Dena M. Castricone, CIPP/US, CIPM’s Post

Is the 75th Percentile FMV, regardless of productivity? For those of you who live in the healthcare regulatory compliance space, I wanted to get your opinion on the recent Community Health Network, Inc. (CHN) case.  In case you’re not familiar with it, CHN ignored guidance from their valuation consultants regarding physician compensation. One of their valuation firms essentially advised CHN that physician compensation at or below the 75th percentile (of national survey data) was FMV regardless of productivity. What are your general thoughts on this?

The answer is no for a couple of reasons. 1) CMS basically said as much in their 2021 Stark Law changes, which stated that it is not CMS' policy that anything below the 75th percentile is OK and anything above is suspect. FMV is based on the facts and circumstances of a particular arrangement. 2) Productivity is only one element of value - access, quality, patient experience, cost of care and a multitude of other factors all matter when determining the fair market value of a particular arrangement.

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Did you miss "Adverse Action Reporting: The Consequences Of A Permanent Record," part 3 of our Exploring Hospital and Physician Dynamics webinar series? Listen on-demand here:

Did you miss "Adverse Action Reporting: The Consequences Of A Permanent Record," part 3 of our Exploring Hospital and Physician Dynamics webinar series? Listen on-demand here:

Did you miss "Adverse Action Reporting: The Consequences Of A Permanent Record," part 3 of our Exploring Hospital and Physician Dynamics webinar series? Listen on-demand here:

Measuring what matters. PROMs/PREMs and patient-directed surveys to identify opportunities and create clarity in patient-directed care. An important, and often missed opportunity to objectify MSK care and create a 360-degree view of the clinical experience.

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This week on Sg2 Perspectives, host Trevor DaRin sits down with Sg2 Senior Director Casi Roethler, MBA, MHA, FACHE to talk all things primary care: what they’re seeing, what they’re hearing, what data they’re tracking, and what may change about primary care in the near- and long-term. Trevor and Casi touch on the consumer shift, employed vs independent physicians, and what the primary care landscape could look like in 5 or 10 years. https://bit.ly/4bmYXmP