As global enforcement expectations continue to rise, regulators and self-regulatory bodies increasingly focus on how FMV is determined, documented, and applied in practice. While most large organisations have policies and structures in place, many small to medium size still struggle to translate FMV requirements into consistent, defensible, and scalable operational processes. The result is a persistent gap between written standards and day-to-day execution.
FMV in the Healthcare Context
The principle is clear: compensation must reflect the genuine value of services rendered and must never be linked, directly or indirectly, to inducement, prescribing, purchasing, or recommendation behaviour.
Why FMV Is Under Heightened Scrutiny
Regulators now look well beyond the existence of an FMV policy. During audits, inspections, and investigations, organisations are expected to demonstrate:
- Clearly defined and current FMV methodologies
- FMV Tiering,
- Consistent application across engagement types and geographies
- Robust documentation, approval workflows, and audit trails
- Alignment between FMV decisions and transparency disclosures
The critical question has shifted from “Do you have an FMV policy?” to “Can you clearly explain, evidence, and defend how this rate was determined?”
The Compliance and Business Impact
Leading organisations are reframing FMV as an operational capability embedded within engagement, contracting, and transparency workflows. This shift requires:
- Periodic review and recalibration of FMV methodologies
- Clear governance aligned with ABAC and transparency frameworks
- Strong documentation standards and approval controls
- Integration into systems and processes used by the business
How Eunomia Supports FMV Governance and Delivery
Conclusion
Eunomia partners with healthcare organisations to turn FMV from a compliance risk into a compliance strength—through structured, pragmatic, and audit-ready solutions.
