Thought Leadership

Thought Leadership

Home / Insights / Thought Leadership

New OIG Advisory Opinion: Implications for FMV in Physician Gainsharing

January 10, 2018 Andrea Ferrari

Published: 01/10/2018 | Author: Andrea M. Ferrari, JD, MPH 

On January 5, 2018, the Office of Inspector General of the United States Department of Health and Human Services (“OIG”) posted a new Advisory Opinion addressing a proposed physician gainsharing arrangement. This Advisory Opinion, No. 17-091, is the first time that the OIG has opined [...]


Student Loan Repayment and Physician Employment

Published: 12/12/2017 | Authors: Scott M. Safriet, CVA, MBA & Elizabeth Cohen, JD

For physicians that have recently completed their medical education, student loan repayment is an often asked for benefit when contemplating employment opportunities.  However, while not technically cash in hand to the physician, it is nonetheless considered a [...]


Searching for Doctor McDreamy: Specialty Hospitalist Arrangements and Fair Market Value

November 21, 2017 Andrew L. Worthington

Published: 11/21/2017 | Author: Andrew L. Worthington

The combination of healthcare industry consolidation and physician shortages can leave hospitals with few options to secure coverage by specialist physicians. Oftentimes, the traditional on-call arrangement may not be sufficient to secure consistent coverage of hospital-based service lines. [...]


42 Million Reasons to Consider FMV in Marketing Arrangements

Published: 11/10/2017 | Authors: Daniel Levin, CFA & Nicholas Janiga, ASA

Over the past few years, marketing arrangements have drawn increased scrutiny from government regulators.  As an example, on June 28, 2017, the United States Department of Justice announced that a hospital located in Los Angeles, California had agreed to pay $42 million [...]


President Trump, the Opioid Crisis, and Fair Market Value

October 31, 2017 Luis Argueso

Published: 10/31/2017 | Author: Luis A. Argueso 

On October 26, 2017, President Trump declared that opioid addiction represented a “public health emergency,” as reported by the Wall Street Journal. Concurrent with this declaration, the administration outlined steps that it would take to ameliorate the harm caused by the opioid crisis. One such [...]


Call Coverage: Version 2.0

October 12, 2017 Cindy Alvarez, JD


Historically, hospitals relied on physicians to provide call coverage without compensation. Over the years, the industry has changed, and physicians have become less willing to provide on-call coverage without some form of remuneration. Faced with these new demands, hospitals struggle to secure adequate coverage to [...]