[sheet: Summary Dashboard]

[sheet: Summary Dashboard]
Field | Value
Client | Arbor Health Technologies Inc.
Client EIN | 84-3291057
Client NPI (Organizational) | 1497253810
Client HQ Address | 200 Concord Avenue, Suite 400, Cambridge, MA 02138
C&H Matter Number | 1010-00003
Engagement Opened | January 30, 2023
Engagement Closed | July 12, 2023
Responsible Partner | Miriam Calloway
Billing Partner | Joel Strauss
Lead Associate | Christopher Aiken
Working Associate | Amy Whitfield
Source Report | Grayson Whitaker & Associates LLP — Report GW-AHT-2022-Final, dated December 12, 2022
Consultant Principal | Carolyn Fitch
Board Resolution Authorizing Engagement | Resolution No. 2023-01-004, adopted January 24, 2023
Total Arrangements Flagged | 40
High-Risk Arrangements | 17
Moderate-Risk Arrangements | 23
Low-Risk Arrangements (post-review reclassification) | 0
Applicable Statutes | Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); Stark Law (42 U.S.C. § 1395nn); M.G.L. c. 175H, § 3; Conn. Gen. Stat. § 20-7a(d)
AHT FY2022 Net Revenue | $214,300,000
Medicare/Medicaid Revenue (61%) | $130,700,000
Commercial Payer Revenue (39%) | $83,600,000
Total W-2 Employed Physicians | 147
Total IC / Medical Director Arrangements | 38
Total Clinic Locations | 23 (14 MA, 4 CT, 3 RI, 2 NH)
FMV Valuation Firm | Northbridge Valuation Advisors LLC
FMV Appraiser Contact | Sandra Kilpatrick, Managing Director
External Auditor | Halsted Accounting Group LLP
Audit Engagement Partner | Ronald Desmond
PE Sponsor | Ridgeline Capital Partners Fund IV, L.P. (72% equity, acquired January 2021, $185M)
Ridgeline Board Designees | Claudia Sorrento (Managing Director); Marcus Whitmore (Principal)
AHT CEO | Dr. Nathan Ellsworth
AHT General Counsel | Patricia Yamamoto
AHT Chief Compliance Officer | Derek Huang
AHT General Outside Counsel | Westbrook Hale LLP (Elena Marchetti, Partner)
[sheet: Master Inventory]
Arrangement ID | GW Report Item # | Arrangement Category | Counterparty / Physician Name | Arrangement Description | Agreement Date | Annual Value / Compensation | FY2022 Referral Volume | Applicable Statute(s) | Risk Tier — Initial (GW) | Risk Tier — C&H Final | Stark Exception(s) Evaluated | Stark Exception Met? | AKS Safe Harbor(s) Evaluated | AKS Safe Harbor Met? | State Law Implicated | FMV Substantiation Status | Commercial Reasonableness Status | Key Compliance Deficiency | Recommended Remediation Action | Remediation Priority | Responsible AHT Contact | Detailed Analysis Memo Reference | Notes
ARR-001 | GW-H-01 | Third-Party Services — Diagnostic Imaging | Meridian Diagnostics LLC | Per-scan facility access fee ($185/scan) for mobile MRI and advanced diagnostic imaging at 4 AHT clinic locations; Meridian owned by Dr. Franklin Osei (60%) and Gerald Pratt (40%) | March 1, 2021 | $777,000 (4,200 scans × $185) | $2,800,000 | Both (AKS + Stark) | High | High | Space Rental (42 C.F.R. § 411.357(a)); Equipment Rental (42 C.F.R. § 411.357(b)) | No | Space Rental (42 C.F.R. § 1001.952(b)); Equipment Rental (42 C.F.R. § 1001.952(c)) | No | Conn. Gen. Stat. § 20-7a(d) | Deficient | Deficient | Per-scan fee varies with volume of referrals; inconsistent with requirement that rental be set in advance and not vary with volume/value of referrals | Restructure to fixed monthly facility rental at FMV; Northbridge FMV opinion requested; draft restructured agreement prepared and transmitted to Linden & Pryor LLP (Thomas Beckett) | Immediate | Patricia Yamamoto / Derek Huang | Meridian Diagnostics Facility Access Fee — Detailed AKS/Stark Analysis | Meridian address: 88 Trumbull Street, Hartford, CT 06103; EIN: 82-4019673
ARR-002 | GW-H-02 | Third-Party Services — Laboratory | Pinnacle Laboratory Services Inc. | No-cost electronic laboratory interface integrated into ArborConnect under preferred laboratory agreement | June 15, 2020 | $120,000/year (estimated market value; provided at $0) | $1,650,000 | Both (AKS + Stark) | High | High | Non-Monetary Remuneration (42 C.F.R. § 411.357(k)) — $459 CY2023 limit; Indirect Compensation | No | Personal Services (42 C.F.R. § 1001.952(d)) | No | M.G.L. c. 175H, § 3 | Deficient | N/A | Lab interface value ($120,000/year) far exceeds Stark non-monetary remuneration annual limit of $459; constitutes potential remuneration linked to $1.65M in referrals | Convert to FMV license fee arrangement; letter sent to Pinnacle requesting restructuring discussions | Immediate | Derek Huang | Pinnacle Laboratory Services — Detailed AKS/Stark Analysis | Pinnacle address: 1200 Warwick Avenue, Suite 110, Warwick, RI 02886; EIN: 05-6138290
ARR-003 | GW-H-03 | Third-Party Services — Laboratory (CME) | Pinnacle Laboratory Services Inc. | Pinnacle-sponsored CME events for AHT physicians — 4 events in FY2022 totaling $86,000 | June 15, 2020 (under same preferred lab agreement) | $86,000 (FY2022) | $1,650,000 (combined referral volume) | Both (AKS + Stark) | High | High | Non-Monetary Remuneration; Fair Market Value | No | Personal Services | No | M.G.L. c. 175H, § 3 | Deficient | Deficient | CME sponsorship by referral source raises AKS inducement concerns; total value combined with lab interface far exceeds any applicable exception thresholds | Separate CME sponsorship from referral relationship; require independent CME funding or FMV payment for educational services | Immediate | Derek Huang | Pinnacle Laboratory Services — Detailed AKS/Stark Analysis
ARR-004 | GW-H-04 | Conflict of Interest — Ownership/Investment | Dr. Karen Ellsworth (spouse of CEO Dr. Nathan Ellsworth) | 4.2% passive equity interest in Pinnacle Laboratory Services Inc. held by CEO's spouse | N/A | N/A (equity interest, not direct compensation) | $1,650,000 (Pinnacle referral volume) | Both (AKS + Stark) | High | High | Ownership/Investment Exception (42 C.F.R. § 411.356) | Partial — requires analysis of publicly traded / rural provider criteria | Investment Interest Safe Harbor (42 C.F.R. § 1001.952(a)) | Partial | M.G.L. c. 175H, § 3 | N/A | N/A | CEO's spouse holds equity in entity receiving referrals from AHT; creates appearance and potential actuality of improper inducement; conflict of interest disclosure deficient | Require formal conflict-of-interest disclosure; evaluate divestiture or recusal protocols; enhance referral independence safeguards | Immediate | Patricia Yamamoto / Derek Huang | Pinnacle Laboratory Services — Detailed AKS/Stark Analysis
ARR-005 | GW-H-05 | Management Services Arrangement | ConnectiCare Physicians Network, LLC — Practice 1 of 9 | MSA providing billing, coding, practice management, IT to independently owned physician practice; 15% of collected net revenue management fee | Various | $525,889 (estimated 1/9 of $4.73M) | Referrals to AHT ancillary services (lab, imaging, PT) — volume tracked | Both (AKS + Stark) | High | High | Indirect Compensation (42 C.F.R. § 411.354(c)); Personal Services (42 C.F.R. § 411.357(d)) | Partial | Management Contracts (42 C.F.R. § 1001.952(d)) | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending (Northbridge) | Pending | Percentage-based fee (15% of collections) combined with referrals from managed practices to AHT-owned ancillary services creates unbroken chain of financial relationships under Stark indirect compensation analysis; fee may vary with referrals | Restructure to fixed-fee or blended model not varying with referrals to AHT ancillary services; add referral tracking safeguards; use revised MSA template | 30-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis | CPN address: 55 Asylum Street, 7th Floor, Hartford, CT 06103; aggregate managed practice revenue: $31.53M
ARR-006 | GW-H-06 | Medical Director Agreement | Various — Representative High-Risk Medical Director | Medical director stipend; effective average hourly rate of $501.28/hour across 38 arrangements (aggregate $1.92M/year ÷ 3,830.4 hours); above 90th percentile for multiple specialties | Various | $50,526 (average per arrangement: $1.92M ÷ 38) | N/A — referral relationship inherent | Both (AKS + Stark) | High | High | Employment (42 C.F.R. § 411.357(c)); Personal Services (42 C.F.R. § 411.357(d)); Fair Market Value (42 C.F.R. § 411.357(l)) | No | Employment (42 C.F.R. § 1001.952(i)); Personal Services (42 C.F.R. § 1001.952(d)) | No | M.G.L. c. 175H, § 3 | Deficient | Deficient | $501.28/hour effective rate exceeds 90th percentile benchmarks (MGMA, SullivanCotter); insufficient documentation of duties and hours; FMV and commercial reasonableness not substantiated | Restructure compensation to align with FMV per Northbridge opinions; increase documented hours commensurate with compensation; standardize duty descriptions; use revised IC/Medical Director Agreement template | Immediate | Derek Huang / Dr. Nathan Ellsworth | Medical Director Compensation — FMV and Commercial Reasonableness Analysis | Stipend range: $25,000 – $110,000/year; mean hours/month: 8.4
ARR-007 | GW-H-07 | Lakeview Legacy — Physician Employment | Dr. Vivian Chao (former Lakeview managing partner; current AHT Regional Medical Director — Central MA) | Employment agreement assumed in Lakeview Medical Associates, P.C. acquisition (August 15, 2022, $11.4M asset purchase); compensation formula non-compliant | August 15, 2022 (assumed) | Per legacy agreement | N/A | Both (AKS + Stark) | High | High | Employment (42 C.F.R. § 411.357(c)) | No | Employment (42 C.F.R. § 1001.952(i)) | Partial | M.G.L. c. 175H, § 3 | Deficient | Deficient | Missing FMV substantiation; expired term with holdover issues; non-compliant compensation formula | Restate agreement using revised Physician Employment Agreement template; obtain Northbridge FMV opinion; cure holdover deficiency | Immediate | Patricia Yamamoto | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo | Lakeview pre-acquisition revenue: $18.2M ($10.9M Medicare/Medicaid ≈ 60%); Lakeview EIN: 04-3782145; Westbrook Hale LLP (Elena Marchetti) handled original acquisition
ARR-008 | GW-H-08 | Lakeview Legacy — Medical Director Agreement #1 | Lakeview Legacy Physician (assumed) | Medical director agreement assumed in acquisition; annual stipend $45,000 | August 15, 2022 (assumed) | $45,000 | N/A | Both (AKS + Stark) | High | High | Personal Services (42 C.F.R. § 411.357(d)); Fair Market Value (42 C.F.R. § 411.357(l)) | No | Personal Services (42 C.F.R. § 1001.952(d)) | No | M.G.L. c. 175H, § 3 | Deficient | Deficient | No FMV substantiation; expired term; duties not adequately specified | Restructure using revised IC/Medical Director Agreement template; obtain Northbridge FMV opinion | Immediate | Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-009 | GW-H-09 | Lakeview Legacy — Medical Director Agreement #2 | Lakeview Legacy Physician (assumed) | Medical director agreement assumed in acquisition; annual stipend $60,000 | August 15, 2022 (assumed) | $60,000 | N/A | Both (AKS + Stark) | High | High | Personal Services; Fair Market Value | No | Personal Services | No | M.G.L. c. 175H, § 3 | Deficient | Deficient | Same deficiencies as ARR-008 | Same remediation as ARR-008 | Immediate | Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-010 | GW-H-10 | Lakeview Legacy — Medical Director Agreement #3 | Lakeview Legacy Physician (assumed) | Medical director agreement assumed in acquisition; annual stipend $72,000 | August 15, 2022 (assumed) | $72,000 | N/A | Both (AKS + Stark) | High | High | Personal Services; Fair Market Value | No | Personal Services | No | M.G.L. c. 175H, § 3 | Deficient | Deficient | Same deficiencies as ARR-008; highest stipend of three Lakeview medical director agreements | Same remediation as ARR-008 | Immediate | Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-011 | GW-H-11 | Lakeview Legacy — Office Lease (Worcester) | Landlord — Worcester clinic location | Office lease at 75 Belmont Street, Worcester, MA 01605 assumed in acquisition | August 15, 2022 (assumed) | Per lease terms | N/A | Both (AKS + Stark) | High | High | Space Rental (42 C.F.R. § 411.357(a)) | Partial | Space Rental (42 C.F.R. § 1001.952(b)) | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | Lease terms may not meet space rental exception/safe harbor requirements (FMV rent, fixed term, exclusive use); FMV not substantiated post-acquisition | Obtain Northbridge FMV appraisal; amend or restate lease using revised Office Space Lease template | 30-Day | Patricia Yamamoto | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-012 | GW-H-12 | Lakeview Legacy — Office Lease (Shrewsbury) | Landlord — Shrewsbury clinic location | Office lease at 310 Main Street, Suite 2A, Shrewsbury, MA 01545 assumed in acquisition | August 15, 2022 (assumed) | Per lease terms | N/A | Both (AKS + Stark) | High | High | Space Rental (42 C.F.R. § 411.357(a)) | Partial | Space Rental (42 C.F.R. § 1001.952(b)) | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | Same deficiencies as ARR-011 | Same remediation as ARR-011 | 30-Day | Patricia Yamamoto | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-013 | GW-M-01 | Value-Based Payment | Covenant Health Plans Inc. | Value-based payment incentive bonuses tied to quality metrics ($2.1M in FY2022); Covenant is largest commercial payer at $38.6M (18% of net revenue) | Per provider agreement | $2,100,000 (FY2022 incentive bonuses) | $38,600,000 (total Covenant revenue) | Stark (value-based enterprise exception analysis) | Moderate | Moderate | Value-Based Enterprise Exceptions (42 C.F.R. § 411.357 — CMS Final Rule, 85 Fed. Reg. 77492, eff. Jan. 19, 2021) | Partial — requires documentation of qualifying VBE | Value-Based Arrangements (42 C.F.R. § 1001.952 — AKS Final Rule, 85 Fed. Reg. 77684, eff. Jan. 19, 2021) | Partial | M.G.L. c. 175H, § 3 | Pending | Pending | Need to confirm AHT-Covenant arrangement qualifies as a value-based enterprise under modernized Stark/AKS rules; documentation of value-based purposes and target patient population required | Document value-based enterprise structure; obtain legal opinion on exception applicability; update Covenant provider agreement terms | 60-Day | Derek Huang | Stark Law Compliance Assessment Memorandum; AKS Compliance Assessment Memorandum | Covenant address: 500 Boylston Street, 12th Floor, Boston, MA 02116
ARR-014 | GW-H-13 | ConnectiCare MSA — Practice 2 | ConnectiCare Physicians Network, LLC — Practice 2 | MSA providing billing, coding, practice management, IT to independently owned physician practice; 15% of collected net revenue management fee | Various | $570,000 | Referrals to AHT ancillary services — tracked | Both (AKS + Stark) | High | High | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Same structural issues as ARR-005; high referral volume to AHT ancillary services | Same remediation as ARR-005 | 30-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis
ARR-015 | GW-H-14 | ConnectiCare MSA — Practice 3 | ConnectiCare Physicians Network, LLC — Practice 3 | MSA providing billing, coding, practice management, IT; 15% fee | Various | $612,000 | Referrals to AHT ancillary services — tracked | Both (AKS + Stark) | High | High | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Same structural issues as ARR-005; high referral volume to AHT ancillary services | Same remediation as ARR-005 | 30-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis
ARR-016 | GW-H-15 | ConnectiCare MSA — Practice 4 | ConnectiCare Physicians Network, LLC — Practice 4 | MSA providing billing, coding, practice management, IT; 15% fee | Various | $498,000 | Referrals to AHT ancillary services — tracked | Both (AKS + Stark) | High | High | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Same structural issues as ARR-005; significant referral volume to AHT ancillary services | Same remediation as ARR-005 | 30-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis
ARR-017 | GW-H-16 | ConnectiCare MSA — Practice 5 | ConnectiCare Physicians Network, LLC — Practice 5 | MSA providing billing, coding, practice management, IT; 15% fee | Various | $541,000 | Referrals to AHT ancillary services — tracked | Both (AKS + Stark) | High | High | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Same structural issues as ARR-005; significant referral volume to AHT ancillary services | Same remediation as ARR-005 | 30-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis
ARR-018 | GW-H-17 | ConnectiCare MSA — Practice 6 | ConnectiCare Physicians Network, LLC — Practice 6 | MSA providing billing, coding, practice management, IT; 15% fee | Various | $487,111 | Referrals to AHT ancillary services — tracked | Both (AKS + Stark) | Moderate | Moderate | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Same structural issues as ARR-005; lower referral volume to AHT ancillary services | Same remediation as ARR-005 | 60-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis
ARR-019 | GW-M-02 | ConnectiCare MSA — Practice 7 | ConnectiCare Physicians Network, LLC — Practice 7 | MSA providing billing, coding, practice management, IT; 15% fee | Various | $463,000 | Referrals to AHT ancillary services — tracked | Both (AKS + Stark) | Moderate | Moderate | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Same structural issues as ARR-005; lower referral volume | Same remediation as ARR-005 | 60-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis
ARR-020 | GW-M-03 | ConnectiCare MSA — Practice 8 | ConnectiCare Physicians Network, LLC — Practice 8 | MSA providing billing, coding, practice management, IT; 15% fee | Various | $518,000 | Referrals to AHT ancillary services — tracked | Both (AKS + Stark) | Moderate | Moderate | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Same structural issues as ARR-005; moderate referral volume | Same remediation as ARR-005 | 60-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis
ARR-021 | GW-M-04 | ConnectiCare MSA — Practice 9 | ConnectiCare Physicians Network, LLC — Practice 9 | MSA providing billing, coding, practice management, IT; 15% fee | Various | $515,000 | Referrals to AHT ancillary services — tracked | Both (AKS + Stark) | Moderate | Moderate | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Same structural issues as ARR-005; moderate referral volume | Same remediation as ARR-005 | 60-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis
ARR-022 | GW-M-05 | ConnectiCare MSA — Aggregate/Oversight | ConnectiCare Physicians Network, LLC — Aggregate oversight arrangement | Umbrella MSA oversight and compliance coordination across all 9 practices; aggregate fee allocation | Various | Included in aggregate $4,730,000 | Aggregate referrals tracked | Both (AKS + Stark) | Moderate | Moderate — reclassified from High per C&H analysis | Indirect Compensation; Personal Services | Partial | Management Contracts | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending | Pending | Structural indirect compensation chain; aggregate fee allocation methodology not documented | Same remediation as ARR-005; document fee allocation methodology | 60-Day | Patricia Yamamoto | ConnectiCare MSA Arrangements — Indirect Compensation Analysis | Aggregate managed practice revenue: $31,530,000
ARR-023 | GW-M-06 | Lakeview Legacy — Physician Employment | Lakeview Physician #2 | Employment agreement assumed in acquisition; compensation requires FMV review | August 15, 2022 (assumed) | $285,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated post-acquisition; compensation formula requires review | Restate using revised templates; obtain Northbridge FMV opinion | 30-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-024 | GW-M-07 | Lakeview Legacy — Physician Employment | Lakeview Physician #3 | Employment agreement assumed in acquisition; compensation requires FMV review | August 15, 2022 (assumed) | $310,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated post-acquisition; holdover term issue | Restate using revised templates; obtain Northbridge FMV opinion | 30-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-025 | GW-M-08 | Lakeview Legacy — Physician Employment | Lakeview Physician #4 | Employment agreement assumed in acquisition | August 15, 2022 (assumed) | $265,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; expired term | Restate using revised templates; obtain Northbridge FMV opinion | 30-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-026 | GW-M-09 | Lakeview Legacy — Physician Employment | Lakeview Physician #5 | Employment agreement assumed in acquisition | August 15, 2022 (assumed) | $295,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; compensation formula requires review | Restate using revised templates; obtain Northbridge FMV opinion | 60-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-027 | GW-M-10 | Lakeview Legacy — Physician Employment | Lakeview Physician #6 | Employment agreement assumed in acquisition | August 15, 2022 (assumed) | $330,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; potential above-FMV total compensation | Restate using revised templates; obtain Northbridge FMV opinion | 60-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-028 | GW-M-11 | Lakeview Legacy — Physician Employment | Lakeview Physician #7 | Employment agreement assumed in acquisition | August 15, 2022 (assumed) | $275,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; term expired | Restate using revised templates; obtain Northbridge FMV opinion | 60-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-029 | GW-M-12 | Lakeview Legacy — Physician Employment | Lakeview Physician #8 | Employment agreement assumed in acquisition | August 15, 2022 (assumed) | $248,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; holdover issue | Restate using revised templates; obtain Northbridge FMV opinion | 60-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-030 | GW-M-13 | Lakeview Legacy — Physician Employment | Lakeview Physician #9 | Employment agreement assumed in acquisition | August 15, 2022 (assumed) | $302,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; compensation formula requires review | Restate using revised templates; obtain Northbridge FMV opinion | 60-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-031 | GW-M-14 | Lakeview Legacy — Physician Employment | Lakeview Physician #10 | Employment agreement assumed in acquisition | August 15, 2022 (assumed) | $258,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; term requires review | Restate using revised templates; obtain Northbridge FMV opinion | 60-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-032 | GW-M-15 | Lakeview Legacy — Physician Employment | Lakeview Physician #11 | Employment agreement assumed in acquisition | August 15, 2022 (assumed) | $272,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Employment; Personal Services; Fair Market Value | Partial | Employment; Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; current term but compensation above benchmark | Restate using revised templates; obtain Northbridge FMV opinion | 30-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-033 | GW-M-16 | Lakeview Legacy — Independent Contractor | Lakeview IC Physician #1 | IC agreement assumed in acquisition; part-time specialist | August 15, 2022 (assumed) | $145,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Personal Services; Fair Market Value | Partial | Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; IC classification requires review | Restate using revised IC Agreement template; obtain Northbridge FMV opinion | 30-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-034 | GW-M-17 | Lakeview Legacy — Independent Contractor | Lakeview IC Physician #2 | IC agreement assumed in acquisition; part-time specialist | August 15, 2022 (assumed) | $128,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Personal Services; Fair Market Value | Partial | Personal Services | Partial | M.G.L. c. 175H, § 3 | Deficient | Pending | FMV not substantiated; IC classification and term require review | Restate using revised IC Agreement template; obtain Northbridge FMV opinion | 30-Day | Patricia Yamamoto / Derek Huang | Lakeview Legacy Arrangements — Post-Acquisition Compliance Gap Memo
ARR-035 | GW-M-18 | Medical Director / IC Arrangement (non-Lakeview) | AHT Medical Director — Physician C | Medical director stipend; effective hourly rate above 75th percentile but below 90th; duties partially documented | Various | $68,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Personal Services; Fair Market Value; Employment | Partial | Personal Services; Employment | Partial | M.G.L. c. 175H, § 3 | Pending (Northbridge) | Pending | Effective hourly rate above benchmark but less extreme; duty documentation incomplete | Align compensation with FMV per Northbridge opinion; standardize duty descriptions; use revised template | 60-Day | Derek Huang | Medical Director Compensation — FMV and Commercial Reasonableness Analysis
ARR-036 | GW-M-19 | Medical Director / IC Arrangement (non-Lakeview) | AHT Medical Director — Physician D | Medical director stipend; moderate FMV deviation | Various | $55,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Personal Services; Fair Market Value; Employment | Partial | Personal Services; Employment | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending (Northbridge) | Pending | Effective hourly rate above 75th percentile; hours documentation needs improvement | Align compensation with FMV per Northbridge opinion; improve hour tracking; use revised template | 60-Day | Derek Huang | Medical Director Compensation — FMV and Commercial Reasonableness Analysis
ARR-037 | GW-M-20 | Medical Director / IC Arrangement (non-Lakeview) | AHT Medical Director — Physician E | Medical director stipend; moderate FMV deviation | Various | $47,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Personal Services; Fair Market Value; Employment | Partial | Personal Services; Employment | Partial | M.G.L. c. 175H, § 3 | Pending (Northbridge) | Pending | Effective hourly rate above benchmark; partial duty documentation | Align compensation with FMV per Northbridge opinion; use revised template | 90-Day | Derek Huang | Medical Director Compensation — FMV and Commercial Reasonableness Analysis
ARR-038 | GW-M-21 | Medical Director / IC Arrangement (non-Lakeview) | AHT Medical Director — Physician F | Medical director stipend; moderate FMV deviation | Various | $38,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Personal Services; Fair Market Value; Employment | Partial | Personal Services; Employment | Partial | M.G.L. c. 175H, § 3 | Pending (Northbridge) | Pending | Effective hourly rate modestly above benchmark; partial duty documentation | Align compensation with FMV per Northbridge opinion; use revised template | 90-Day | Derek Huang | Medical Director Compensation — FMV and Commercial Reasonableness Analysis
ARR-039 | GW-M-22 | Medical Director / IC Arrangement (non-Lakeview) | AHT IC — Physician G | Independent contractor arrangement; moderate FMV concern | Various | $82,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Personal Services; Fair Market Value | Partial | Personal Services | Partial | Conn. Gen. Stat. § 20-7a(d) | Pending (Northbridge) | Pending | Effective hourly rate above 75th percentile; IC classification adequate | Align compensation with FMV per Northbridge opinion; use revised template | 60-Day | Derek Huang | Medical Director Compensation — FMV and Commercial Reasonableness Analysis
ARR-040 | GW-M-23 | Medical Director / IC Arrangement (non-Lakeview) | AHT IC — Physician H | Independent contractor arrangement; moderate FMV concern | Various | $25,000 | N/A | Both (AKS + Stark) | Moderate | Moderate | Personal Services; Fair Market Value | Partial | Personal Services | Partial | M.G.L. c. 175H, § 3 | Pending (Northbridge) | Pending | Effective hourly rate modestly above benchmark; lowest stipend in portfolio | Align compensation with FMV per Northbridge opinion; use revised template | 90-Day | Derek Huang | Medical Director Compensation — FMV and Commercial Reasonableness Analysis
[sheet: Meridian Diagnostics]
Field | Detail
Counterparty Full Legal Name | Meridian Diagnostics LLC
Entity Type | LLC
Jurisdiction | Connecticut
EIN | 82-4019673
Address | 88 Trumbull Street, Hartford, CT 06103
Counsel | Linden & Pryor LLP (Thomas Beckett, Partner); 750 Main Street, Suite 1400, Hartford, CT 06103
Ownership Structure | Dr. Franklin Osei (60%, Managing Member / Radiologist); Gerald Pratt (40%, non-physician investor)
Agreement Type | Services/Facility Access Agreement
Agreement Date | March 1, 2021
Agreement Term | 3-year initial term (March 1, 2021 – February 28, 2024); auto-renewal for successive 1-year periods
Services Provided | Mobile MRI and advanced diagnostic imaging services at 4 AHT clinic locations
AHT Clinic Locations Served | Hartford Clinic #15; New Haven Clinic #16; Bridgeport Clinic #17; Stamford Clinic #18
Fee Structure | Per-scan facility access fee: $185 per scan paid by Meridian to AHT
FY2022 Scan Volume | 4,200 scans
FY2022 Facility Fee Revenue to AHT | $777,000 (4,200 × $185)
FY2021 Facility Fee Revenue to AHT (comparison) | $592,000 (3,200 scans × $185)
Year-Over-Year Scan Volume Increase | 31.3% (3,200 to 4,200)
FY2022 Referral Volume (AHT physicians to Meridian) | $2,800,000
Risk Tier | High
Applicable Statutes | AKS (42 U.S.C. § 1320a-7b(b)); Stark Law (42 U.S.C. § 1395nn); Conn. Gen. Stat. § 20-7a(d)
Stark Exceptions Evaluated | Space Rental (42 C.F.R. § 411.357(a)); Equipment Rental (42 C.F.R. § 411.357(b))
Stark Exception Met? | No — per-scan fee varies with volume of referrals; fails 'set in advance' and 'does not vary' requirements
AKS Safe Harbors Evaluated | Space Rental (42 C.F.R. § 1001.952(b)); Equipment Rental (42 C.F.R. § 1001.952(c))
AKS Safe Harbor Met? | No — same deficiency; aggregate compensation varies with volume
FMV Substantiation | Deficient — no independent FMV appraisal for per-scan rate; Northbridge opinion requested
Commercial Reasonableness | Deficient — arrangement structure appears designed to correlate payment with referral volume
Key Risk Factor | Per-scan fee creates direct correlation between facility access payments and volume of referrals from AHT physicians to Meridian; fundamental structural non-compliance
Recommended Remediation | Convert per-scan fee to fixed monthly facility rental at FMV; obtain Northbridge FMV appraisal; use revised Equipment Lease / Access Agreement template with Stark/AKS safe harbor provisions; 3-year term with annual FMV recertification
Remediation Status | Draft restructured facility access agreement prepared; transmitted to Linden & Pryor LLP (Thomas Beckett) with compliance rationale letter
Remediation Priority | Immediate
Voluntary Disclosure Consideration | Evaluated under CMS SRDP and OIG SDP — identified as highest-risk item for potential disclosure
Detailed Analysis Memo | Meridian Diagnostics Facility Access Fee — Detailed AKS/Stark Analysis
[sheet: Pinnacle Laboratory]
Field | Detail
Counterparty Full Legal Name | Pinnacle Laboratory Services Inc.
Entity Type | Corporation
Jurisdiction | Rhode Island
EIN | 05-6138290
Address | 1200 Warwick Avenue, Suite 110, Warwick, RI 02886
Agreement Type | Preferred Laboratory Agreement
Agreement Date | June 15, 2020
Agreement Term | 5-year initial term (June 15, 2020 – June 14, 2025)
AHT Clinics Served | Rhode Island (3 clinics) and southeastern Massachusetts clinics
FY2022 Referral Volume | $1,650,000
Risk Tier | High
Applicable Statutes | AKS (42 U.S.C. § 1320a-7b(b)); Stark Law (42 U.S.C. § 1395nn); M.G.L. c. 175H, § 3
--- Issue 1: No-Cost Electronic Lab Interface ---
Interface Description | Electronic laboratory interface integrated into ArborConnect EHR/practice management platform
Cost to AHT | $0 (provided at no charge by Pinnacle)
Estimated Market Value | $120,000/year
Stark Non-Monetary Remuneration Limit (CY2023) | $459/year
Exceedance | $120,000 vs. $459 limit — exceeds by approximately $119,541 (260× the limit)
Stark Exception Analysis | Non-Monetary Remuneration Exception (42 C.F.R. § 411.357(k)) — NOT MET; value far exceeds annual limit
AKS Safe Harbor Analysis | Personal Services Safe Harbor — NOT MET; no FMV compensation flowing to Pinnacle for the interface; constitutes potential inducement linked to referrals
--- Issue 2: CME Sponsorship ---
CME Events in FY2022 | 4 events
Total CME Sponsorship Value | $86,000
Average CME Event Cost | $21,500
Concern | CME sponsorship by referral source creates appearance of inducement to refer; combined with lab interface, total remuneration = $206,000/year
--- Issue 3: Dr. Karen Ellsworth Equity Interest ---
Equity Holder | Dr. Karen Ellsworth (spouse of AHT CEO Dr. Nathan Ellsworth)
Equity Percentage | 4.2% passive interest
Nature of Interest | Passive — Dr. Karen Ellsworth is an independent physician, not employed by AHT
Stark Analysis | Ownership/Investment Exception (42 C.F.R. § 411.356) — requires analysis of publicly traded securities and rural provider criteria; partial applicability
AKS Analysis | Investment Interest Safe Harbor (42 C.F.R. § 1001.952(a)) — partial; requires further analysis of entity size and passive investor criteria
Conflict of Interest | CEO's spouse holds equity in entity receiving $1.65M in referrals from AHT; creates conflict of interest requiring formal disclosure and recusal protocols
State Law | M.G.L. c. 175H, § 3
Combined Annual Remuneration from Pinnacle | $206,000 ($120,000 interface + $86,000 CME)
Recommended Remediation — Interface | Convert to FMV license fee arrangement; AHT to pay Pinnacle FMV for interface or Pinnacle to charge FMV; letter sent requesting restructuring discussions
Recommended Remediation — CME | Separate CME sponsorship from referral relationship; require independent CME funding or FMV payment for educational services
Recommended Remediation — Equity | Require formal conflict-of-interest disclosure by Dr. Nathan Ellsworth; evaluate divestiture or recusal protocols; enhance referral independence safeguards
Remediation Priority | Immediate
Voluntary Disclosure Consideration | Evaluated under CMS SRDP and OIG SDP
Detailed Analysis Memo | Pinnacle Laboratory Services — Detailed AKS/Stark Analysis
[sheet: ConnectiCare MSAs]
Practice # | Managed Practice Name | MSA Effective Date | Services Provided | FY2022 Collected Net Revenue | Management Fee Rate | FY2022 Management Fee Revenue to AHT | Referrals to AHT Ancillary Services? | Ancillary Services Referred | Estimated Referral Value to AHT Ancillaries | Stark Indirect Compensation Chain Identified? | AKS Management Contract Safe Harbor Met? | Risk Tier | Key Deficiency | Recommended Remediation | Remediation Priority
1 | Hartford Area Practice #1 | January 1, 2020 | Billing, coding, practice management, IT infrastructure (ArborConnect) | $3,506,000 | 15% | $525,900 | Yes | Laboratory, Diagnostic Imaging, Physical Therapy | $412,000 | Yes | Partial | High | Percentage-based fee combined with referrals to AHT ancillary services creates unbroken chain of financial relationships; fee structure may be deemed to vary with volume/value of referrals | Restructure to fixed-fee or blended model; add referral tracking safeguards; use revised MSA template | 30-Day
2 | Hartford Area Practice #2 | March 1, 2020 | Billing, coding, practice management, IT infrastructure | $3,800,000 | 15% | $570,000 | Yes | Laboratory, Diagnostic Imaging | $385,000 | Yes | Partial | High | Same structural issues; high referral volume to AHT ancillary services | Same remediation as Practice #1 | 30-Day
3 | Hartford Area Practice #3 | June 15, 2020 | Billing, coding, practice management, IT infrastructure | $4,080,000 | 15% | $612,000 | Yes | Laboratory, Diagnostic Imaging, Physical Therapy | $498,000 | Yes | Partial | High | Same structural issues; highest referral volume among Hartford practices | Same remediation as Practice #1 | 30-Day
4 | Hartford Area Practice #4 | September 1, 2020 | Billing, coding, practice management, IT infrastructure | $3,320,000 | 15% | $498,000 | Yes | Laboratory, Diagnostic Imaging | $347,000 | Yes | Partial | High | Same structural issues; significant referral volume | Same remediation as Practice #1 | 30-Day
5 | Hartford Area Practice #5 | November 1, 2020 | Billing, coding, practice management, IT infrastructure | $3,607,000 | 15% | $541,050 | Yes | Laboratory, Physical Therapy | $372,000 | Yes | Partial | High | Same structural issues; significant referral volume to AHT ancillary services | Same remediation as Practice #1 | 30-Day
6 | Hartford Area Practice #6 | January 15, 2021 | Billing, coding, practice management, IT infrastructure | $3,247,000 | 15% | $487,050 | Yes | Laboratory | $218,000 | Yes | Partial | Moderate | Same structural issues; lower referral volume to ancillary services | Same remediation as Practice #1 | 60-Day
7 | Hartford Area Practice #7 | April 1, 2021 | Billing, coding, practice management, IT infrastructure | $3,087,000 | 15% | $463,050 | Yes | Laboratory, Diagnostic Imaging | $195,000 | Yes | Partial | Moderate | Same structural issues; lower referral volume | Same remediation as Practice #1 | 60-Day
8 | Hartford Area Practice #8 | July 1, 2021 | Billing, coding, practice management, IT infrastructure | $3,453,000 | 15% | $517,950 | Yes | Laboratory | $168,000 | Yes | Partial | Moderate | Same structural issues; moderate referral volume | Same remediation as Practice #1 | 60-Day
9 | Hartford Area Practice #9 | October 1, 2021 | Billing, coding, practice management, IT infrastructure | $3,430,000 | 15% | $514,500 | Yes | Laboratory, Diagnostic Imaging | $155,000 | Yes | Partial | Moderate | Same structural issues; moderate referral volume | Same remediation as Practice #1 | 60-Day
TOTAL | All 9 Managed Practices | $31,530,000 | 15% | $4,729,500 | $2,750,000 | 5 High / 4 Moderate
[sheet: Medical Director Arrangements]
Arrangement # | Physician Name | Specialty | Clinic Location / State | Arrangement Type | Annual Stipend | Contracted Hours/Month | Actual Documented Hours/Month | Effective Hourly Rate | MGMA 50th Percentile Benchmark | MGMA 75th Percentile Benchmark | MGMA 90th Percentile Benchmark | Rate vs. 90th Percentile | FMV Substantiation Status | Commercial Reasonableness Status | Duties Adequately Documented? | Agreement Term Status | Risk Tier | Source | Recommended Remediation | Northbridge FMV Opinion Status
1 | Physician A (redacted) | Cardiology | Massachusetts — Clinic #3 | Medical Director | $95,000 | 8 | 6.5 | $1,217.95 | $225/hr | $310/hr | $385/hr | Above | Deficient | Deficient | No | Expired — holdover | High | Legacy AHT | Reduce stipend or increase documented hours to align with FMV; restate agreement; obtain Northbridge opinion | Requested
2 | Physician B (redacted) | Primary Care | Connecticut — Clinic #15 | Medical Director | $42,000 | 10 | 9.0 | $388.89 | $180/hr | $240/hr | $295/hr | Above | Deficient | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation; use revised template | Requested
3 | Dr. Vivian Chao | Multi-Specialty (Regional Medical Director) | Massachusetts — Central MA (Worcester) | Medical Director / Regional Medical Director | $110,000 | 12 | 10.0 | $916.67 | $225/hr | $310/hr | $385/hr | Above | Deficient | Deficient | Partial | Holdover (Lakeview assumed) | High | Lakeview Assumed | Restructure as Regional Medical Director role with enhanced documented duties; obtain Northbridge FMV opinion; restate using revised template | Requested
4 | Physician D (redacted) | Orthopedic Surgery | Massachusetts — Clinic #5 | Medical Director | $88,000 | 8 | 7.0 | $1,047.62 | $250/hr | $340/hr | $420/hr | Above | Deficient | Deficient | No | Expired — holdover | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
5 | Physician E (redacted) | Gastroenterology | Massachusetts — Clinic #7 | Medical Director | $76,000 | 8 | 6.0 | $1,055.56 | $230/hr | $315/hr | $390/hr | Above | Deficient | Deficient | No | Expired — holdover | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
6 | Physician F (redacted) | Internal Medicine | Connecticut — Clinic #16 | Medical Director | $55,000 | 10 | 8.5 | $539.22 | $180/hr | $240/hr | $295/hr | Above | Deficient | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
7 | Physician G (redacted) | Neurology | Massachusetts — Clinic #2 | Medical Director | $68,000 | 8 | 6.0 | $944.44 | $235/hr | $320/hr | $400/hr | Above | Deficient | Deficient | No | Expired | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
8 | Physician H (redacted) | Primary Care | Rhode Island — Clinic #19 | Medical Director | $38,000 | 8 | 7.5 | $422.22 | $180/hr | $240/hr | $295/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve hour tracking | Requested
9 | Physician I (redacted) | Endocrinology | Massachusetts — Clinic #4 | Medical Director | $52,000 | 8 | 7.0 | $619.05 | $220/hr | $300/hr | $370/hr | Above | Deficient | Pending | Partial | Holdover | Moderate | Legacy AHT | Align compensation; restate agreement | Requested
10 | Physician J (redacted) | Pulmonology | Connecticut — Clinic #17 | Medical Director | $63,000 | 8 | 6.5 | $807.69 | $225/hr | $310/hr | $385/hr | Above | Deficient | Deficient | No | Expired | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
11 | Physician K (redacted) | Rheumatology | Massachusetts — Clinic #6 | Medical Director | $47,000 | 8 | 7.0 | $559.52 | $210/hr | $285/hr | $355/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
12 | Physician L (redacted) | Dermatology | Massachusetts — Clinic #8 | Medical Director | $41,000 | 6 | 5.0 | $683.33 | $200/hr | $275/hr | $340/hr | Above | Deficient | Pending | No | Expired | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
13 | Physician M (redacted) | Urology | Rhode Island — Clinic #20 | Medical Director | $58,000 | 8 | 6.5 | $743.59 | $220/hr | $300/hr | $375/hr | Above | Deficient | Deficient | No | Holdover | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
14 | Physician N (redacted) | Family Medicine | New Hampshire — Clinic #22 | Medical Director | $35,000 | 10 | 9.0 | $324.07 | $175/hr | $235/hr | $290/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
15 | Physician O (redacted) | Oncology | Massachusetts — Clinic #1 | Medical Director | $82,000 | 8 | 6.0 | $1,138.89 | $250/hr | $340/hr | $425/hr | Above | Deficient | Deficient | No | Expired — holdover | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
16 | Lakeview Physician — MD #1 | Internal Medicine | Massachusetts — Worcester | Medical Director | $45,000 | 8 | 5.5 | $681.82 | $180/hr | $240/hr | $295/hr | Above | Deficient | Deficient | No | Expired | High | Lakeview Assumed | Restructure using revised template; obtain Northbridge FMV opinion | Requested
17 | Lakeview Physician — MD #2 | Family Medicine | Massachusetts — Shrewsbury | Medical Director | $60,000 | 8 | 6.0 | $833.33 | $175/hr | $235/hr | $290/hr | Above | Deficient | Deficient | No | Expired | High | Lakeview Assumed | Restructure using revised template; obtain Northbridge FMV opinion | Requested
18 | Lakeview Physician — MD #3 | Cardiology | Massachusetts — Worcester | Medical Director | $72,000 | 10 | 7.5 | $800.00 | $225/hr | $310/hr | $385/hr | Above | Deficient | Deficient | No | Expired | High | Lakeview Assumed | Restructure using revised template; obtain Northbridge FMV opinion | Requested
19 | Physician P (redacted) | Nephrology | Massachusetts — Clinic #9 | IC | $62,000 | 8 | 7.0 | $738.10 | $225/hr | $305/hr | $380/hr | Above | Deficient | Pending | Partial | Holdover | Moderate | Legacy AHT | Align compensation; restate agreement | Requested
20 | Physician Q (redacted) | Psychiatry | Connecticut — Clinic #18 | IC | $48,000 | 8 | 7.5 | $533.33 | $200/hr | $270/hr | $335/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
21 | Physician R (redacted) | General Surgery | Massachusetts — Clinic #10 | Medical Director | $73,000 | 8 | 6.0 | $1,013.89 | $240/hr | $325/hr | $405/hr | Above | Deficient | Deficient | No | Expired | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
22 | Physician S (redacted) | Primary Care | Rhode Island — Clinic #21 | Medical Director | $36,000 | 10 | 9.5 | $315.79 | $180/hr | $240/hr | $295/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
23 | Physician T (redacted) | Ophthalmology | Massachusetts — Clinic #11 | Medical Director | $51,000 | 6 | 5.0 | $850.00 | $215/hr | $290/hr | $360/hr | Above | Deficient | Pending | Partial | Holdover | Moderate | Legacy AHT | Align compensation; restate agreement | Requested
24 | Physician U (redacted) | ENT | New Hampshire — Clinic #23 | Medical Director | $44,000 | 8 | 7.0 | $523.81 | $210/hr | $285/hr | $355/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
25 | Physician V (redacted) | Infectious Disease | Massachusetts — Clinic #12 | IC | $39,000 | 8 | 7.5 | $433.33 | $215/hr | $290/hr | $360/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
26 | Physician W (redacted) | Hematology | Massachusetts — Clinic #13 | Medical Director | $57,000 | 8 | 6.5 | $730.77 | $230/hr | $315/hr | $390/hr | Above | Deficient | Pending | No | Expired | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
27 | Physician X (redacted) | Physical Medicine | Connecticut — Clinic #15 | IC | $33,000 | 8 | 8.0 | $343.75 | $185/hr | $250/hr | $310/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
28 | Physician Y (redacted) | Allergy/Immunology | Massachusetts — Clinic #14 | Medical Director | $29,000 | 8 | 7.5 | $322.22 | $190/hr | $255/hr | $315/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
29 | Physician Z (redacted) | Emergency Medicine | Massachusetts — Clinic #1 | IC | $67,000 | 10 | 8.0 | $697.92 | $235/hr | $320/hr | $400/hr | Above | Deficient | Pending | Partial | Holdover | Moderate | Legacy AHT | Align compensation; restate agreement | Requested
30 | Physician AA (redacted) | Pain Management | Massachusetts — Clinic #4 | Medical Director | $54,000 | 8 | 6.5 | $692.31 | $220/hr | $300/hr | $375/hr | Above | Deficient | Pending | No | Expired | High | Legacy AHT | Reduce stipend or increase documented hours; restate agreement | Requested
31 | Lakeview IC Physician #1 | Orthopedic Surgery | Massachusetts — Worcester | IC | $145,000 | 12 | 10.0 | $1,208.33 | $250/hr | $340/hr | $420/hr | Above | Deficient | Pending | Partial | Holdover (Lakeview assumed) | Moderate | Lakeview Assumed | Restate using revised IC template; obtain Northbridge FMV opinion | Requested
32 | Lakeview IC Physician #2 | Gastroenterology | Massachusetts — Shrewsbury | IC | $128,000 | 12 | 10.0 | $1,066.67 | $230/hr | $315/hr | $390/hr | Above | Deficient | Pending | Partial | Holdover (Lakeview assumed) | Moderate | Lakeview Assumed | Restate using revised IC template; obtain Northbridge FMV opinion | Requested
33 | Physician BB (redacted) | Hospitalist | Massachusetts — Clinic #2 | Medical Director | $46,000 | 10 | 9.0 | $425.93 | $195/hr | $260/hr | $320/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
34 | Physician CC (redacted) | OB/GYN | Rhode Island — Clinic #19 | Medical Director | $40,000 | 8 | 7.0 | $476.19 | $195/hr | $265/hr | $330/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
35 | Physician DD (redacted) | Pediatrics | Massachusetts — Clinic #6 | Medical Director | $31,000 | 8 | 8.0 | $322.92 | $170/hr | $230/hr | $285/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
36 | Physician EE (redacted) | Geriatrics | Massachusetts — Clinic #8 | Medical Director | $28,000 | 8 | 7.5 | $311.11 | $175/hr | $235/hr | $290/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
37 | Physician FF (redacted) | Vascular Surgery | Connecticut — Clinic #17 | IC | $25,000 | 6 | 5.5 | $378.79 | $245/hr | $335/hr | $415/hr | Below | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Confirm FMV compliance; improve documentation | Requested
38 | Physician GG (redacted) | Sports Medicine | New Hampshire — Clinic #22 | Medical Director | $30,000 | 8 | 7.0 | $357.14 | $190/hr | $255/hr | $315/hr | Above | Pending | Pending | Partial | Current | Moderate | Legacy AHT | Align compensation; improve documentation | Requested
SUMMARY | $1,920,000 | Mean: 8.4 | Mean: 7.1 | $501.28 (weighted avg) | 37 of 38 Above 90th | 23 Deficient; 15 Pending | 12 Deficient; 26 Pending | 0 Yes; 14 No; 24 Partial | 15 Current; 12 Expired; 11 Holdover | 17 High; 21 Moderate | 33 Legacy AHT; 5 Lakeview | 38 Requested; 0 Received