perform the same services. Key considerations of these arrangements include the burden to the provider (e.g. time required, acuity of patients, malpractice risk, etc.), as well as whether the provider can bill and collect for services provided under the arrangement.
Physician On-Call Arrangements
On-call arrangements generally present themselves in two forms: restricted coverage and unrestricted coverage. The physician availability required by these arrangements can vary greatly. Restricted coverage requires the physician to be physically present at the facility during the coverage period. Hospital-based specialties are commonly arranged in this manner. Unrestricted coverage generally does not restrict the physician to the facility, but requires the physician to be within a reasonable distance from the facility so they can be onsite within a reasonable time, such as 30 minutes. LBMC considers the facts and circumstances of each arrangement to determine a unique level of burden based upon guidelines and commentary in applicable Office of Inspector General (OIG) Advisory Opinions.
Medical Director Arrangements
Arrangements for medical director services (and other administrative services) take into consideration activities which are not directly related to the provision of healthcare services to patients. Stark Phase III Regulations make a critical distinction between the clinical and administrative work provided by physicians and require FMV compensation be determined for administrative physician services. LBMC completes a thorough analysis of the services provided, as well as the expertise and qualifications of the physician required.
Management Service Agreements
Healthcare management services can be either professional or clinical services. Professional management is typically performed by non-physician business personnel and provided in combination with other services such as billing, equipment leasing, staff leasing, information systems, or electronic health records services. Clinical management is similar to medical directorship arrangements; however, it is provided by a group of physicians, as opposed to a single physician.
Joint Ventures and Leasing Arrangements
Joint Venture arrangements occur when two or more businesses agree to share profit, loss, and control in a specific enterprise. Leasing arrangements can occur when one hospital seeks to borrow equipment from another hospital. LBMC uses its resources and experience to value these rates and arrangements.
Professional Services Arrangements
Often hospitals contract directly with an independent physician or a physician group for various types of services. Under these arrangements, the physician group maintains its independent practice, for which the hospital is not financially or operationally responsible. This provides flexibility for the hospital and the physician group.
Subsidy and/or Collection Guarantee Arrangements
It is common for hospitals to make arrangements with physician groups in hospital-based specialties for coverage, particularly when the hospital experiences difficulty securing qualified staff for clinical areas. Hospitals often contract with independent healthcare providers for a combination of 24-hour onsite and on-call coverage. Due to low patient volumes and/or high indigent patient volumes, healthcare providers may be unable to collect sufficient professional fees. As a result, hospitals may subsidize the coverage or guarantee market based collections to secure consistent and adequate coverage.
Physician Compensation Consulting/ Planning
LBMC physician compensation consulting and planning begins by having discussions with providers about their vision, values and goals to help align compensation with the organizations objectives. LBMC completes a thorough review and assessment of current compensation models, recommends financially sustainable and compliant models and assists organizations in implementing compensation plans.
Clinical Co-Management Arrangements
Clinical Co-Management arrangements occur when facilities contract with a group of employed or independent physicians to manage the quality of a hospital’s service lines. These agreements are arranged to align the goals of the facility and the physician and often include an incentive for achieving quality outcome goals. LBMC analyzes the administrative duties, clinical duties and agreed upon goals to determine fair market value compensation for the services.
The LBMC compensation valuation team understands the strict regulatory requirements and substantial financial penalties healthcare companies face today. We perform due diligence by collecting and analyzing material facts with careful attention to risks or concerns.