PYA Principal Tynan Olechny and Senior Manager Annapoorani Bhat provided important information for rural providers related to fair market value and commercial reasonableness considerations during a National Rural Health Association webinar, “Valuations: What Rural Providers Need to Know."
Accounting Update Overview with a Healthcare SlantPYA, P.C.
PYA Principal and Director of Audit Services Doug Arnold presented during East Tennessee State University’s 38th Annual Accounting, Auditing, and Tax Updating CPE conference. His presentation covered many recent Accounting Standards Updates, but leaned toward their applications in healthcare.
Healthcare Valuations in an Era of Reform and UncertaintyPYA, P.C.
PYA Principal Jim Lloyd's AICPA Health Care Industry Conference presentation explored reform and current environment highlights, healthcare transactions and affiliations, valuation considerations, and regulatory issues.
PYA Presents Intro to Healthcare Valuation PYA, P.C.
PYA Principal Jim Lloyd, along with other presenters, provided a “Healthcare Valuation 101” during a pre-conference workshop at the 2013 AICPA Healthcare Industry Conference.
As healthcare is a language “all its own,” PYA Principal David McMillan presented “Learning the New Language of Healthcare" at the Georgia Society of CPAs' 2014 Healthcare Conference.
Presentation Covers Physician Practice CompliancePYA, P.C.
PYA Consulting Manager Valerie Rock presented “Compliance in the Physician Practice.” She discussed the importance of having a compliance plan, coding and billing monitoring, audit schedules, and provider expectations.
How to Have a Successful Engagement and a Happily Ever After: “New Age” Nuanc...PYA, P.C.
PYA’s Tynan Olechny and Valerie Rock presented “How to Have a Successful Engagement and a Happily Ever After: ‘New Age’ Nuances to Physician Hospital Arrangements” with R. Ross Burris III of Polsinelli at the Health Care Compliance Association’s (HCCA) Regional Annual Conference.
Forensic and Valuation Issues in HealthcarePYA, P.C.
PYA Principal Carol Carden co-presented “Forensic and Valuation Issues in Healthcare” at the AICPA Forensic & Valuation Services Conference in New Orleans, LA, November 10, 2014.
Don’t Stumble Coming Out of the Gate –Top Ten Issues to Address When Acquirin...PYA, P.C.
PYA Consulting Principal Carol Carden co-presented with Charlene McGinty of McKenna Long. They examined the top issues to address when acquiring a physician practice and some of the common and more complex issues hospitals face during the acquisition.
Accounting Update Overview with a Healthcare SlantPYA, P.C.
PYA Principal and Director of Audit Services Doug Arnold presented during East Tennessee State University’s 38th Annual Accounting, Auditing, and Tax Updating CPE conference. His presentation covered many recent Accounting Standards Updates, but leaned toward their applications in healthcare.
Healthcare Valuations in an Era of Reform and UncertaintyPYA, P.C.
PYA Principal Jim Lloyd's AICPA Health Care Industry Conference presentation explored reform and current environment highlights, healthcare transactions and affiliations, valuation considerations, and regulatory issues.
PYA Presents Intro to Healthcare Valuation PYA, P.C.
PYA Principal Jim Lloyd, along with other presenters, provided a “Healthcare Valuation 101” during a pre-conference workshop at the 2013 AICPA Healthcare Industry Conference.
As healthcare is a language “all its own,” PYA Principal David McMillan presented “Learning the New Language of Healthcare" at the Georgia Society of CPAs' 2014 Healthcare Conference.
Presentation Covers Physician Practice CompliancePYA, P.C.
PYA Consulting Manager Valerie Rock presented “Compliance in the Physician Practice.” She discussed the importance of having a compliance plan, coding and billing monitoring, audit schedules, and provider expectations.
How to Have a Successful Engagement and a Happily Ever After: “New Age” Nuanc...PYA, P.C.
PYA’s Tynan Olechny and Valerie Rock presented “How to Have a Successful Engagement and a Happily Ever After: ‘New Age’ Nuances to Physician Hospital Arrangements” with R. Ross Burris III of Polsinelli at the Health Care Compliance Association’s (HCCA) Regional Annual Conference.
Forensic and Valuation Issues in HealthcarePYA, P.C.
PYA Principal Carol Carden co-presented “Forensic and Valuation Issues in Healthcare” at the AICPA Forensic & Valuation Services Conference in New Orleans, LA, November 10, 2014.
Don’t Stumble Coming Out of the Gate –Top Ten Issues to Address When Acquirin...PYA, P.C.
PYA Consulting Principal Carol Carden co-presented with Charlene McGinty of McKenna Long. They examined the top issues to address when acquiring a physician practice and some of the common and more complex issues hospitals face during the acquisition.
The Heartaches Associated with Billing for Cardiac DevicesPYA, P.C.
PYA Principal Denise Hall-Gaulin and Consulting Manager Joanna Malcolm presented a free webinar for the Georgia chapter of the Healthcare Financial Management Association, on Tuesday, December 6, 2016.
The presentation was geared toward C-suite hospital leaders, compliance officers, in-house counsel, operational leaders, and patient accounting leadership, and covered:
The criteria for implantable cardioverter defibrillators (ICDs), pacemakers, and other devices
The documentation requirements for payment
The prerequisites for a clean audit
PYA Principal Jim Lloyd was among the faculty who spoke at the 2013 Mid-South Commercial Law Institute during a panel discussion on “Healthcare Facilities in Bankruptcy.” The presentation provided an overview of healthcare facilities and key issues, healthcare regulatory environment, valuation of healthcare facilities, and red flags for healthcare businesses in bankruptcy or distress.
PYA Principal Carol Carden recently spoke on the topic “Valuation Issues in Healthcare” at the Tennessee Society of Certified Public Accountants’ Healthcare Conference.
Affiliation Strategies for At-Risk Community HospitalsPYA, P.C.
PYA Senior Healthcare Consulting Manager Michael Ramey presented “Affiliation Strategies for At-Risk Community Hospitals” with Jay Hardcastle, partner at Bradley Arant Boult Cummings at the AHLA Health Care Transactions Program. The presentation helped:
1. Identify factors affecting the continued financial viability of community hospitals.
2. Introduce the importance of board/management being proactive in evaluating potential affiliation alternatives before reaching a dire state.
3. Discuss the request-for-proposal process.
4. Explore legal structures to retain the best value for the community via appropriate models (i.e., management agreement, lease, acquisition, joint operating agreement, joint venture, affiliation).
5. Provide lessons learned from recent hospital transactions.
PYA Presentation: “Thorny Issues in FMV and Commercial Reasonableness"PYA, P.C.
PYA Principals Jim Lloyd and Lyle Oelrich presented "Thorny Issues in Fair Market Value and Commercial Reasonableness" at the Greater Kansas City Society of Healthcare Attorneys, Wednesday, April 16, 2014.
PYA Healthcare Consulting Senior Manager Robert Mundy co-presented during, “Valuing Hospitals,” Thursday, July 31, at 1 p.m. EST. This webinar explores the changing world of hospital economics, regulations, and valuations and how appraisers can best prepare themselves for both the opportunities and challenges that lie ahead.
Big Data: Implications of Data Mining for Employed Physician Compliance Manag...PYA, P.C.
PYA Principal Denise Hall presented “Big Data: Implications of Data Mining for Employed Physician Compliance Management” at Becker’s Annual CEO & CIO Strategy Roundtables, November 18-19, 2015.
The presentation explored:
Data being aggregated by the government, as well as new approaches by regulators.
Public relations and litigation risk from the public dissemination of data by the government.
Big data connections to payment through quality metrics and the potential for new theories of False Claims Act (FCA) suits.
Internal use of broad spectrum analytics in employed physician compliance management.
Determination of risk tolerance and the customization of “outside the box” analytics.
Benchmarking, monitoring, and defining physician-focused risk area reviews.
ICD-10 Is Really Here: What Does That Mean To Compliance Officers?PYA, P.C.
PYA Principal Denise Hall presented “ICD-10 Is REALLY Here: What Does that Mean to Compliance Officers?” at the THA 2015 Fall Compliance Conference. The presentation helps providers get “in tune” with the latest in ICD-10 compliance:
* A brief discussion of ICD-10 and its impact on healthcare.
* Compliance risks with the transition to the ICD-10 system.
* Mitigation of compliance risk and denial activities during and post-implementation.
* ICD-10’s impact on value-based purchasing and quality-based payment models.
Guarding Your Client's Valuation from Attack--Dos and Don'ts for Requesting, ...PYA, P.C.
During an AHLA webinar series roundtable discussion, “Guarding Your Client’s Valuation from Attack—Dos and Don’ts for Requesting, Reviewing, Using, and Discarding FMV Opinions,” PYA Principal Carol Carden joined other legal experts to explore the practical issues for counsel to consider when balancing the arguments for scrutinizing valuation reports with the arguments for ensuring valuator independence.
Presentation Explores Many Contexts of Community BenefitPYA, P.C.
PYA Principal David McMillan gets to the bottom of the definition of community benefit in “Community Benefit: One Term, Many Contexts,” a presentation given at the 2013 AICPA Healthcare Industry Conference.
PYA Principal Carol Carden presented on current issues in healthcare valuation at The Texas Society of Certified Public Accountants Business Valuation, Forensic, and Litigation Services Conference at the Hilton Fort Worth, October 14, 2014.
Exclusive Contracting and Incentivizing Quality in Your Hospitalist ProgramPYA, P.C.
PYA Principal Carol Carden co-presented a session along with Mark Easterly, Vice President of Legal Services for Houston Methodist, on “Exclusive Contracting and Incentivizing Quality in Your Hospitalist Program" at the AHLA Physicians and Hospitals Law Institute.
The Top Ten Issues in Physician Practice Acquisition and ValuationPYA, P.C.
A webinar hosted by The National Association of Certified Valuators and Analysts (NACVA) and presented by PYA Consulting Principal Darcy Devine outlines ten common, but often complex, issues that arise during the physician practice acquisition process. The webinar took place Friday, February 13, 2015. “Don’t Stumble Coming Out of the Gate—The Top Ten Issues in Physician Practice Acquisition and Valuation” is geared toward health system and physician practice financial executives as well as business valuators working with those entities.
Presentation Offers Valuation Strategies for Tax-Effective Practice TransactionsPYA, P.C.
PYA Principal Jim Lloyd co-presented a session at the 2013 AICPA Healthcare Industry Conference in New Orleans on “Valuation Strategies for More Tax-Effective Physician/Dentist Practice Transactions.”
PYA Senior Consultant Kathryn Culver presented "Fundamentals of Healthcare Valuation" before the Tennessee Society of Certified Public Accountants (TSCPA). The presentation:
Provided a healthcare valuation overview.
Discussed healthcare valuation approaches.
Covered healthcare valuation considerations and trends.
Chronic Care Management in Post-Acute/LTC SettingPYA, P.C.
PYA Principal Denise Hall and PYA Manager Lori Baker presented an educational session, “Chronic Care Management in Post-Acute/LTC Setting” to members of The Vision Group during The Society for Post-Acute and Long-Term Care Medicine’s (AMDA) Annual Conference.
Commercial Reasonableness in Hospital-Physician TransactionsPYA, P.C.
PYA Principals Lyle Oelrich and Darcy Devine presented “Commercial Reasonableness in Hospital-Physician Transactions” to the Health Care Fraud Working Group in Memphis, TN, April 10, 2013.
The Heartaches Associated with Billing for Cardiac DevicesPYA, P.C.
PYA Principal Denise Hall-Gaulin and Consulting Manager Joanna Malcolm presented a free webinar for the Georgia chapter of the Healthcare Financial Management Association, on Tuesday, December 6, 2016.
The presentation was geared toward C-suite hospital leaders, compliance officers, in-house counsel, operational leaders, and patient accounting leadership, and covered:
The criteria for implantable cardioverter defibrillators (ICDs), pacemakers, and other devices
The documentation requirements for payment
The prerequisites for a clean audit
PYA Principal Jim Lloyd was among the faculty who spoke at the 2013 Mid-South Commercial Law Institute during a panel discussion on “Healthcare Facilities in Bankruptcy.” The presentation provided an overview of healthcare facilities and key issues, healthcare regulatory environment, valuation of healthcare facilities, and red flags for healthcare businesses in bankruptcy or distress.
PYA Principal Carol Carden recently spoke on the topic “Valuation Issues in Healthcare” at the Tennessee Society of Certified Public Accountants’ Healthcare Conference.
Affiliation Strategies for At-Risk Community HospitalsPYA, P.C.
PYA Senior Healthcare Consulting Manager Michael Ramey presented “Affiliation Strategies for At-Risk Community Hospitals” with Jay Hardcastle, partner at Bradley Arant Boult Cummings at the AHLA Health Care Transactions Program. The presentation helped:
1. Identify factors affecting the continued financial viability of community hospitals.
2. Introduce the importance of board/management being proactive in evaluating potential affiliation alternatives before reaching a dire state.
3. Discuss the request-for-proposal process.
4. Explore legal structures to retain the best value for the community via appropriate models (i.e., management agreement, lease, acquisition, joint operating agreement, joint venture, affiliation).
5. Provide lessons learned from recent hospital transactions.
PYA Presentation: “Thorny Issues in FMV and Commercial Reasonableness"PYA, P.C.
PYA Principals Jim Lloyd and Lyle Oelrich presented "Thorny Issues in Fair Market Value and Commercial Reasonableness" at the Greater Kansas City Society of Healthcare Attorneys, Wednesday, April 16, 2014.
PYA Healthcare Consulting Senior Manager Robert Mundy co-presented during, “Valuing Hospitals,” Thursday, July 31, at 1 p.m. EST. This webinar explores the changing world of hospital economics, regulations, and valuations and how appraisers can best prepare themselves for both the opportunities and challenges that lie ahead.
Big Data: Implications of Data Mining for Employed Physician Compliance Manag...PYA, P.C.
PYA Principal Denise Hall presented “Big Data: Implications of Data Mining for Employed Physician Compliance Management” at Becker’s Annual CEO & CIO Strategy Roundtables, November 18-19, 2015.
The presentation explored:
Data being aggregated by the government, as well as new approaches by regulators.
Public relations and litigation risk from the public dissemination of data by the government.
Big data connections to payment through quality metrics and the potential for new theories of False Claims Act (FCA) suits.
Internal use of broad spectrum analytics in employed physician compliance management.
Determination of risk tolerance and the customization of “outside the box” analytics.
Benchmarking, monitoring, and defining physician-focused risk area reviews.
ICD-10 Is Really Here: What Does That Mean To Compliance Officers?PYA, P.C.
PYA Principal Denise Hall presented “ICD-10 Is REALLY Here: What Does that Mean to Compliance Officers?” at the THA 2015 Fall Compliance Conference. The presentation helps providers get “in tune” with the latest in ICD-10 compliance:
* A brief discussion of ICD-10 and its impact on healthcare.
* Compliance risks with the transition to the ICD-10 system.
* Mitigation of compliance risk and denial activities during and post-implementation.
* ICD-10’s impact on value-based purchasing and quality-based payment models.
Guarding Your Client's Valuation from Attack--Dos and Don'ts for Requesting, ...PYA, P.C.
During an AHLA webinar series roundtable discussion, “Guarding Your Client’s Valuation from Attack—Dos and Don’ts for Requesting, Reviewing, Using, and Discarding FMV Opinions,” PYA Principal Carol Carden joined other legal experts to explore the practical issues for counsel to consider when balancing the arguments for scrutinizing valuation reports with the arguments for ensuring valuator independence.
Presentation Explores Many Contexts of Community BenefitPYA, P.C.
PYA Principal David McMillan gets to the bottom of the definition of community benefit in “Community Benefit: One Term, Many Contexts,” a presentation given at the 2013 AICPA Healthcare Industry Conference.
PYA Principal Carol Carden presented on current issues in healthcare valuation at The Texas Society of Certified Public Accountants Business Valuation, Forensic, and Litigation Services Conference at the Hilton Fort Worth, October 14, 2014.
Exclusive Contracting and Incentivizing Quality in Your Hospitalist ProgramPYA, P.C.
PYA Principal Carol Carden co-presented a session along with Mark Easterly, Vice President of Legal Services for Houston Methodist, on “Exclusive Contracting and Incentivizing Quality in Your Hospitalist Program" at the AHLA Physicians and Hospitals Law Institute.
The Top Ten Issues in Physician Practice Acquisition and ValuationPYA, P.C.
A webinar hosted by The National Association of Certified Valuators and Analysts (NACVA) and presented by PYA Consulting Principal Darcy Devine outlines ten common, but often complex, issues that arise during the physician practice acquisition process. The webinar took place Friday, February 13, 2015. “Don’t Stumble Coming Out of the Gate—The Top Ten Issues in Physician Practice Acquisition and Valuation” is geared toward health system and physician practice financial executives as well as business valuators working with those entities.
Presentation Offers Valuation Strategies for Tax-Effective Practice TransactionsPYA, P.C.
PYA Principal Jim Lloyd co-presented a session at the 2013 AICPA Healthcare Industry Conference in New Orleans on “Valuation Strategies for More Tax-Effective Physician/Dentist Practice Transactions.”
PYA Senior Consultant Kathryn Culver presented "Fundamentals of Healthcare Valuation" before the Tennessee Society of Certified Public Accountants (TSCPA). The presentation:
Provided a healthcare valuation overview.
Discussed healthcare valuation approaches.
Covered healthcare valuation considerations and trends.
Chronic Care Management in Post-Acute/LTC SettingPYA, P.C.
PYA Principal Denise Hall and PYA Manager Lori Baker presented an educational session, “Chronic Care Management in Post-Acute/LTC Setting” to members of The Vision Group during The Society for Post-Acute and Long-Term Care Medicine’s (AMDA) Annual Conference.
Commercial Reasonableness in Hospital-Physician TransactionsPYA, P.C.
PYA Principals Lyle Oelrich and Darcy Devine presented “Commercial Reasonableness in Hospital-Physician Transactions” to the Health Care Fraud Working Group in Memphis, TN, April 10, 2013.
Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...MD Ranger, Inc.
Have you structured your hospital-based physician contracts to address all aspects of compliance?
Hospitalist agreements involve unique compliance and financial issues, particularly when global payments and advanced practice providers are involved. Risks include indirect compensation, billing and other compliance issues. This presentation will discuss compliance risks and provide guidance on how to structure compliant contracts and business arrangements.
Online Conference Takes “Deep Dive” into Affordable Care ActPYA, P.C.
PYA’s Martie Ross, Principal, joined three other panelists in a full-day, online conference sponsored by the American Institute of Certified Public Accountants to offer an in-depth look at healthcare reform under the Affordable Care Act (ACA).
How to improve operating margins
● What does operating margin tell you about the organization, and how would
you calculate this ratio?
● Select a local medical service organization and describe how it has
specifically improved its operating margins.
HFMA
Financial Reporting Function
Financial Reporting Function
Financial Accounting Standards Board
(FASB)
FASB standards rest on certain
assumptions:
Ø Monetary unit
Ø Economic entity
Ø Time period
Ø Going concern
Financial Reporting Function
FASB
Two key principles
Ø Cost principle
Ø Full disclosure principle
Financial Reporting Function
Generally Accepted Accounting Principles
(GAAP)
Ø Consistency
Ø Relevance
Ø Reliability
Ø Comparability
Financial Reporting Function
Financial Statements
For Profit Not-for-Profit
Balance Sheet Statement of Financial
Position
Income Statement Statement of Operations
Statement of Cash Flows Statement of Cash Flows
Financial Reporting Function
Accepted Accounting Methods
Ø Accrual
Ø Cash
Ø Fund
Financial Reporting Function
Financial Statement Presentation
Ø Two years are displayed
- Prior year to the right of the current year
Ø Statement of Operations or Income Statement are for a period of
time—typically a month
Ø Statement of Cash Flows reflects a period of time consistent with the
Statement of Operations or Income Statement—typically a month
Ø Statement of Financial Position or Balance Sheet reflect the status
of Assets, Liabilities, and Net Assets/Shareholders’ Equity as of a
day.
Financial Reporting Function
Ratio Analysis
Ø Liquidity Ratios
Ø Profitability Ratios
Ø Asset Efficiency Ratios
Ø Capital Structure Ratios
Ø Operating Indicators
Financial Reporting Function
Ratio Analysis
Ø Liquidity
- Current ratio
- Quick ratio
Current ratio = Current Assets/Current Liabilities
Quick ratio = (Cash + Marketable Securities + Net
Accounts Receivable)/Current Liabilities
Financial Reporting Function
Ratio Analysis
Ø Profitability
- Operating margin
- Return on assets
Operating Margin = [(Operating Revenue-Operating
Expenses)/Total Operating Revenues] x 100
Return on Assets = Excess of revenues over expenses/
Total Assets
Financial Reporting Function
Ratio Analysis
Ø Asset efficiency
- Total asset turnover
- Inventory turnover
Total Asset Turnover = Total Operating Revenue/ Total
Assets
Inventory Turnover = Total Operating Revenue/ Inventory
Financial Reporting Function
Ratio Analysis
Ø Capital structure
- Debt to Capitalization
- Debt service coverage
Debt to Capitalization = [Long-term Debt/ (Long-term Debt
+ Unrestricted Net Assets)] x 100
Debt Service Coverage = (Excess of revenues over
expenses + Depre.
“CARES Act Provider Relief Fund: Opportunities, Compliance, and Reporting”PYA, P.C.
PYA Principal Martie Ross spoke at the virtual North Carolina Healthcare Association Critical Access Hospital Statewide Meeting. The two-day event, “Quality Focus is a Finance Focus,” provided critical access hospital leaders with the opportunity to network and review data-informed strategies as well as updates to the Medicare Flexibility Program Project. It also provided guidance on federal compliance and tracking of Provider Relief Funds.
In “CARES Act Provider Relief Fund: Opportunities, Compliance, and Reporting,” Martie gave an overview of the history of distribution of those funds as well as regulations and guidelines including:
Statutory Language
Reporting Requirements
Use of Funds Calculation
Expenses
Risk Management
Martie presented Thursday, March 4, 2021.
If you would like guidance related to Provider Relief Fund regulations, or for assistance with any matter related to strategy and integration, compliance, or valuation, contact one of our PYA executives at (800) 270-9629.
PYA Presented on 2021 E/M Changes and a CARES Act Update During GHA Complianc...PYA, P.C.
The Georgia Hospital Association (GHA) Compliance Officers Roundtable, an active GHA group that meets quarterly and includes educational sessions featuring government representatives, industry experts, and other thought leaders speaking about compliance-related issues, conducted their latest meeting virtually. PYA Principals Lori Foley, Tynan Kugler, and Valerie Rock were among the presenters at this quarter’s event. In their session, they:
Described key elements associated with 2021 E/M changes, and strategies for preparation and implementation.
Explained the impact of 2021 E/M changes on physician compensation and contracting, including potential mitigation approaches.
Presented key components of Stark Law and Anti-Kickback Statute final rules.
Provided an update on the CARES Act.
The Compliance Certification Board offered CEUs for this event, which took place on Friday, December 4, 2020.
Webinar: “Trick or Treat? October 22nd Revisions to Provider Relief Fund Repo...PYA, P.C.
On October 22nd, the Department of Health and Human Services released revised Provider Relief Fund (PRF) reporting requirements. Under HHS’ September 19 directive, “lost revenue” was defined narrowly as a negative change in year-over-year patient care operating net income. Now, HHS will permit providers to use PRF funds to cover the difference between their 2019 and 2020 actual patient care revenue with some adjustments for COVID-related expenses. The October 22nd notice is available here.
PYA Principals Martie Ross and Michael Ramey hosted a complimentary 30-minute webinar, “Trick or Treat? October 22nd Revisions to Provider Relief Fund Reporting Requirements” on Thursday, October 29th.
“Regulatory Compliance Enforcement Update: Getting Results from the Guidance” PYA, P.C.
PYA Principal and Chief Compliance Officer Shannon Sumner and Consulting Senior Manager Susan Thomas presented “Regulatory Compliance Enforcement Update: Getting Results from the Guidance” at the virtual 2020 Montana Healthcare Conference. They reviewed the sources of regulatory enforcement and investigation information—guidelines, statutory updates, best practices, settlements, case studies, etc.—available to healthcare organizations. They will also discuss how to interpret and implement the guidance in order to strengthen the compliance function and protect the organization. The presentation covered:
Compliance regulatory requirements for healthcare organizations.
Guidance available for consideration in organizational compliance programs.
Internal and external reporting to ensure regulatory requirements are met.
Best practices for implementation of guidance.
Case studies for illustration of guidance implementation.
“Federal Legislative and Regulatory Update,” Webinar at DFWHCPYA, P.C.
The Dallas Fort Worth Hospital Council (DFWHC) and PYA co-hosted an exclusive complimentary webinar, “Federal Legislative and Regulatory Update,” on Wednesday, September 23.
DFWHC President/CEO Stephen Love hosted a discussion with PYA Senior Manager Kathy Reep about concerns that have dropped from the radar during the last four months of COVID-19, addressing issues for which hospitals must prepare in approaching 2021. This session focused on these key areas:
Appropriate use criteria
Transparency
Site neutral payments
The future of the Medicare Trust Fund
The federal budget
Key provisions of the final rule for the inpatient prospective payment system for FY2021 and the proposed outpatient rule for CY2021
On-Demand Webinar: Compliance With New Provider Relief Funds Reporting Requir...PYA, P.C.
On September 19, the Department of Health and Human Services (HHS) published its Post-Payment Notice of Reporting Requirements. The Notice details the reporting requirements for all Provider Relief Fund (PRF) recipients that have received $10,000 or more in aggregate payments.
Under the PRF Terms and Conditions, a recipient may use the funds only for healthcare-related expenses and lost revenue attributable to coronavirus. The Notice provides the clearest direction to date regarding permissible uses of PRF funds.
PYA offered a 45-minute complimentary webinar that explained the new reporting requirements and delved into permissible uses. While many questions remain, we provided practical advice on the next steps in the reporting process.
The webinar took place Monday, October 5 at 11 a.m. EDT.
Webinar: “While You Were Sleeping…Proposed Rule Positioned to Significantly I...PYA, P.C.
You likely know from the headlines that the 2021 Medicare Physician Fee Schedule (MPFS) Proposed Rule slashes payments for surgical specialists. But the impact of the Proposed Rule is far broader, reflecting a fundamental realignment driven by the transition to value-based payments. In our webinar, “While You Were Sleeping…Proposed Rule Positioned to Significantly Impact Physician Compensation,” PYA experts addressed these proposals, helping you understand and prepare for the changes ahead.
Following this presentation, attendees were able to:
Understand how a handful of wRVU changes would alter Medicare reimbursement for nearly all physicians.
Appreciate the operational impact of these changes.
Recognize the challenges to existing physician compensation models.
Identify strategies and tactics to prepare for and manage these impacts.
Presenters include PYA Principals Angie Caldwell, Martie Ross, and Valerie Rock. The webinar took place Thursday, September 10 and was hosted in conjunction with the Florida Hospital Association.
If you have additional questions about the MPFS Proposed Rule and its impact on physician compensation or need assistance with any matter involving physician compensation, valuation, strategy and integration, or compliance, contact a PYA executive below at (800) 270-9629.
Webinar: “Cybersecurity During COVID-19: A Look Behind the ScenesPYA, P.C.
Cybersecurity breaches have been in the news almost daily for some time now. COVID-19 has amplified the problem, as “bad actors” seize upon the opportunity to take advantage of hospitals at their most vulnerable time. Given this climate and an aging HIPAA rule, it is difficult to anticipate and prepare for the future.
PYA Principal Barry Mathis presented “Cybersecurity During COVID-19: A Look Behind the Scenes,” on Wednesday, August 12, 2020. This one-hour, complimentary webinar was hosted by PYA in conjunction with the Montana Hospital Association as Part 2 of the Frontier States Town Hall Meeting.
Barry covered information related to HIPAA, cybersecurity, and a special behind-the-scenes view into the tradecraft of bad actors. This unique presentation included:
Recent enforcement trends by the Office for Civil Rights.
The current environment for ransomware.
An opportunity to watch as Barry logs onto the Dark Web and shows you first-hand how bad actors operate.
Ideas for managing cybersecurity threats.
On Friday, August 21, 2020, a webinar co-hosted by PYA prepared hospitals for a new rule taking effect on January 1, 2021, to address price transparency in healthcare. The Centers for Medicare & Medicaid Services published a rule in November 2019 requiring hospitals to establish, update, and make public a list of their standard charges for items and services they provide. In addition to the current requirement to post standard charges on their websites, the Final Rule requires hospitals to publish online, in a machine-readable format, their payer-specific negotiated rates for 300 “shoppable” services and their standard charges for all items and services provided, defined as the gross charge, payer-specific negotiated charges, discounted cash price, and the de-identified minimum and maximum charges.
As we approach January 2021, it is vital that hospitals understand the requirements of the pricing transparency rule and options for compliance. It is unlikely that this rule will “go away”–court decisions are always subject to appeal, and there is even concern that Congress is considering action that would transform these requirements from regulation to legislation.
During the complimentary webinar, PYA Senior Manager Kathy Reep discussed hospital requirements related to pricing transparency, and Chris Kenny, Partner in the Washington, D.C., office of King & Spalding, addressed concerns related to compliance and the legal challenges associated with the final transparency rule.
This webinar was presented in conjunction with:
Dallas-Fort Worth Hospital Council
Florida Hospital Association
Georgia Hospital Association
Kansas Hospital Association
Louisiana Hospital Association
Montana Hospital Association
Not a surprise to most — healthcare is making headlines on an international level. Though not front and center, still of importance to the hospital community are issues working their way through government agencies and the legislature.
As one of the keynote speakers of this year’s virtual Florida Institute of CPAs Health Care Industry Conference, PYA Senior Manager Kathy Reep presented a “Federal Legislative and Regulatory Update.” She covered a number of current issues affecting healthcare providers, including:
Price transparency.
Congressional action on surprise billing.
The Administration’s budget for 2021.
Medicare proposed rules related to hospital inpatient payments and post-acute care for FY2021.
The virtual event took place June 23-24, 2020.
Webinar: Post-Pandemic Provider Realignment — Navigating An Uncertain MarketPYA, P.C.
The COVID-19 pandemic will materially affect U.S. provider industry structure, as financial weaknesses are exposed, risk tolerances are tested, and uncertainties persist. As a result, provider mergers-and-acquisitions (M&A) activities across industry sectors will likely spike in the short- to medium-term future. Providers of all types need to be aware of, and prepared for, the changes they will face.
In this 45-minute joint webinar, PYA Principal Brian Fuller and Juniper Advisory Managing Director Jordan Shields provided a real-time assessment of the COVID-19 pandemic, as well as shared predictions for what the extending crisis means in coming years for M&A activity in the provider space.
The webinar took place Thursday, August 6, 2020, at 11 a.m. EDT.
Since March, PYA experts have closely tracked and carefully evaluated the pandemic’s impact on employed physician compensation. During this complimentary one-hour webinar, PYA Principals Angie Caldwell and Martie Ross highlighted five immediate considerations for hospitals and health systems to manage the storm. They also explored five longer-term considerations impacting future planning.
This webinar took place Friday, July 24, 2020, at 11 a.m. EDT, and was held in conjunction with:
Dallas-Fort Worth Hospital Council
Florida Hospital Association
Kansas Hospital Association
Montana Hospital Association
The COVID-19 pandemic has exposed organizational and industry weaknesses. To build a more resilient delivery system, leaders now must engage their governing boards in re-calibrating strategic plans, re-evaluating investments, and re-imagining hospitals’ and health systems’ roles in their communities.
In this 45-minute webinar, PYA Principals Martie Ross and Brian Fuller provided a framework for these critical discussions including root-cause analysis, market assessment, new realities, guiding principles, and strategic and operational priorities.
This webinar originally took place on Wednesday, June 24, 2020.
Webinar: Free Money with Strings Attached – Cares Act Considerations for Fron...PYA, P.C.
PYA, in conjunction with the Montana Hospital Association, recently co-hosted a Frontier States Town Hall Meeting webinar, “Free Money With Strings Attached: CARES Act Considerations for Frontier States’ Healthcare Provider Organizations.” Principals Lori Foley, Martie Ross, and David McMillan introduced the CARES Act Provider Relief Fund including distribution formulas, the attestation process, the verification and application process, and ongoing recordkeeping requirement. They also answered attendees’ numerous questions regarding these matters.
Webinar: “Got a Payroll? Don’t Leave Money on the Table”PYA, P.C.
Under the CARES Act, every employer with a payroll has an opportunity to retain cash–whether they have a PPP loan or not. What employers need to know right now.
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) along with the Payroll Protection Program (PPP) offer all business owners relief, but the details can be confusing or overlooked.
Perhaps you don’t fully understand how the deferral of the employer’s share of Social Security taxes works. Maybe you wonder if the deferral even applies to you—good news, it does if you have a payroll!
Failure to fully understand your options could cost you money, at a time when “cash is king.”
As part of PYA’s ongoing commitment to sharing helpful guidance, Tax Principals Debbie Ernsberger and Mark Brumbelow outlined issues and opportunities within the CARES Act, and answered questions during a one-hour webinar that originally aired on Wednesday, May 20, 2020.
Webinar: So You Have a PPP Loan. Now What?PYA, P.C.
The CARES Act provides relief to small businesses through Paycheck Protection Program (PPP) loans, but receiving the loan is only the first part of the equation. PYA discussed what businesses need to know and do next.
Failure to fully understand the requirements for PPP loan forgiveness could cost employers money, at a time when every penny counts. Employers need to stay up-to-date on recent activities regarding the PPP loan forgiveness application, necessary documentation, and other best practices to ensure they are well-prepared for the next steps under the PPP.
As part of PYA’s ongoing commitment to sharing helpful guidance, Tax Principals Debbie Ernsberger and Mark Brumbelow outlined PPP loan forgiveness requirements and answered questions during a one-hour webinar on Wednesday, June 3, 2020.
Webinar: “Making It Work—Physician Compensation During the COVID-19 Pandemic”PYA, P.C.
What to do with your physician compensation plan in the face of the COVID-19 pandemic? It’s a question that leaves administrators searching for answers.
PYA Principal Angie Caldwell and Senior Manager Katie Culver introduced several key considerations for provider compensation during and after the COVID-19 pandemic. In PYA’s complimentary webinar, they:
Summarized the current environment impacting physician compensation associated with the pandemic.
Provided an overview of the Stark Blanket Waivers and opportunities created for physician compensation.
Described restoration and recovery strategies for physician resources.
PYA hosted this one-hour webinar Tuesday, April 28, 2020, at 11 a.m. EDT in conjunction with the Florida Hospital Association.
Webinar: “Provider Relief Fund Payments – What We Know, What We Don’t Know, W...PYA, P.C.
The federal government is now making CARES Act Relief Fund payments to Medicare providers. These payments are not loans—they do not have to be repaid or forgiven. However, this money comes with strings attached.
During PYA’s 30-minute webinar, Provider Relief Fund Payments—What We Know, What We Don’t Know, What To Do Now, PYA Principals Martie Ross and Lori Foley discussed:
The source of the funds.
The required attestation process.
Compliance, tax, and audit concerns.
The webinar took place Friday April 17, 2020.
Webinar: “Hospitals, Capital, and Cashflow Under COVID-19”PYA, P.C.
Hospitals and providers need to think creatively, strategically, and long-term about capital and cashflow under the pressures of the COVID-19 pandemic. A one-hour webinar hosted by PYA discussed the current state of capital markets for non-profit healthcare systems, and considerations for capital management, including the role of real estate assets.
PYA Principal Michael Ramey joined Realty Trust Group Senior Vice-President Michael Honeycutt and Ponder & Company Managing Director Jeffrey B. Sahrbeck to present “Hospitals, Capital, and Cashflow, Under COVID-19” In this webinar, they covered:
Hospital industry capital market updates and trends, including how the capital markets are responding to the crisis.
Access to capital under recent regulations.
Cash preservation techniques for hospitals considering real estate operations and assets.
The webinar took place Thursday, April 9, 2020, at 11 a.m. EDT.
PYA Webinar: “Additional Expansion of Medicare Telehealth Coverage During COV...PYA, P.C.
Late on March 30, CMS released an interim rule which, among other things, significantly expands Medicare telehealth coverage, even beyond the initial Section 1135 waivers. PYA’s complimentary one-hour webinar explained these changes and how they make telehealth an even more attractive option in response to the COVID-19 pandemic.
PYA Principals Martie Ross and Valerie Rock addressed the latest developments, including:
New reimbursement for telephone-only services.
Broader coverage for remote patient monitoring.
New payments for rural health clinics and federally qualified health centers.
Use of telehealth to meet supervision requirements.
New rules regarding coding and billing as well as the changed payment rates for telehealth services.
The webinar took place Friday April 3, 2020, at 11 a.m. EDT.
Empowering ACOs: Leveraging Quality Management Tools for MIPS and BeyondHealth Catalyst
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CHAPTER 1 SEMESTER V - ROLE OF PEADIATRIC NURSE.pdfSachin Sharma
Pediatric nurses play a vital role in the health and well-being of children. Their responsibilities are wide-ranging, and their objectives can be categorized into several key areas:
1. Direct Patient Care:
Objective: Provide comprehensive and compassionate care to infants, children, and adolescents in various healthcare settings (hospitals, clinics, etc.).
This includes tasks like:
Monitoring vital signs and physical condition.
Administering medications and treatments.
Performing procedures as directed by doctors.
Assisting with daily living activities (bathing, feeding).
Providing emotional support and pain management.
2. Health Promotion and Education:
Objective: Promote healthy behaviors and educate children, families, and communities about preventive healthcare.
This includes tasks like:
Administering vaccinations.
Providing education on nutrition, hygiene, and development.
Offering breastfeeding and childbirth support.
Counseling families on safety and injury prevention.
3. Collaboration and Advocacy:
Objective: Collaborate effectively with doctors, social workers, therapists, and other healthcare professionals to ensure coordinated care for children.
Objective: Advocate for the rights and best interests of their patients, especially when children cannot speak for themselves.
This includes tasks like:
Communicating effectively with healthcare teams.
Identifying and addressing potential risks to child welfare.
Educating families about their child's condition and treatment options.
4. Professional Development and Research:
Objective: Stay up-to-date on the latest advancements in pediatric healthcare through continuing education and research.
Objective: Contribute to improving the quality of care for children by participating in research initiatives.
This includes tasks like:
Attending workshops and conferences on pediatric nursing.
Participating in clinical trials related to child health.
Implementing evidence-based practices into their daily routines.
By fulfilling these objectives, pediatric nurses play a crucial role in ensuring the optimal health and well-being of children throughout all stages of their development.
CHAPTER 1 SEMESTER V PREVENTIVE-PEDIATRICS.pdfSachin Sharma
This content provides an overview of preventive pediatrics. It defines preventive pediatrics as preventing disease and promoting children's physical, mental, and social well-being to achieve positive health. It discusses antenatal, postnatal, and social preventive pediatrics. It also covers various child health programs like immunization, breastfeeding, ICDS, and the roles of organizations like WHO, UNICEF, and nurses in preventive pediatrics.
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Telehealth Psychology Building Trust with Clients.pptxThe Harvest Clinic
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The dimensions of healthcare quality refer to various attributes or aspects that define the standard of healthcare services. These dimensions are used to evaluate, measure, and improve the quality of care provided to patients. A comprehensive understanding of these dimensions ensures that healthcare systems can address various aspects of patient care effectively and holistically. Dimensions of Healthcare Quality and Performance of care include the following; Appropriateness, Availability, Competence, Continuity, Effectiveness, Efficiency, Efficacy, Prevention, Respect and Care, Safety as well as Timeliness.
Global launch of the Healthy Ageing and Prevention Index 2nd wave – alongside...ILC- UK
The Healthy Ageing and Prevention Index is an online tool created by ILC that ranks countries on six metrics including, life span, health span, work span, income, environmental performance, and happiness. The Index helps us understand how well countries have adapted to longevity and inform decision makers on what must be done to maximise the economic benefits that comes with living well for longer.
Alongside the 77th World Health Assembly in Geneva on 28 May 2024, we launched the second version of our Index, allowing us to track progress and give new insights into what needs to be done to keep populations healthier for longer.
The speakers included:
Professor Orazio Schillaci, Minister of Health, Italy
Dr Hans Groth, Chairman of the Board, World Demographic & Ageing Forum
Professor Ilona Kickbusch, Founder and Chair, Global Health Centre, Geneva Graduate Institute and co-chair, World Health Summit Council
Dr Natasha Azzopardi Muscat, Director, Country Health Policies and Systems Division, World Health Organisation EURO
Dr Marta Lomazzi, Executive Manager, World Federation of Public Health Associations
Dr Shyam Bishen, Head, Centre for Health and Healthcare and Member of the Executive Committee, World Economic Forum
Dr Karin Tegmark Wisell, Director General, Public Health Agency of Sweden
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Growing Prevalence of Lifestyle Diseases
The rising incidence of lifestyle diseases such as diabetes, cardiovascular diseases, and cancer is a major trend driving the clinical trials market in India. These conditions necessitate the development and testing of new treatment methods, creating a robust demand for clinical trials. The increasing burden of these diseases highlights the need for innovative therapies and underscores the importance of India as a key player in global clinical research.
Fair Market Value: What Rural Providers Need to Know
1. Page 0
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Valuations: What Rural
Providers Need to Know
Tynan Olechny, MBA/MPH, AVA
Annapoorani Bhat, ASA
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Agenda
1
2
3
4
Overview of Healthcare Regulatory Considerations
Special Considerations for Rural Healthcare Providers
Fair Market Value (FMV) and Commercial Reasonableness (CR) Defined
5 FMV Enforcement Cases
Key Industry Trends
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Times Are Changing…
• Overall theme is consolidation and
integration.
• Significant trend of
hospital/physician alignment.
• Increased focus on reducing
healthcare costs while also
improving quality of patient care.
• Changes in healthcare delivery
system from healthcare reform
package.
• Continued government focus on
fraud and abuse.
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Rural Health Differentiators
• About 10% of physicians practice in rural areas, yet rural areas account for
about 25% of the patient population.
– There are 2,157 Health Professional Shortage Areas (HPSAs) in rural and frontier
areas of all states and US territories compared to 910 in urban areas.
• Rural patients tend to be poorer, are less likely to have insurance coverage,
and are more likely to have a chronic illness than patients in urban areas.
• Medicare payments to rural hospitals are much lower than to hospitals in
urban areas for the same services.
• Rural hospitals tend to be much smaller, with lower patient volume than those
in urban areas, but are still faced with providing the same broad range of
services and high-quality care.
• More than 470 rural hospitals have closed within the past 25 years.
Source: National Rural Health Association; American Hospital Association.
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Key Rural Health Issues
• Insufficient patient volumes to cover high-fixed costs
– Problem: Maintaining healthcare access for rural residents comes with a high
price tag, but low patient volumes do not generate sufficient revenues for
providers to cover those costs.
– Band-Aid: Special Medicare and Medicaid payment enhancements to rural
providers to cover the gap.
– Pain Point: Potential elimination of payment enhancements.
– Cure: Providers across multiple communities within a region work
collaboratively to spread costs while maintaining services by strategically
allocating resources.
– Prescription: Inclusive governance structure to foster trust relationships
among providers: no trust, no spread.
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Key Rural Health Issues
• Insufficient patient population over which to spread risk
– Problem: Rural providers are unable to pursue risk-based contracts because
there is insufficient patient population over which to spread risks.
– Band-Aid: Exclude rural providers from value-based contracting opportunities.
– Pain Point: Growing pressure from payers to purchase value instead of
volume; demand from rural communities for quality and efficiency.
– Cure: Providers serving multiple rural primary care service areas form network
to aggregate populations for contracting purposes.
– Prescription: Sufficient clinical integration among network providers to
survive antitrust scrutiny: no integration, no aggregation.
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Trends in Rural Areas
• Professional Service Agreement (PSA)
– Rural hospitals contract with physicians from urban areas to hold clinics and
perform procedures.
• Medical Directorships
– Provide clinical and administrative leadership to a specific service line of the
hospital.
• Clinical Co-management Arrangements
– Align physicians and hospital to achieve greater efficiencies and improve
patient outcomes.
Key Concept: FMV is critical to determination of payment
for transactions between physicians and hospitals.
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Overview of Healthcare
Regulatory Considerations
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• Regulatory concerns affecting physician-hospital
transactions, such as employment, can be daunting.
• Physicians are constrained by laws not applicable to other
industries.
• Primary legal concerns are Stark Law, Anti-Kickback Statute,
and False Claims Act.
• Transactions with 501(c)(3) hospitals bring heightened
scrutiny from OIG and IRS.
Bottom Line: Physicians cannot receive compensation
based on their referrals when reimbursed by federal (or
state) healthcare dollars.
Key Regulatory Considerations
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Stark Law
• Also called the “Physician Self-Referral Law.”
• Prohibits a physician from making referrals for designated
health services to entities in which the physician (or a family
member) has a financial relationship.
• Designated Health Services (DHS):
- Currently 12 health services
- Includes hospital inpatient and outpatient services, as well as
clinical lab, physical and occupational therapy, radiology,
certain imaging, DME, home health, and various other
services and supplies
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Stark Law (continued)
• Is a “strict liability” law
• Contains various “exceptions”
Rural provider exception applies to physician ownership
interests
• Enforced by the Centers for Medicare & Medicaid Services
(CMS), although Department of Justice adjudicates false
claims arising from violations of the Stark Law
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Anti-Kickback Statute (AKS)
• Prohibits the payment or receipt of remuneration to induce
or reward referrals for Medicare or Medicaid services.
• Criminal statute that requires proof of “intent,” i.e.,
knowingly and willfully paying for referrals.
• If one purpose of the payment is to induce referrals, then
AKS is violated, even if there are other legitimate business
reasons for the payment.
• Contains various “safe harbors.”
• Enforced by the Office of the Inspector General (OIG) and
the Department of Justice (DOJ).
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False Claims Act
Imposes liability on any person who submits a claim to the
federal government that the person knows (or should know)
is false.
Civil statute.
Often “piggy-backed” with the AKS and Stark.
Subject to qui tam (“whistle-blower”) suits.
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IRS 501(c)(3) Anti-Inurement Rules
501(c)(3) tax exempt entities
must avoid “excess benefit”
transactions.
Transactions must be at FMV
and must be consistent with the
entity’s charitable mission.
Violations can result in loss of tax
exempt status.
Rules
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Penalties for Violations of Key
Healthcare Regulations
Penalties for violation can include:
• Denial of payment.
• Refund of payment.
• Civil monetary penalty up to $15,000 per claim.
• Civil monetary penalty up to $100,000 for each
“scheme” designed to circumvent the law.
• Civil monetary penalty of up to three times the
amount of claims.
• Possible criminal penalties, including jail time.
• Exclusion from the Medicare or Medicaid program.
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Fair Market Value and Commercial
Reasonableness Defined
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What is Fair Market Value?
$
Willing
Seller
Willing
Buyer
$“Ground Rules”
• Arm’s length transaction
• Bona fide bargaining
• Neither is under compulsion
• Reasonable knowledge of relevant
facts
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• Determined from the perspective of hypothetical buyers and
sellers without the ability to refer business to one another.
• No consideration for synergies. However, such synergies
often exist!
• The financial terms of the transaction must make economic
sense based on the services being provided.
• Determination of FMV involves both quantitative and
qualitative analyses.
Fair Market Value – Key Concepts
20. Page 19
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Importance of FMV Opinions
• Many regulatory exceptions require employment
arrangements to be at fair market value.
• FMV opinions ensure transactions are compliant with key
regulatory considerations and serve to protect hospital and
physicians from government scrutiny.
• Nearly two-thirds (65%) of organizations have established
governance policies regarding physician compensation
arrangements that may require an external review for FMV.
-Of these, more than half (53%) conduct an external FMV
review of physician compensation levels annually.
Source: Sullivan, Cotter and Associates, Inc. 2013 Physician Compensation and Productivity Survey.
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What Are the Key Steps and Factors
in the FMV Process?
• A comprehensive understanding of
all aspects surrounding the
proposed arrangement.
• Examples include:
– Hospital staffing needs/full-time
equivalents (FTEs) required
– Physician/practice specialty
– Community-specific factors
– Exclusivity of services
– Coverage details
– Billing specifics
Step 1:
Ascertain
Key Facts
Surrounding
the
Arrangement
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What Are the Key Steps and Factors
in the FMV Process?
• Physician experience
• Provider productivity
• Market comparables
• Quality measures
• Reimbursement trends
• Payer mix
• Practice performance
• Supply/demand
• Compensation trends
• HPSA and MUA/P
designation
Step 2:
Determine
Factors that
May Impact
FMV
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What Are the Key Steps and Factors
in the FMV Process?
• Medical Group Management
Association
• Sullivan, Cotter & Associates, Inc.
• Hospital & Healthcare Compensation
Service
• American Medical Group Association
• The Delta Companies
• Merritt Hawkins & Associates
• Modern Healthcare
• Other “Objective” Survey Benchmarks
Step 3:
Identify
Multiple
Objective Data
Sources for
Benchmarking
24. Page 23
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What Are the Key Steps and Factors
in the FMV Process?
• Compensation survey data
• Cost to replace/build
• Locum tenens
• Market comparable analysis
• Productivity analyses
• Time studies
• Compensation per wRVU
• Collections per wRVU
• Other relevant analyses
Step 4:
Identify
Analyses for
Determining
FMV
Compensation
25. Page 24
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What is Commercial Reasonableness?
• Defined by the Department of Health and Human
Services (HHS) as an arrangement which appears to be
“a sensible, prudent business agreement from the
perspective of the particular parties involves, even in the
absence of any potential referrals.”
• Many Stark exceptions require payment to be
commercially reasonable.
Key Concept: In the absence of a referral relationship, is
the arrangement one that makes “good business sense?”
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Example Factors in Determining CR
• Is each component of the proposed arrangement (as well as
the entire arrangement):
- A reasonable necessity that is essential to the functioning of the entities
involved?
- Reasonably necessary to accomplish a rational business purpose?
• Does any specialized training and/or experience of the
provider exist that should be taken into account?
• Are the particular nature of the duties and the corresponding
amount of accountability under the proposed arrangement
clearly defined and reasonable?
• Are patient demand, the number of hospital patients, and/or
the community need sufficient to justify the services?
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FAIR MARKET
VALUE
COMMERCIAL
REASONABLENESS
Overall
Arrangement
“WHY?”
SENSE CENTS
Range of
Dollars Only
“HOW
MUCH?”
Scope
Key Question
Differentiating Between FMV and CR
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Special Considerations for
Rural Healthcare Providers
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When To Obtain a Third-Party Valuation
• FMV opinions can be expensive due to the time
spent in research and discussion of difficult issues.
• May not make practical business sense for rural
healthcare providers to obtain an FMV opinion for
every proposed arrangement.
Key Concept: Seek outside assistance on riskier or
more complex arrangements.
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Evaluating Risk
• Is the arrangement commercially reasonable?
• Are you offering to pay at the median or at the 90th
percentile of national survey benchmarks?
• Are there multiple components to the compensation
arrangement? Could the physician be getting paid
twice for the same services?
• Is there potential for a productivity or other bonus to
push total compensation above the 90th percentile?
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Proceeding Without an FMV Opinion
• Though an FMV opinion will be your best defense if the
arrangement is ever called into question, rural healthcare
providers may choose not to obtain a formal report for various
reasons. Without an FMV report, it’s still important to:
– Document your clear, objective methodology in determining
compensation for arrangement
– Establish and document appropriate need for services
– Document any other important factors – i.e. location in a Health
Professional Shortage Area (HPSA) or Medically Underserved
Area/Population (MUA/P), or recruiting difficulties
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Contact Information:
TOlechny@pyapc.com
ABhat@pyapc.com
(404) 266-9876
www.pyapc.com
Thank You!