HMS Valuation Partners present at the 2022 IPMI Healthcare Compliance Institute
THINK TANK SESSION ON COMPLEX FMV CONSIDERATIONS IN COMMON TRANSACTIONS: A CASE STUDY REVIEW
Health care providers regularly receive scrutiny from regulatory agencies under anti-kickback, fraud and abuse, and pricing regulations. In addition, the federal government continues to aggressively pursue Stark violations and health care fraud and abuse with billions annually in judgments and settlements won or negotiated in recent years. Ensuring Fair Market Value (FMV) support of these transactions is one critical component for health systems to navigate safe harbors and/or exceptions.
So, how might one value these financial arrangements?
While utilizing benchmark data for FMV support in isolation is useful for context, many of these common transactions have nuances that need to be considered and may not be entirely applicable to the rates reported on the surveys. Understanding the complexities around common transactions is increasingly important given the volume of financial arrangements transacted by hospitals and health systems.
This Think Tank Session will outline and explore complex FMV considerations to avoid potential compliance pitfalls in the following common transactions:
• Hospital-Based Transactions
• Physician Compensation
• Emergency Call Coverage
• Medical Office Timeshares