Blogs

Beyond the Surveys

March 6, 2024

HMS Partners Joe Aguilar and Chip Hutzler recently took the stage to speak at a Think Tank Session, “Beyond the Surveys: Ensuring FMV Based on the Facts and Circumstances of Each Agreement” at the IMPI Healthcare Law and Compliance Institute in Orlando, Florida. This session provided a review of the 2020 CMS commentary on FMV and its impact on establishing Fair Market Value, including a list of non-survey factors parties should consider.  The discussion included an in-depth look at several relevant FMV example situations, in light of the CMS guidance on utilizing facts and circumstances to support compensation.

To view the presentation slides, click here: HMS IPMI Think Tank – Beyond Surveys

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Joe Aguilar

Partner—MBA, MPH, MSN, CVA

Chip Hutzler

Partner—JD, MBA, CVA

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