Need a compliance check-up?
Healthcare real estate is unique. The Stark Law, the Anti-Kickback Statute, The False Claims Act, and a myriad of other healthcare statutes and regulations create a complex regulatory environment in which health systems must operate daily. A course of action that may be perfectly acceptable in any other types of real estate transaction could, in the context of healthcare real estate, result in serious violations and expose health systems to significant liability.
In today’s ever-changing healthcare landscape, with increasing competitive pressures and progressive physician alignment models, it is imperative for health systems to create and implement effective healthcare real estate compliance programs to shelter them from regulatory infractions that can result from improperly structured or administered real estate arrangements with referral sources.
RTG provides a broad spectrum of healthcare real estate compliance services. From evaluating the structure for a new transaction, reviewing an existing transaction, or drafting and implementing effective real estate compliance policies and programs, our team has you covered. Leveraging our deep healthcare experience, we can also help improve operational efficiencies within the organization, streamlining processes and identifying cost savings opportunities.
On October 30, 2015, the Centers for Medicare and Medicaid Services (“CMS”) released the CY 2016 Medicare Physician Fee Schedule final rule (the “Final Rule”), which brought several significant changes to the Stark Law, 42 U.S.C. § 1395nn and its associated regulations, 42. C.F.R. § 350 et seq. (the “Stark Law”). The Final Rule, which went into effect January 1, 2016, has brought five important changes and clarifications affecting healthcare real estate.
Health systems’ real estate arrangements with referral sources face numerous compliance pitfalls, any one of which can trigger a violation under the Stark Law. The compliance pitfalls associated with real estate arrangements can be generally subdivided into two categories: (1) transactional and (2) operational. Transactional compliance pitfalls stem from the real estate arrangement itself and the specific structure of the transaction. Operational compliance pitfalls stem from the subsequent administration, or lack thereof, of the real estate arrangements. In this Best Practices Briefing, Realty Trust Group discusses five key transactional compliance pitfalls involving healthcare real estate.
We know and have talked to some healthcare real estate firms others that are good, but they may not have the breadth that RTG has. It would be a learning curve for a new firm to get to know us. RTG knows Northside and the way we want things delivered.