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Services

Compensation Valuation & Provider Arrangement Consulting.

Pinnacle’s clients rely on our expertise to develop, implement, and manage provider affiliation arrangements that not only comply with applicable regulations (Stark, Anti-Kickback, etc.) but also further their objectives. While providers strive to offer the best care to patients, Pinnacle supports clients with knowledge on the forefront of a healthcare regulatory landscape that continuously evolves. These industry changes often influence the structure of provider affiliation agreements and Pinnacle works with our clients to ensure their arrangements are compliant and effective.

Pinnacle leader reviewing Compensation Valuation & Provider Arrangement Consulting on a computer

Fair Market Value Opinions

Overview

As the industry continues to evolve, healthcare organizations develop new types of provider arrangements to deliver care and improve efficiencies. Given the regulatory nuances involved and the differing value drivers for each agreement, the determination of FMV often requires the support of an outside valuation expert. Pinnacle’s consultants work with healthcare organizations to dissect the most complex arrangements and identify the appropriate range of value. Pinnacle’s FMV opinions include thorough documentation and describe key considerations such as appraisal methods, data sources, analytical assumptions, and findings. This comprehensive approach assists our clients with risk management as our opinions serve as stand-alone documentation in the event a subject arrangement is reviewed by a regulatory body.

Example Projects

Pinnacle has assisted numerous clients with physician compensation and valuation matters, including large health systems, academic institutions, smaller community hospitals, and physician groups. Examples of provider arrangement types we regularly review across multiple specialties include:

  • Employment arrangements
  • Recruitment and income guarantee arrangements
  • Clinical co-management arrangements
  • Management services arrangements
  • Medical director arrangements
  • On-call coverage arrangements
  • Staff leasing arrangements
  • Professional services arrangements
  • Consulting arrangements
  • Hospital-based, exclusive provider, and subsidy arrangements
  • Isolated transactions
  • Other miscellaneous physician arrangements

Commercial Reasonableness Assessments

Overview

As with FMV compensation, several statutes and regulations require that provider arrangements be “commercially reasonable”. This standard has been the focus of numerous enforcement actions in recent years. Although CR is an abstract concept, Pinnacle’s CR Checklist provides a concrete methodology for assessing arrangements to ensure compliance. We believe it is important for our clients to understand that a transaction can fail to meet the CR requirement, even if provider compensation is consistent with FMV. Pinnacle leverages in-depth industry knowledge to assist in these analyses, which can stand alone or be included in FMV opinions.

Example Projects

Pinnacle has developed a propriety checklist which serves as the basis for assisting our clients with CR assessments across multiple types of provider arrangements. These arrangements may involve several relevant factors, including consideration of:

  • The relationship between compensation and collections
  • Duplication of services across positions
  • Services provided to a multi-facility organization
  • Community need
  • Provider supply and market dynamics
  • Arrangement process, including business rationale and legal review
  • Unique knowledge or experience of relevant provider(s)
  • Oversight of arrangement(s)
  • Continued assessment of need surrounding the arrangement
  • Other relevant factors that influence CR

Compensation Plan Design & Review

Overview

Each year, Pinnacle performs hundreds of FMV and CR assessments. This extensive experience – combined with our team’s wide-ranging knowledge related to provider alignment – positions us to effectively develop and structure compensation strategies for our clients. We understand that provider compensation methods are constantly evolving in response to a myriad of factors, including changes in organizational strategies, shifts in reimbursement, physician demographics, and other market conditions. For instances, while recent trends in compensation reflect a greater emphasis on quality, value, and citizenship, many organizations are still working to shift from volume-based reimbursement (fee-for-service) to value-based reimbursement (increased quality and reduced costs). This industry shift, coupled with individual client goals, create an ongoing need to develop models that are competitive and innovative, yet compliant. Pinnacle’s experience in navigating and assisting clients with valuing their arrangements provides our team with extensive knowledge in developing compensation plans that meet individual organizational needs.

Example Projects

Pinnacle has supported our clients with compensation plan design and review across multiple types of arrangements and specialties. While no two projects are alike, our in-depth knowledge of healthcare compliance and financial analysis enable us to effectively provide clients with the necessary support. This client collaboration aims to ensure compliant arrangements that also further organizational objectives. These types of projects can vary across a variety of factors and provider types, including:

  • Integrated practices (i.e., employed physicians)
  • Independent practices (i.e., independent contractor physicians)
  • Multiple specialties and service lines
  • Varying operational environments
  • Salary-based clinic positions
  • Productivity and incentive-based plans
  • Hospital-based specialties
  • Surgical specialties
  • Primary care specialties
  • Numerous medical sub-specialties
  • Value-based care and quality metrics
  • Coverage and administrative roles
  • Varying FTEs and mid-level utilization, as well as others

Other Compensation-Related Services and Projects

Overview

In addition to our primary focus areas, Pinnacle’s compensation valuation team regularly performs various evaluations in the context of specialized and/or complex arrangements. Each of these focus areas contains many nuances which our experienced team works through on a collaborative basis with our clients. These subject areas are a value-add for our clients as they are able to launch unique services while relying on Pinnacle’s expertise to provide analytical and consultative support.

Example Projects

Pinnacle regularly assists our clients with unique arrangements that are multi-faceted and innovative in the industry. We have helped clients ranging from large health systems to small start-ups in evaluating compensation associated with unique services or arrangements, including:

  • Telemedicine and digital health services
  • Management services
  • Positions in organizations which are subject to a Corporate Integrity Agreement (CIA)
    • Pinnacle has provided CIA support as the independent review organization (IRO) and also in support of counsel as legal IRO
  • Value-based care arrangements, including:
    • Clinical co-management
    • Clinically integrated networks
    • Hospital efficiency programs
    • Clinical efficiency programs
    • Shared savings
  • Financial matters peripheral to provider compensation, such as:
    • Impact analysis associated with year over year changes to the Medicare Physician Fee Schedule (MPFS)
    • Impact analysis related to external factors such as changes in demand, demographics, and innovative care techniques
    • Scenario analysis involving various compensation components, production, and fair market value caps
  • Build-out of fair market value calculation tools related to various services, including:
    • Clinical compensation
    • Administrative (medical director) compensation
    • Call coverage
    • Aggregate annual compensation
  • Advisory and development of client compensation policies, including factors such as:
    • Defining processes for review and approval of agreements,
    • Establishing triggers for requiring additional fair market value or other review,
    • Determining thresholds for production,
    • Planning for year over year adjustments,
    • Additional protocols that further ensure compliance in conjunction with organizational goals
  • Litigation support
  • Other advisory and analytical matters related to a myriad of compensation-related issues