POLICY AND PROCEDURE. Policy # GA Fair Market Valuation Page 1 of 7

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1 Policy # GA Fair Market Valuation Page 1 of 7 Manual: General Administrative Sponsor: Vice President, Chief Compliance/Privacy Officer Approver: Board of Commissioners Regulation/Standards: Revision Date (s) 01/2009, 05/2012, 03/2014 Review Date (s) Origination Date: 04/2007 Distribution: System-wide I. Purpose The purpose of this policy is to provide direction as to Broward Health's process of determining whether a transaction with a physician or other referral source is made at fair market value and is commercially reasonable in order to comply with the Stark Law and the Anti-Kickback Statute. II. Definitions Fair Market Value (FMV): means the value in arm s length transactions, consistent with the general market value. General market value means the price that an asset would bring, or the compensation that would be included in a service agreement, as the result of a bona fide bargaining between well-informed parties to the agreement who are not otherwise in a position to generate business for the other party at the time of the service agreement. Immediate Family Member: means spouse; birth or adoptive parent, child or sibling; stepparent, stepchild, stepbrother or stepsister; father in law, mother in law, son in law, daughter in law, brother in law, or sister in law; grandparent or grandchild; and spouse of a grandparent or grandchild. Physician: means a doctor of medicine or osteopathy, a doctor of dental surgery or dental medicine, a doctor of podiatric medicine, a doctor of optometry or a chiropractor. Referral Source: means a physician, a physician's immediate family member, an entity that is owned or controlled by a physician or a physician's immediate family member or any non-physician who is in a position to make a referral or control referrals made by another person to a Broward Health region or entity. Work Relative Value Unit (WRVU): means work relative value units using the Centers for Medicare & Medicaid Services (CMS) scale (most recent edition), as reported by one or more national survey sources. Physician compensation may be set, in whole or in

2 Policy #: GA Fair Market Valuation Page 2 of 7 part, using WRVUs as long as the payment per/wrvu never exceeds the 75th percentile. TYPES OF FAIR MARKET VALUE STUDIES Basic Fair Market Value Study (Basic FMV Study): means a fair market value analysis performed internally by Broward Health's Corporate Compensation & Benefits Department. A Basic FMV Study may be relied upon by Broward Health when the total compensation or price for a single transaction or cumulatively with all other similar transactions with a physician or referral source for personal services is below the 75 th percentile of the total compensation or price listed in acceptable market studies or surveys. Enhanced Fair Market Value Study (Enhanced FMV Study): means a fair market value analysis performed by an independent third party. An Enhanced FMV Study must be obtained when the total compensation for a single transaction or cumulatively with all other similar transactions with a physician or referral source for personal services is at or exceeds the 75 th percentile of the total compensation or price listed in acceptable market studies or surveys. The independent third party must be engaged by legal counsel and must be asked to opine on whether the transaction involves fair market value compensation and is commercially reasonable. The selection of the independent third party to prepare an enhanced FMV study shall be done in accordance with Policy GA Selection of Professional Physician & Consulting Services Contractors, as amended. Equipment/Space Fair Market Value Study (Equipment/Space FMV Study): means a fair market value analysis of the price for the sale or lease of equipment or office space by an independent third party. The independent third party must be engaged by legal counsel and must be asked to opine on whether the transaction involves fair market value compensation for the sale or lease of the equipment or space, as applicable, and is commercially reasonable. Personal Property Fair Market Value Study (Personal Property FMV Study): means a fair market value analysis of a medical practice s assets performed by an independent third party. The Personal Property FMV Study must evaluate the value of a medical practice s assets as of the time of closing using recognized valuation methodologies and reasonable economic and market assumptions. The independent third party must be engaged by legal counsel and must be asked to opine on whether the transaction involves fair market value compensation for the assets and is commercially reasonable.

3 Policy #: GA Fair Market Valuation Page 3 of 7 III. Policy Any transaction with a physician or referral source shall (i) not reflect the volume or value of referrals, (ii) be commercially reasonable, and (iii) be consistent with the fair market value of any goods or services exchanged between Broward Health and the physician or referral source, unless the General Counsel authorizes an exception, e.g., in the case of a physician recruitment arrangement. It is the policy of Broward Health to require a fair market value opinion in connection with any transaction between Broward Health and any physician or referral source, in order to comply with Federal or state laws and regulations, including the Stark Law and the Anti-Kickback Statute. Application 1. If a physician, or an immediate family member of a physician as defined above, is to provide or purchase personal services from Broward Health (or one of its affiliates), a Basic FMV Study must be obtained for such contracts, including employment agreements, independent contractor arrangements, e.g., agreements related to medical director, committee, on-call or PPUC services EXCEPT when an Enhanced FMV Study is required as set forth in Procedure section 3 below. 2. An Equipment/Space FMV Study must be obtained before space, equipment or other property is sold or leased by Broward Health (or one of its affiliates) to or from a physician or an immediate family member of a physician as defined herein. 3. A Personal Property FMV Study must be obtained before Broward Health (or one of its affiliates) buys or sells medical practice assets to or from a physician or an immediate family member of a physician as defined herein. 4. All employed physician contracts must have capped total compensation. Compensation caps are set at percentile thresholds based on current and projected productivity to ensure compliance to fair market value standards as reflected in acceptable market studies or surveys. Compensation caps must not exceed the 90th percentile compensation for the year the contract is initiated. Contracts that have recommended compensation caps over the 90th percentile of the initial contract year must be supported by evidence of satisfactory quality indicators, patient satisfaction scores, and coding compliance to qualify for Board review and possible approval. IV. Procedure Prior to executing any transaction with a physician or referral source, the Broward Health region/facility must assure that such compensation is commercially reasonable and consistent with the fair market value for the items or services acquired or sold in such transaction by securing the appropriate type of FMV Study. At a minimum, the following considerations must be included in any fair market value analysis.

4 Policy #: GA Fair Market Valuation Page 4 of 7 1. General a. Fair Market Defined. The term "fair market value" as used in this policy shall be consistent with the definition provided in this policy. b. Term Covered. An Enhanced FMV Study will have that useful life stated in it by the valuator. With regard to a Basic FMV Study and if no term is noted in an Enhanced FMV Study, it will be assumed that the Study remains accurate for a term equal to the shorter of: i) the term of the subject agreement, as well as for the first 12 months of any subsequent agreement entered within 6 months of the termination off the underlying contract, so long as there has been no material change to the agreement terms or supporting facts and circumstances; or ii) 3 years from the commencement date of the agreement. If the term of a FMV Study has expired on a current contract, a new FMV Study shall be obtained. c. Comprehensive. Any FMV Study must specifically list what is included in the valuation. Items and services included in the valuation must match those provided for in the agreement. d. Consideration of Facts and Circumstances. All FMV Studies should provide a thorough analysis of the facts and circumstances of the underlying transaction in comparison to industry benchmark data. e. Selection of Benchmark Data. Benchmark data includes information on transactions comparable in character, nature and value to the transaction being evaluated. Generally, only data from the same geographic location as the proposed transaction should be considered, unless the transaction is so unique as to necessitate a national or global search, or unless adequate local data is not available. Benchmark data generally should not include transactions between health care facilities and their referral sources. 2. Rental or Lease of Space or Equipment a. Limitations: For rental or lease agreements, in addition to the definition of fair market value provided above, rental agreements between Broward Health and any referral source shall not take into consideration the intended use of the property or the convenience or proximity of the property to the lessor and/or potential referral source in the rental payment amount. b. For other policies and procedures to follow related to space/equipment rentals, consult, e.g., Policy GA Physician Equipment or Space Leases. 3. Personal Service Agreements (including Employment Agreements and Independent Contractor Agreements)

5 Policy #: GA Fair Market Valuation Page 5 of 7 Broward Health's Corporate Compensation and Benefits Department will create upon request a Basic FMV Study in accordance with Paragraph 1 above. The Regional Executives may consult the SVP/COO for obtaining Enhanced FMV Studies under the circumstances described below. If there is any question as to whether an Enhanced FMV Study is necessary, the matter should be resolved in favor of obtaining the Enhanced FMV Study. a. For a Basic FMV Study, benchmark data for total compensation and WRVUs must be based on the average from a minimum of at least 3 nationally recognized surveys including but not limited to: (i) Hay Group; (ii) Hospital and Healthcare Compensation Services; (iii) Medical Group Management Association; (iv) Sullivan, Cotter & Associates, Inc.; (v) American Medical Group Association; or (vi) William M. Mercer, Inc. If an alternate survey source is used, the FMV Study must specifically state the source(s) relied upon and the reasons it was used. b. Prior to executing a personal services agreement with a physician or referral source, all other such agreements with that physician or referral source individual must be analyzed. If it is possible that the aggregate compensation from a single agreement or separate services agreements with the same physician will exceed the 75th percentile national compensation level, based on the average of 3 surveys as described above, Board of Commissioner approval is required, in addition to an Enhanced FMV Study. c. If the proposed compensation is based on a WRVU model and the WRVU is at or greater than the 50 th percentile for compensation or the total compensation is not capped at the 75 th percentile, an Enhanced FMV Study and Board approval is required. d. Combined Equipment Lease and Personal Services Agreement. Where a physician provides the equipment pursuant to a personal service agreement, the values of both the professional services and the equipment should be separately stated and analyzed in the appropriate FMV Study. e. An Enhanced FMV Study is required for all contracts with hospital-based physicians, i.e., radiologists, pathologists, anesthesiologists and ER physicians. f. Retaining Physicians for Broward Health Corporate. When Broward Health retains a physician for a group speaking event, testimony, or another purpose benefiting Broward Health, the hourly rate shall be consistent with fair market value and commercially reasonable. As stated in this policy, a Basic or an Enhanced FMV Study will be conducted as appropriate.

6 Policy #: GA Fair Market Valuation Page 6 of 7 g. Obtaining an Enhanced FMV Study. If an Enhanced FMV Study is necessary, General Counsel must be contacted, and will be responsible for overseeing the process to obtain the Enhanced FMV Study. h. For other policies and procedures to follow related to personal services agreements with physicians, consult, e.g., Policies GA Physician Employment Agreements, GA Personal Service Agreements, GA Physician or Medical Practice Management Services, Business Office Services and Contract Services. 4. Assets When acquiring or divesting the medical practice assets of a physician (see, e.g., Policies GA Medical Practice Asset Acquisitions, and GA Medical Practice Asset Divestitures), Broward Health may not rely on a Basic FMV Study to determine the fair market value. A Personal Property FMV Study by an independent party must be obtained. 5. Tracking System Broward Health s Contracts Administration and Vendor Relations Department must electronically document, track and retain in the Contracts Database the FMV Studies conducted for at least 10 years following the expiration or termination of the subject agreement. The tracking system will detail the following items: a. The name of the physician(s) who are parties to the agreement. b. The type of agreement (e.g., lease of equipment, on-call services, employment, etc.) c. Type of FMV Study d. The name of the Broward region/facility e. The term of the agreement f. The date the Basic/Enhanced FMV Study was issued and its expiration date. V. Related Policies GA Medical Practice Asset Acquisitions GA Medical Practice Asset Divestitures

7 Policy #: GA Fair Market Valuation Page 7 of 7 GA Physician Equipment or Space Leases GA Personal Service Agreements GA Physician Recruitment Agreements GA Physician or Medical Practice Management Services, Business Office Services GA Selection of Professional Physician Consulting Services, Contractors Administration and Interpretation The administration and interpretation of this policy is the responsibility of Broward Health s General Counsel and the Vice President, Chief Compliance/Privacy Officer.

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