Healthcare Leases & Stark Law Compliance – Part Two: Critical Dates for Healthcare Leases

Healthcare Leases & Stark Law Compliance

Part Two: Critical Dates for Healthcare Leases

Preventing compliance issues and penalties associated with protocols such as Stark Laws and Anti-Kickback statutes begins with knowing where the issues may lie. Lease agreements contain hundreds of data points, some of which are essential for compliance efforts and for effective portfolio management. Tracking and monitoring the essential data facilitates compliance efforts – internally with the lease agreements themselves, and externally with public standards including Stark I and II, Anti-Kickback, lease accounting, and others.

One subset of essential lease data is critical dates. In broad terms, critical dates are those that are tied to specific events that occur throughout the lease term. They include the following:

  • Lease Date
  • Possession Date
  • Substantial Completion Date
  • Lease Commencement Date
  • Rent Commencement Date
  • Rent Increase Dates
  • Rent Abatement Dates
  • Move Out Date (real estate)
  • Return Date (equipment)
  • Lease Expiration Date
  • Lease Option Date
  • Option Notification Date
  • Option Effective Date
  • Renewal Term Commencement (real estate)
  • Renewal Term Expiration (real estate)
  • Evergreen Commencement (equipment)
  • Evergreen Expiration (equipment)

Dates are often the triggers for key actions taken by either the lessor or the lessee. As a tenant, move in cannot occur prior to lease commencement. Additionally, if you haven’t vacated the premises by the expiration date, you could be put into holdover status by the lessor, resulting in increased rent or a penalty. As a lessor, if rents are scheduled to increase as of a certain date, income could be affected by not monitoring the date and billing timely for the increase. In the case of complying with Stark Laws, occasionally ignoring or forgetting the rent increase or expiration dates could lead to an unintended compliance issue.

Are you sure that you are capturing all essential data and critical dates for lease and regulatory compliance? Scribcor helps healthcare clients assess data quality and manage lease data, applying client-centric processes that ease uncertainty so you can Know. Right. Now. If you would like to learn more, visit us at

By Denise Hinkle

By Denise Hinkle

A seasoned veteran with over 25 years of industry-specific expertise, Denise is responsible for building and maintaining relationships with Scribcor’s existing and potential clients as well as serving on the executive leadership team. Denise is also responsible for creating and presenting a thought leadership series that provides insight and education on a variety of commercial real estate specific topics. Article edited and copy-edited by Katie Goldhagen.

Contact Scribcor Global

We’re always happy to talk lease administration. If you’d like more information about our services, or have a question, or just need some helpful advice on how to get started, just send us a note and we’ll get right back to you. There’s never any pressure or obligation and your contact information is kept confidential.

Share This