Mitigate Risk.
Strengthen Governance.
Independent fair market value (FMV) and commercial reasonableness assessments help health care organizations structure physician compensation with clarity, confidence, and regulatory defensibility.
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When Compensation Risk Becomes Organizational Risk
Physician compensation arrangements sit at the intersection of strategy, regulation, and public scrutiny. Even well-intentioned financial relationships can create significant exposure if FMV and commercial reasonableness standards are not clearly documented, consistently applied, and defensible.
At the same time, organizations must remain competitive in recruiting and retaining physicians in a tight labor market—often while redesigning compensation models to support new care delivery strategies and evolving work effort expectations. Without objective analysis and disciplined oversight, compensation decisions can create unnecessary financial, operational, and reputational risk.
Physician Compensation Balancing Act
Partnering with SullivanCotter
Compensation Structures That Are Defensible By Design
SullivanCotter brings decades of health care-specific experience, market-leading physician compensation data, and deep regulatory insight to help organizations evaluate and structure physician financial relationships with confidence. Through independent FMV and commercial reasonableness assessments, we help leaders proactively mitigate risk related to Stark, Anti-Kickback, and IRS requirements.
Our work goes beyond issuing opinions. We partner with compliance, legal, finance, HR, and physician leadership to support consistent decision-making, strengthen internal governance processes, and ensure compensation structures are commercially sound, market-informed, and built to withstand scrutiny.
We review the following:
What is the business purpose of the arrangement?
Community Need
Timely Access
Licensure/Regulatory
Obligations
Charity Care
Clinical Quality
Network Adequacy
Is the arrangement sensible?
Focused on the structure of the compensation arrangement
Contract terms compared to typical physician arrangement practice
If applicable:
Job description; bona fide need for leadership services
Not duplicative of other services
Time documentation or performance goals
If applicable:
Regulatory/licensure obligation met
Call burden
Compensation when activated
How We Help
SullivanCotter provides independent reviews and advisory support to help organizations evaluate physician compensation arrangements and strengthen defensibility across the enterprise.
FMV and Commercial Reasonableness Reviews & Opinions (organization-wide and individual arrangements)
Value-Based Compensation Reviews
On-Call Pay and Telemedicine Reviews
Co-Management Valuations
Physician Compensation Leadership Reviews
Board and Leadership Education
FMV Training and Advisory Support
Compensation Governance Process and Committee Charter Development
Data That Supports Defensible Decisions
Explore SullivanCotter’s comprehensive survey data—including physician compensation and productivity benchmarks—to support FMV assessments, commercial reasonableness documentation, and compliant compensation design.
Physician Compensation and Productivity Survey
As health care organizations seek to optimize care delivery and improve performance, effectively managing workforce size, shape, and complexity remains key. This survey helps organizations understand how their workforce size, distribution, and cost compare to market practices.
Pulse on the Industry
Stay current with SullivanCotter’s latest insights on physician compensation compliance, evolving regulatory expectations, value-based care compensation trends, and governance practices that reduce risk.
Other Services To Explore
FMV and commercial reasonableness assessments are most effective when supported by strong compensation strategy and governance practices. Partner with SullivanCotter to strengthen internal capabilities in compensation planning, benchmarking, and workforce data management.
Let’s Architect Your Solution
Ready to ensure your physician compensation arrangements are defensible, compliant, and aligned with your organizational strategy? Contact SullivanCotter to put objective insight behind your most critical compensation decisions.
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