A PROFESSIONAL DEVELOPMENT JOURNAL for the CONSULTING DISCIPLINES
28 MARCH | APRIL 2020 the value examiner
By Todd A. Zigrang, MBA, MHA, FACHE, CVA, ASA and Jessica L. Bailey-Wheaton, Esq.
Healthcare Valuation Implications of
COVID-19
///////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////
///////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////
HEALTHCARE INSIGHTS
As of April 13, 2020, more than 558,000 Americans
had been diagnosed with the coronavirus
(COVID-19)the greatest number of confirmed
cases of any country in the worldresulting
in approximately 22,000 deaths.1 The COVID-19 global
pandemic has brought a time of grave uncertainty for U.S.
healthcare and the greater economy. Both the legislative
branch and the executive branch of the federal government
have taken a number of unprecedented actions in an effort
to stem the effects of the pandemic. Consequently, the
uncertainty surrounding the resulting paradigm changes on
the U.S. healthcare industry may have significant valuation
implicationsboth now and in the future.
Recent Legislative Actions
During March 2020, the U.S. Congress passed various
pieces of legislation to combat both the surge in demand
for healthcare services (and resulting shortages in
healthcare workforce manpower and supplies) and the
detrimental effects that the pandemic has had on the U.S.
economy to date.
On March 6, 2020, President Trump signed the $8.3 billion
Coronavirus Preparedness and Response Supplemental
Appropriations Act, 2020,2 which authorizes several
significant activities and expenditures by the U.S. government,
including the following:
1. The Telehealth Services During Certain Emergency
Periods Act (TSDCEPA) of 2020, which gives
1 Internationally, confirmed COVID-19 cases have surpassed 1.8 million,
resulting in over 115,000 deaths worldwide. Coronavirus COVID-19
Global Cases by the Center for Systems Science and Engineering
(CSSE) at Johns Hopkins University, John Hopkins University, April
13, 2020, https://www.arcgis.com/apps/opsdashboard/index.html#/
bda7594740fd40299423467b48e9ecf6 (accessed 4/13/20).
2 Pub. L. No. 116-123, 134 Stat. 146 (2020).
authority to the Secretary of the Department of
Health and Human Services (HHS) to lift some
telehealth delivery restrictions.3
2. $6.2 billion delegated to HHS for activities such as:
a. The Public Health and Social Services
Emergency Fund (PHSSEF)$3.4 billion
in funding is delegated to: the Biomedical
Advanced Research and Development
Authority (BARDA) to research potential
vaccines and therapeutics relating to
coronavirus; contingency funding for
vaccines and other therapeutics; and
the Health Resources and Services
Administration (HRSA) to provide grants
under the Health Center Program.
b. $1.9 billion delegated to the Centers for
Disease Control and Prevention (CDC), to
be directed to state and municipal response
efforts relating to the pandemic and
replenishment of the Infectious Diseases
Rapid Response Reserve Fund.
c. $836 million delegated to the National
Institute of Allergy and Infectious Diseases
(NIAID), for the research of therapies and
vaccines.
d. $61 million delegated to the Food and Drug
Administration (FDA), to develop and
review vaccines and other treatments for
COVID-19.4
3 COVID-19s effects on the telehealth industry will be covered in future
issues of The Value Examiner.
4 Coronavirus Preparedness and Response Supplemental Appropriations
Act, 2020 (see n. 2).
A PROFESSIONAL DEVELOPMENT JOURNAL for the CONSULTING DISCIPLINES
the value examiner MARCH | APRIL 2020 29
On March 18, 2020, Congress passed (and President Trump
signed) the Families First Coronavirus Response Act,5 which
provides for free COVID-19 testing, paid leave, enhanced
unemployment insurance, expanded food security initiatives,
and increased Medicaid funding.
On March 27, 2020, Congress passed (and President Trump
signed) a $2 trillion economic stabilization package, the
Coronavirus Aid, Relief and Economic Security (CARES) Act,
that provides funds to individuals, businesses, and states. The
CARES Act will also provide direct funding to the healthcare
industry through a number of additional measures, including
the following:
1. $100 billion to hospitals, for the purpose of
reimbursing expenses and lost revenue related
to COVID-19, plus an additional $250 million to
increase their surge capacity.
2. A 20 percent increase in Medicare payments
to hospitals related to treatment of COVID-19
inpatients.
3. A delay in disproportionate-share hospital (DSH)
payments through November 2020, which will
effectively increase reimbursement to those safetynet hospitals.
4. A suspension of Medicare sequestration (which
will effectively increase most Medicare provider
reimbursement by 2 percent) through the end of
2020.
5. Advance Medicare payments to critical access and
other hospitals that request them to help balance
out their cash flows (based on payments received
in 2019), which may be paid back over a one-year
period.
6. An extension of several Medicare and Medicaid
programs until November 30, 2020, which may allow
Congress to revisit certain healthcare programs and
policies (e.g., surprise billing, prescription drug
prices) after the 2020 U.S. presidential election.
Recent Executive Branch Actions
In addition to the various laws passed by Congress, the
president and various government agencies have taken a
number of steps to ameliorate the crisis. On March 11, 2020,
5 Pub. L. No. 116-127, 134 Stat. 177 (2020).
President Trump announced aggressive measures to combat
the spread of coronavirus, including the following:
1. Instructing the Internal Revenue Service to allow
high-deductible health plans (HDHPs) to provide
health benefits associated with testing and treatment
of COVID-19 without a deductible, or with a
deductible below the minimum deductible amount,
without losing tax status as an HDHP, thereby
allowing tax-favored contributions to health savings
accounts (HSAs) by patients.6
2. Collaborating with national health insurers to
cover all American patients COVID-19 testing and
treatment, without copayments.7
3. Instructing the Department of Treasury to defer tax
payments for individuals and businesses impacted
by COVID-19.8
On March 13, 2020, President Trump officially declared
the COVID-19 pandemic a national emergency.9 This
proclamation allows for greater flexibility for healthcare
providers and access to additional resources for states.
Following the proclamation, the CMS issued a number of
waivers for healthcare providers and announced additional
measures that are active for the duration of the pandemic:10
1. The skilled nursing facility (SNF) three-day rule
(which requires Medicare beneficiaries to have a
three-day hospital stay before Medicare pays for SNF
services) has been waived.
6 IRS Notice 2020-15, High Deductible Health Plans and Expenses
Related To COVID-19 (March 11, 2020); see https://www.irs.gov/pub/irsdrop/n-20-15.pdf (accessed 3/12/20).
7 President Donald J. Trump Has Taken Unprecedented Steps To Respond
To The Coronavirus And Protect The Health And Safety Of Americans,
The White House, March 11, 2020, https://www.whitehouse.gov/briefingsstatements/president-donald-j-trump-taken-unprecedented-steps-respondcoronavirus-protect-health-safety-americans/ (accessed 3/12/20).
8 Ibid.
9 Letter from President Donald J. Trump on Emergency Determination
Under the Stafford Act, The White House, March 13, 2020, https://www.
whitehouse.gov/briefings-statements/letter-president-donald-j-trumpemergency-determination-stafford-act/ (accessed 3/17/20).
10 CMS Takes Action Nationwide to Aggressively Respond to Coronavirus
National Emergency, Centers for Medicare & Medicaid Services, March 13,
2020, https://www.cms.gov/newsroom/press-releases/cms-takes-actionnationwide-aggressively-respond-coronavirus-national-emergency (accessed
3/17/20); COVID-19 Emergency Declaration Blanket Waivers for Health Care
Providers, Centers for Medicare & Medicaid Services, https://www.cms.gov/
files/document/covid19-emergency-declaration-health-care-providers-factsheet.pdf (accessed 3/18/20).
A PROFESSIONAL DEVELOPMENT JOURNAL for the CONSULTING DISCIPLINES
30 MARCH | APRIL 2020 the value examiner
2. Critical access hospitals (CAHs) are no longer
required to (a) limit the number of beds to 25 or (b)
limit patient length of stay to 96 hours.
3. The requirement that acute care hospitals house
acute care patients and psychiatric patients in
distinct units separate from the rest of the hospital
has been waived.
4. Lost or damaged durable medical equipment (DME)
may be replaced without a face-to-face patient
encounter.
5. Providers already licensed in one state may now
practice in another state without a license.
6. Providers (both physicians and nonphysician
practitioners) may receive expedited temporary
Medicare billing privileges, waived application fees,
and waived background checks.
7. States may apply for section 1135 waivers, which
would allow their Medicaid programs to relax
various restrictions, allowing them to:
a. Reimburse out-of-state licensed providers
under the states Medicaid program;
b. Authorize providers to provide care in
alternative settings; and
c. Suspend prior authorization requirements.11
Recent Federal Reserve Actions
In response to the economic instability, the Fed (a
governmental agency) has also made a number of drastic
moves to offset the greater market panic resulting from
COVID-19:
1. On March 15, 2020, the federal funds rate was
reduced 1 percent to between 0 and 0.25 percent.12
2. On March 15, 2020, the Fed directed the Open
Market Trading Desk (the Desk) to increase holdings
to $500 billion in Treasury securities and $200
billion in mortgage-backed securities in the coming
months.13
11 CMS Approves Medicaid Section 1135 Waivers for 11 Additional States
in Response to COVID-19, Centers for Medicare & Medicaid Services, https://
www.cms.gov/newsroom/press-releases/cms-approves-medicaid-section1135-waivers-11-additional-states-response-covid-19 (accessed 3/27/20).
12 Transcript of Chair Powells Press Conference Call, Federal Reserve
Board, March 15, 2020, https://www.federalreserve.gov/mediacenter/files/
FOMCpresconf20200315.pdf (accessed 3/17/20).
13 Statement Regarding Treasury Securities, Agency Mortgage-Backed
3. On March 17, 2020, a lending facility was established
to support short-term commercial debt markets
(similar to what was used during the Great
Recession).14
These unprecedented measures are the most aggressive since
the Great Recession, the most significant economic downturn
since the Great Depression, which lasted from December
2007 to June 2009.15 Subsequently, on March 23, 2020, the
Fed announced additional, broader measures, including:
1. Removal of the March 15 limit on the purchase of
treasury securities and mortgage-backed securities.
The Desk will make purchases in the amounts
needed to support smooth market functioning and
effective transmission of monetary policy to the
broader economy.
2. Establishment of new credit programs to support up
to $300 billion in financing to employers, consumers,
and businesses.
3. Establishment of two facilities to support credit to
large employersthe Primary Market Corporate
Credit Facility, to provide new bond and loan
issuance, and the Secondary Market Corporate
Credit Facility, to provide liquidity for outstanding
corporate bonds.
4. Establishment of the Term Asset-Backed Securities
Loan Facility to support credit to consumers and
businesses.
5. Expansion of the Money Market Mutual Fund
Liquidity Facility to include additional securities,
including municipal variable rate demand notes and
bank certificates of deposit, in order to facilitate the
flow of credit to municipalities.
6. Expansion of the Commercial Paper Funding Facility
to include high-quality, tax-exempt commercial
paper and reduction of facility pricing.16
Securities, and Repurchase Agreement Operations, Federal Reserve Bank of
New York, March 15, 2020, https://www.newyorkfed.org/markets/opolicy/
operating_policy_200315 (accessed 3/17/20).
14 Federal Reserve Board announces establishment of a Commercial
Paper Funding Facility (CPFF) to support the flow of credit to households
and businesses, Federal Reserve Board, March 17, 2020, https://www.
federalreserve.gov/newsevents/pressreleases/monetary20200317a.htm
(accessed 3/17/20).
15 Jim Chappelow, The Great Recession, Investopedia, March 10, 2020,
https://www.investopedia.com/terms/g/great-recession.asp (accessed 3/18/20).
16 Federal Reserve announces extensive new measures to support the
A PROFESSIONAL DEVELOPMENT JOURNAL for the CONSULTING DISCIPLINES
the value examiner MARCH | APRIL 2020 31
Despite these measures, financial market conditions have
remained volatile:17
1. As of March 16, 2020, the Dow Jones Industrial
Average, the Standard and Poors 500 (S&P 500),
and the Nasdaq indices have all entered bear market
territory (a fall of more than 30 percent from recent
highs).18
2. Selloffs in the S&P 500 have triggered multiple
trading halts.
3. All 11 sectors of the S&P 500 have seen considerable
stock price declines.
4. Stocks of airline and cruise industries have tumbled
more than 20 percent.
5. International financial markets have seen precipitous
declines.
6. Most multinational corporations project a decline in
earnings due to the pandemic.
7. The U.S. dollar has surged against all major currencies,
an indication of stressful market periods.19
8. A record number of Americans, 5.25 million, filed
for unemployment benefits the week ending April
11, 2020.20 The total number of Americans filing
for unemployment benefits exceeds 22 million, the
greatest since the Great Depression.21
Valuation Implications
The financial market conditions above will impact valuations
performed on or after December 31, 2019.22 Previous Black
Swan Events, i.e., an unpredictable event that is beyond
economy, Federal Reserve Board, March 23, 2020, https://www.federalreserve.
gov/newsevents/pressreleases/monetary20200323b.htm (accessed 3/26/20).
17 Caitlin Ostroff, Joanne Chiu, and Caitlin McCabe, Stocks Plunge 10% in
Dows Worst Day Since 1987, The Wall Street Journal, March 12, 2020, https://
www.wsj.com/articles/global-stocks-follow-u-s-markets-lower-11583975524
(accessed 3/12/20); William L. Watts, Stocks Plunge at Opening Bell,
Triggering Trading Halt, Marketwatch, March 16, 2020, https://www.
marketwatch.com/story/stocks-plunge-at-opening-bell-triggering-tradinghalt-2020-03-16 (accessed 3/16/20).
18 Caitlin McCabe, Anna Hirtenstein, and Chong Koh Ping, Dow Plummets
Nearly 3,000 Points as Virus Fears Spread, Wall Street Journal, March 16,
2020, https://www.wsj.com/articles/stocks-dow-slide-after-fed-slashes-rates11584310328?mod=article_inline (accessed 3/17/20).
19 Caitlin Ostroff and Joe Wallace, Dollar Surges as Investors Seek Shelter
From Market Disruption, Wall Street Journal, March 17, 2020, https://
www.wsj.com/articles/dollar-surges-as-investors-seek-shelter-from-marketdisruption-11584447525 (accessed 3/17/20).
20 Unemployment Insurance Weekly Claims, Department of Labor, April
16, 2020, https://www.dol.gov/ui/data.pdf (accessed 4/17/20).
normal expectations for a situation and has potentially
severe consequences (such as the Great Recession),23 as well
as evaluation of current events and market conditions, can
help provide guidance for the impact upon the valuation of
healthcare enterprises, assets, and services.
Valuation Approaches for Healthcare Enterprises, Assets,
and Services
The impact of the financial market conditions above on the
valuation of healthcare enterprises, assets, and services will
partially depend on the valuation approach utilized. The
three general valuation approaches are:
1. Income approach
Valuation methods under the income approach seek the
present value of anticipated future economic benefits that will
accrue to the willing buyer of the business, asset, or service.
In addition to estimating the future economic benefits of
post-transaction ownership, an appropriate discount rate
risk-adjusted for the property interestby which the benefits
are discounted to present value, must also be developed.
2. Market approach
Valuation methods under the market approach are premised
on the foundation that actual transactions of similar property
interests guide value. The efficient market hypothesis posits
that prices derived from well-functioning, publicly traded
markets are reflective of all pertinent information available
to the participants in the market, i.e., a price derived from
market transactions represents the market consensus present
value of the expected future economic benefit to be received
from the ownership of the enterprise, asset, or service by a
willing buyer.
3. Asset/cost approach
Valuation methods under the asset/cost approach seek an
indication of value by determining the cost of reproducing or
replacing an asset or providing a service.
No matter which valuation methodology is selected,
economic value is quantified as the expectation of future
21 U.S. now has 22 million unemployed, wiping out a decade of job
gains, Washington Post, April 16, 2020, https://www.washingtonpost.com/
business/2020/04/16/unemployment-claims-coronavirus/ (accessed 4/17/20).
22 Lari Masten, Business Valuation ConsiderationsLiving with
COVID-19, March 25, 2020, https://www.linkedin.com/pulse/businessvaluation-considerations-living-covid-19-lari-masten- (accessed 3/26/20).
23 Jim Chappelow, Black Swan, Investopedia, March 11, 2020, https://www.
investopedia.com/terms/b/blackswan.asp (accessed 3/26/20).
A PROFESSIONAL DEVELOPMENT JOURNAL for the CONSULTING DISCIPLINES
32 MARCH | APRIL 2020 the value examiner
economic benefit to be derived from the ownership or receipt
of the property or service, respectively.
Impact on the Valuation of Healthcare Enterprises and
Assets
Hospitals and other healthcare enterprises will see significant
financial impacts from the cancellations of financially vital
procedures. In a recent survey of orthopedic surgeons,
interventional cardiologists, and anesthesiologists, 23 percent
of responding physicians noted an increase in deferrals or
cancellations of procedures, and 55 percent of responding
physicians expected that deferrals and cancellations will
continue to increase.24 While cancellations of elective
procedures have been primarily initiated by patients, the
need for additional inpatient capacity at healthcare facilities
could drive a further reduction in elective procedures,25
especially given the direction from the CDC that hospitals
in affected regions cancel non-urgent procedures for an
indefinite time26 and the recommendation from professional
societies, such as the American College of Surgeons, that
hospitals be prepared to call off all elective surgeries during
the pandemic.27 Cancellations of profitable cardiac and
orthopedic elective surgeries will undoubtedly hurt hospital
margins. In addition to the loss of revenue from elective
procedures, there will also be increased costs related to space,
supplies, and staffing needed to respond to COVID-19 cases.
According to S&P Global Ratings, hospitals could see up to
a 20 percent decline in admissions for up to six months.28
S&P Global Ratings has lowered its financial outlook for
hospital companies LifePoint and Tenet Healthcare due to
the pandemic and the effects on revenue.29
These factors could lead to a negative impact on the
short-term economic benefits that would be derived from
ownership in healthcare enterprises and assets, even with
current legislative actions.
The long-term impact of the COVID-19 outbreak on
U.S. economic growth and the U.S. healthcare industry
is currently uncertain. This uncertainty may also present
significant opportunities for healthcare providers, especially
for those providing telehealth services.30 In fact, the
temporary rollback of regulations has increased demand for
telemedicine services 10- to 20-fold.31
In addition to adoption and provision of telehealth
services, there is an increase in the use of additional tools
and technologies to help manage patient outcomes, such
as remote clinical observation and disease management,
improved communication tools, self-service diagnostics
and self-care tools, predictive analytics and knowledge
management, artificial intelligence, informational chatbots,
cross-industry collaborations, and innovative care models.32
Those companies and providers that can make this transition,
or already have, may (1) differentiate themselves from their
competition and guideline comparables (which may lead to
a higher indication of value under market-based methods);
or (2) provide enhanced economic benefit of ownership
with reduced uncertainty (which may increase value under
The long-term impact of the
COVID-19 outbreak on U.S. economic
growth and the U.S. healthcare
industry is currently uncertain.
24 Tara Bannow, Doctors report canceled procedures amid COVID-19,
Modern Healthcare, March 11, 2020, https://www.modernhealthcare.com/
providers/doctors-report-canceled-procedures-amid-covid-19 (accessed
3/16/20).
25 Chad Mulvany, COVID-19 outbreak will negatively impact U.S. hospital
finances, Healthcare Financial Management Association, March 16, 2020,
https://www.hfma.org/topics/accounting-and-financial-reporting/article/
covid-19-outbreak-will-negatively-impact-us-hospital-finances.html (accessed
3/16/20).
26 Melanie Evans and Anna Wilde Mathews, Hospitals Push Off Surgeries
to Make Room for Coronavirus Patients, Wall Street Journal, March 16, 2020,
https://www.wsj. (accessed 3/17/20).
27 COVID-19: Recommendations for Management of Elective Surgical
Procedures, American College of Surgeons, March 13, 2020, https://www.facs.
org/covid-19/clinical-guidance/elective-surgery (accessed 3/17/20).
28 Sara Hansard, Coronavirus Outbreak Threatens to Slash Hospital
Admissions, Bloomberg Law, March 26, 2020, https://news.bloomberglaw.
?context=search&index=4 (accessed 4/16/20).
29 Ibid.
30 Jonathan Manis, Therell be no back to normal for healthcare after
COVID-19 crisis, Modern Healthcare, March 25, 2020, https://www.
modernhealthcare.com/opinion-editorial/therell-be-no-back-normalhealthcare-after-covid-19-crisis?utm_source=modern-healthcare-dailyfinance-wednesday&utm_medium=email&utm_campaign=20200325&utm_
content=article6-headline (accessed 3/27/20).
31 Erin Brodwin and Casey Ross, Surge in patients overwhelms telehealth
services amid coronavirus pandemic, Stat, March 17, 2020, https://
www.statnews.com/2020/03/17/telehealth-services-overwhelmed-amidcoronavirus-pandemic/ (accessed 3/20/20).
32 Therell be no back to normal for healthcare after COVID-19 crisis (see
n. 29).
A PROFESSIONAL DEVELOPMENT JOURNAL for the CONSULTING DISCIPLINES
the value examiner MARCH | APRIL 2020 33
income-based methods); both of which may have a positive
impact on value. In addition, those companies and providers
that have already spent the resources, time, and funds may
increase value under a cost-based method.
Further, it is important to note that when considering incomebased valuation methods, up to 75 percent of the value could
exist in the terminal period (i.e., the period beyond the shortterm discrete projection of economic benefits).33 The longterm impact of the COVID-19 outbreak on the valuation
of healthcare enterprises and assets remains to be seen.
However, the long-term prospects of those companies that
are positioned to deliver care in a high-quality, cost-effective
manner in the post-COVID-19 world may outweigh any
short-term negative impact on valuations from COVID-19.
Impact on the Valuation of Healthcare Services
The majority of compensation arrangements have not factored
in compensation during extreme public health crises such as
the current COVID-19 outbreak. Regulatory guidance will
continue to change around compensation arrangements that
are revised or entered into during and after the outbreak.
Currently, there is strong demand for essential services
in the emergency departments and intensive care units at
the epicenter of the COVID-19 outbreak, and hospitals
are attempting to redeploy specialists who do not typically
treat infectious diseases to meet the excess demand.34 There
may be a need to change compensation arrangements to
provide payment to these providers for working extra hours
and facing additional risk. The amount of hazard pay that
providers would qualify for would depend upon the selection
of an appropriate proxy for the determination of the hazard
pay premium and would likely vary on a case-by-case basis
as some providers may already work in inherently dangerous
environments and some amount of compensation may already
be factored into existing arrangements. Certain qualitative
factors may also impact the necessity for hazard pay, such
as situations where there is insufficient personal protective
equipment for providers, which would require providers to
reuse equipment and increase risk of infection.35
Physicians and nonphysician providers delivering
nonessential services under provider services agreements
(PSA) will likely experience a near-term decline in
productivity due to the limitation or cancellation of
elective procedures. Hospitals may consider converting
affected specialists to a fixed salary or stipends to
temporarily stabilize their income and minimize the
impact to these specialists.
On March 30, 2020, CMS published Blanket Waivers of
Section 1877(g) of the Social Security Act, wherein the HHS
Secretary waived certain requirements under the Stark Law
(subject to certain conditions), including:
1. Remuneration between an entity and a physician (or
the physicians immediate family member) that is
above or below fair market value for:
a. services personally performed by the
physician (or the immediate family member
of the physician) to the entity;
b. items or services purchased by the entity
from the physician (or the immediate family
member of the physician);
c. The use of premises or for items or services
purchased, medical staff incidental benefits;
d. Nonmonetary compensation that surpasses
the current Stark Law limit of $300 per year;
and
e. Remuneration resulting from a loan with an
interest rate below fair market value.
2. Rental charges between an entity and a physician
(or the physicians immediate family member) that
is above or below fair market value for the lease of
office space or equipment.36
CMS provided specific examples wherein these blanket
waivers may apply, including a hospital compensating
a physician above the contracted rate in recognition of
particularly hazardous or challenging environments.37
33 Shannon P. Pratt and Roger J. Grabowski, Cost of Capital: Applications
and Examples, 4th ed. (Hoboken, NJ: John Wiley & Sons, 2010), 34.
34 Tara Bannow and Maria Castellucci, Hospitals redeploy specialists to
COVID-19 front lines, Modern Healthcare, March 30, 2020, https://www.
modernhealthcare.com/hospitals/hospitals-redeploy-specialists-covid-19-
front-lines (accessed 3/30/20).
35 Matthew Wetzel, Stephen Bucci, and Jason Ruchaber, Fraud and
Abuse: Impact of COVID-19 on Health Care Fair Market Value, March 30,
2020, in AHLAs Speaking of Health Law, podcast, https://www.buzzsprout.
(accessed 3/30/20).
36 Note that these waivers are retroactive to March 1, 2020. Blanket
Waivers of Section 1877(g) of the Social Security Act Due to Declaration of
COVID-19 Outbreak in the United States as a National Emergency, Centers
for Medicare & Medicaid Services, https://www.cms.gov/files/document/
covid-19-blanket-waivers-section-1877g.pdf (accessed 3/31/20).
37 Ibid.
A PROFESSIONAL DEVELOPMENT JOURNAL for the CONSULTING DISCIPLINES
34 MARCH | APRIL 2020 the value examiner
While these waivers provide needed relief to healthcare
providers, this does not eliminate the need for a fair market
value analysis in order to comply with fraud and abuse
laws. Fair market value of these arrangements will vary on
an individual basis and adequate documentation for the
necessity of these arrangements will reduce regulatory risks
should the arrangement be subject to scrutiny in the future.38
Further, documenting the commercial reasonableness of
these arrangements may prove vital to substantiating the
extraordinary circumstances of the change in compensation,
as a commercial reasonableness opinion may serve to set
forth the qualitative aspects of such an arrangement and
provide the reasoning behind compensation changes.
In addition to the above, existing pay-for-performance
compensation models may require normalizing adjustments
for the period impacted by COVID-19.
Future physician compensation arrangements will need
to take into consideration normalizing adjustments to
industry normative benchmark compensation data for
2020. Some healthcare systems are temporarily reducing
nonessential physician compensation, which may impact the
compensation reported in that data.39
Conclusion
While the focus of healthcare providers and regulators is,
appropriately, on the access to and delivery of care to those
impacted by the COVID-19 outbreak, the regulatory scrutiny
related to fraud and abuse issues will persist. This current
uncertainty creates a plausible scenario wherein a valuation
professional may be required to deviate from industry
normative benchmark data to account for those specific facts
and circumstances related to a given transaction. As a result,
valuation professionals opining on these transactions should
utilize an evidence-driven methodology that includes both
qualitative and quantitative assessments of the specific facts
and circumstances related to the transaction, document their
consideration of these facts and circumstances, and articulate
their ultimate applicability to the transaction in support of
their opinions.
Todd A. Zigrang, MBA, MHA, FACHE,
CVA, ASA, is president of Health Capital
Consultants, where he focuses on the areas of
valuation and financial analysis for hospitals
and other healthcare enterprises. Mr.
Zigrang has significant physician-integration
and financial analysis experience and has
participated in the development of a physician
owned, multispecialty management service organization and
networks involving a wide range of specialties, physician
owned hospitals, as well as several limited liability companies
for acquiring acute care and specialty hospitals, ASCs, and
other ancillary facilities. Email: [email protected].
Jessica L. Bailey-Wheaton, Esq., serves as
vice president and general counsel of Health
Capital Consultants, where she conducts
project management and consulting services
related to the impact of both federal and
state regulations on healthcare exempt
organization transactions, and provides
research services necessary to support
certified opinions of value related to the fair market value
and commercial reasonableness of transactions related to
healthcare enterprises, assets, and services. Email: jbailey@
healthcapital.com.
VE
While these waivers provide needed
relief to healthcare providers, this
does not eliminate the need for a
fair market value analysis in order to
comply with fraud and abuse laws.
38 Patsy Powers, Physician compensation relationships in the time of
COVID-19, Chambers and Partners, March 26, 2020, https://chambers.
com/articles/physician-compensation-relationships-in-the-time-of-covid-19
(accessed 4/30/2020).
39 Intermountain cutting doc pay as COVID-19 impacts service lines,
Modern Healthcare, March 28, 2020, https://www.modernhealthcare.com/
physician-compensation/intermountain-cutting-doc-pay-covid-19-impactsservice-lines (accessed 3/30/20).
Copyright of Value Examiner is the property of National Association of Certified Valuation
Analysts and its content may not be copied or emailed to multiple sites or posted to a listserv
without the copyright holder’s express written permission. However, users may print,
download, or email articles for individual use.
Are you busy and do not have time to handle your assignment? Are you scared that your paper will not make the grade? Do you have responsibilities that may hinder you from turning in your assignment on time? Are you tired and can barely handle your assignment? Are your grades inconsistent?
Whichever your reason is, it is valid! You can get professional academic help from our service at affordable rates. We have a team of professional academic writers who can handle all your assignments.
Students barely have time to read. We got you! Have your literature essay or book review written without having the hassle of reading the book. You can get your literature paper custom-written for you by our literature specialists.
Do you struggle with finance? No need to torture yourself if finance is not your cup of tea. You can order your finance paper from our academic writing service and get 100% original work from competent finance experts.
Computer science is a tough subject. Fortunately, our computer science experts are up to the match. No need to stress and have sleepless nights. Our academic writers will tackle all your computer science assignments and deliver them on time. Let us handle all your python, java, ruby, JavaScript, php , C+ assignments!
While psychology may be an interesting subject, you may lack sufficient time to handle your assignments. Don’t despair; by using our academic writing service, you can be assured of perfect grades. Moreover, your grades will be consistent.
Engineering is quite a demanding subject. Students face a lot of pressure and barely have enough time to do what they love to do. Our academic writing service got you covered! Our engineering specialists follow the paper instructions and ensure timely delivery of the paper.
In the nursing course, you may have difficulties with literature reviews, annotated bibliographies, critical essays, and other assignments. Our nursing assignment writers will offer you professional nursing paper help at low prices.
Truth be told, sociology papers can be quite exhausting. Our academic writing service relieves you of fatigue, pressure, and stress. You can relax and have peace of mind as our academic writers handle your sociology assignment.
We take pride in having some of the best business writers in the industry. Our business writers have a lot of experience in the field. They are reliable, and you can be assured of a high-grade paper. They are able to handle business papers of any subject, length, deadline, and difficulty!
We boast of having some of the most experienced statistics experts in the industry. Our statistics experts have diverse skills, expertise, and knowledge to handle any kind of assignment. They have access to all kinds of software to get your assignment done.
Writing a law essay may prove to be an insurmountable obstacle, especially when you need to know the peculiarities of the legislative framework. Take advantage of our top-notch law specialists and get superb grades and 100% satisfaction.
We have highlighted some of the most popular subjects we handle above. Those are just a tip of the iceberg. We deal in all academic disciplines since our writers are as diverse. They have been drawn from across all disciplines, and orders are assigned to those writers believed to be the best in the field. In a nutshell, there is no task we cannot handle; all you need to do is place your order with us. As long as your instructions are clear, just trust we shall deliver irrespective of the discipline.
Our essay writers are graduates with bachelor's, masters, Ph.D., and doctorate degrees in various subjects. The minimum requirement to be an essay writer with our essay writing service is to have a college degree. All our academic writers have a minimum of two years of academic writing. We have a stringent recruitment process to ensure that we get only the most competent essay writers in the industry. We also ensure that the writers are handsomely compensated for their value. The majority of our writers are native English speakers. As such, the fluency of language and grammar is impeccable.
There is a very low likelihood that you won’t like the paper.
Not at all. All papers are written from scratch. There is no way your tutor or instructor will realize that you did not write the paper yourself. In fact, we recommend using our assignment help services for consistent results.
We check all papers for plagiarism before we submit them. We use powerful plagiarism checking software such as SafeAssign, LopesWrite, and Turnitin. We also upload the plagiarism report so that you can review it. We understand that plagiarism is academic suicide. We would not take the risk of submitting plagiarized work and jeopardize your academic journey. Furthermore, we do not sell or use prewritten papers, and each paper is written from scratch.
You determine when you get the paper by setting the deadline when placing the order. All papers are delivered within the deadline. We are well aware that we operate in a time-sensitive industry. As such, we have laid out strategies to ensure that the client receives the paper on time and they never miss the deadline. We understand that papers that are submitted late have some points deducted. We do not want you to miss any points due to late submission. We work on beating deadlines by huge margins in order to ensure that you have ample time to review the paper before you submit it.
We have a privacy and confidentiality policy that guides our work. We NEVER share any customer information with third parties. Noone will ever know that you used our assignment help services. It’s only between you and us. We are bound by our policies to protect the customer’s identity and information. All your information, such as your names, phone number, email, order information, and so on, are protected. We have robust security systems that ensure that your data is protected. Hacking our systems is close to impossible, and it has never happened.
You fill all the paper instructions in the order form. Make sure you include all the helpful materials so that our academic writers can deliver the perfect paper. It will also help to eliminate unnecessary revisions.
Proceed to pay for the paper so that it can be assigned to one of our expert academic writers. The paper subject is matched with the writer’s area of specialization.
You communicate with the writer and know about the progress of the paper. The client can ask the writer for drafts of the paper. The client can upload extra material and include additional instructions from the lecturer. Receive a paper.
The paper is sent to your email and uploaded to your personal account. You also get a plagiarism report attached to your paper.
GET A PERFECT SCORE!!! 
Delivering a high-quality product at a reasonable price is not enough anymore.
That’s why we have developed 5 beneficial guarantees that will make your experience with our service enjoyable, easy, and safe.
You have to be 100% sure of the quality of your product to give a money-back guarantee. This describes us perfectly. Make sure that this guarantee is totally transparent.
Read moreEach paper is composed from scratch, according to your instructions. It is then checked by our plagiarism-detection software. There is no gap where plagiarism could squeeze in.
Read moreThanks to our free revisions, there is no way for you to be unsatisfied. We will work on your paper until you are completely happy with the result.
Read moreYour email is safe, as we store it according to international data protection rules. Your bank details are secure, as we use only reliable payment systems.
Read moreBy sending us your money, you buy the service we provide. Check out our terms and conditions if you prefer business talks to be laid out in official language.
Read more