
In an environment of increasing regulation and enforcement
activities by the Office of Inspector General (OIG), hospital
executives find themselves dealing with compliance issues related to
leasing office space to or from physicians. Additionally,
hospitals often miss collecting revenue in their role as landlord or
overpay rental expenses in their position of tenant. While
hospitals theoretically have policy and procedures in place, few
practically or consistently apply them. Meadows & Ohly
provides specialized expertise and industry knowledge to lease
auditing and compliance review.
COMPLIANCE REVIEW
> Analysis of office leases and amendments between the hospital
and physicians for accuracy and compliance
with Stark and
anti-kickback regulations.
>
Evaluation of hospital processes and controls used to manage
leasing activities and administer leases.
>
Evaluation of documented leasing guidelines and the procedures
used to implement those guidelines.
>
Review fair market value documentation used to establish and
update leasing guidelines.
LEASE AUDITING
> Lease files: Are documents properly executed? Are leases and
amendments current? Are subleases or
timeshare arrangements
properly documented? Are renewals completed on a timely basis?
>
Verify landlord charges: Base rent, escalations, operating
expenses, common area maintenance (CAM), real
estate taxes,
utility submeter charges, biomedical waste, overtime HVAC, etc…
>
Audit account receivables and collection practices.
> Review lease administration practices and procedures for
effectiveness and consistency.
LEASE ADMINISTRATION AND RENT COLLECTIONS
> Maintain all lease files and rent rolls.
> Prepare invoices for all landlord lease charges.
> Manage account receivables and collection process.
> Minimize potential hospital/physician conflict over rent issues.
> Lease Auditing and Compliance Review services are offered on
hourly, fixed fee and/or contingency bases.
> Lease
Administration and Rent Collections are offered on a contingency
basis.