October 31, 2019

Valuation of Specialty Pharmacies

The specialty pharmacy marketplace in the US has experienced rapid growth in recent years. The number of specialty pharmacies operating in the US has more than doubled since 2015. US expenditures for specialty drugs have also nearly doubled from $83 billion in 2013 to $157 billion in 2017. Combined with spending on orphan drugs, total US expenditures on specialty pharmaceuticals is now nearly equal the amount spent on traditional medications.[1],[2]

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Topics: Healthcare Valuation, Valuation

October 17, 2019

Proposed Changes to Stark Law Encourage Transition to a Value-Driven Healthcare System

Last week, the Department of Health and Human Services (HHS) and the Center for Medicare and Medicaid (CMS) revealed proposed changes to “modernize” and clarify regulations that interpret the Physician Self-Referral Regulations (Stark Law) and the Federal Anti-Kickback Statute. The Proposed Rule immediately highlights a focus on the transition to a value-driven healthcare system, which is in-line with the OIG’s priorities. 

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Topics: Value-Based Care, Stark Law

October 10, 2019

Is Your Physician Contract Commercially Reasonable?

When considering Stark Law exceptions for vetting financial arrangements with physicians, we often witness a tendency to focus primarily on Fair Market Value (FMV). This is rightly so, as ensuring physician contracts comply with FMV is a critical part of risk management.

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Topics: Physician Compensation, FMV, Commercially Reasonable

October 03, 2019

Selecting the Right Level of Appraisal or Valuation

For those seeking valuation or appraisal services, the varying levels of services offered can often be confusing to navigate. Appraisers/valuators offer many different services to meet the needs of a diverse client base. Confusion in the process of selection can lead clients to select a service based solely on price, only later to discover, as with many things in life, you get what you pay for. 

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Topics: FMV, Valuation

September 19, 2019

Fair Market Valuation of Accountable Care Organizations

An accountable care organization (“ACO”) is a healthcare delivery entity characterized by a payment model that facilitates coordination among providers — charged with the care of a specified patient population.

Participation in an ACO is voluntary, and participants must be willing to become accountable for the quality, cost, and overall care of the specified population. Commonly, ACOs receive capitated payments based on the size of the patient population served, though other reimbursement models exist. ACO participants are financially incentivized to lower healthcare costs while improving quality as they share in a portion of the excess between total capitated payments and total healthcare costs.

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Topics: Fair Market Value, FMV, ACO

August 29, 2019

6 Questions to Ask When Assessing a Physician On-Call Arrangement

On-call pay is the hospital’s payment for access to physicians providing call coverage. The provision of on-call pay to physicians continues to be a hot topic for hospital leaders and physicians. Therefore, it is important from a strategic, financial and regulatory perspective to properly structure physician on-call pay arrangements.

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Topics: Physician Compensation

August 15, 2019

Fair Market Value Physician Compensation Fails

Determining fair market value (FMV) compensation in a healthcare setting generally requires the use of multiple, objective data points and an understanding of how to apply that information given the unique facts and circumstances of the subject arrangement relative to the overall market.

Understanding what the government considers as support for FMV, and what it does not, is critical to selecting and enacting policies and procedures for establishing FMV physician compensation.

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Topics: Physician Compensation, Fair Market Value

August 08, 2019

IPPS Final Rule FY 2020 — 3 Main Takeaways

There are two things I know will happen at the beginning of August: Football is about to begin and the newest updates on the next fiscal year payment system will soon be released. Last Friday, the Federal Fiscal Year (FFY) 2020 Inpatient Prospective Payment System (IPPS) Final Rule was released. This quickly changed my weekend plans as I delved into the details to fully understand what changes the Centers for Medicare and Medicaid Services (CMS) would implement for FFY 2020. I’m just glad it was before football season started.

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Topics: IPPS

July 11, 2019

Nonprofit Hospitals: At the Intersection of Compliance Efforts Lies Revenue Opportunity

Compliance is a fact of life for hospitals and health systems, and it’s only getting more complex. But what if I told you that by coordinating the time and effort spent on accounting, tax and reimbursement rules, you could leverage that effort to maximize reimbursements and minimize audit exposure?

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Topics: Revenue Recognition Standard

July 03, 2019

Revenue Recognition Standard Is Here. It’s Time to Fix Your AR Model

Here’s a cautionary tale: It’s early 2020 and Joe the CFO is sitting down with his hospital’s board of directors and independent auditors. Next up on the agenda: Presentation of the 2019 audited financial statements.

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Topics: Revenue Recognition Standard

May 16, 2019

BPCI Advanced – To Apply, or Not to Apply?

With mandatory programs on the horizon, the voluntary Bundled Payments for Care Improvement Advanced (BPCI-A) program offers early access to data and valuable experience in redesigning patient care. But with applications closing June 24, 2019, healthcare organizations will need to make some quick decisions about participating in this voluntary Medicare bundled payment program.

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Topics: BPCI-A

February 28, 2019

Tax Reform: Do Final 199A Regulations Help or Hurt Healthcare Entities?

We have been monitoring and reporting on tax reform for several months, including one of the most complicated areas of the new law – Section 199A, commonly known as the 20% pass-through deduction.

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Topics: Tax Reform, Section 199A

January 29, 2019

Tax Reform: Are Your Parking Expenses Deductible?

A recent notice from the Internal Revenue Service has provided additional guidance regarding changes that the Tax Cuts and Jobs Act (TCJA) made to the tax treatment of parking fringe benefits. Previously, employers could generally deduct expenses related to “qualified transportation fringe benefits” that they provided to employees, including parking. The new law disallowed this deduction.

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Topics: Tax Reform