Shared Procedure Suites: The Time Share Cardiac Suite Concept

Interventional and procedural specialties depend on expensive rooms: imaging systems, monitoring, sterile space, recovery bays and trained staff. A hospital can spread that cost over many physicians and many hours. An independent physician who builds a suite often cannot fill it alone, at least at first. Empty hours are pure cost.

The idea behind a shared procedure suite is to fill those hours with other qualified physicians, under a clear agreement, so that the facility is used efficiently and more patients can be treated outside the hospital. Dr. Siddiqui's version of this idea, which he calls the Time Share Cardiac Suite Concept, is now used nationally.

Where the idea came from

In The Dark Side of Medicine, Dr. Siddiqui describes building his first surgery center before he had much income, on the expectation that the practice would grow. When it was finished, he was the only physician using it, and he was in that office one day a week. The rest of the schedule was open.

“You know what? Other doctors are going to want to use this.”

Living in Orlando, he notes, he was surrounded by the timeshare model: an owner pays for a defined slice of time at a property each year, and other owners use it the rest of the year. He studied the concept, talked with real-estate professionals and applied the same thinking to his clinical space, offering other physicians defined use of the suite and sometimes the full facility.

As he describes it, the visiting physicians brought their own staff, did their own billing and ran their sessions as their own, while he acted as the landlord, responsible for upkeep, repairs and cleanliness. The suite stayed in use, the visiting physicians gained access to a facility they did not have to build, and patients gained another outpatient option.

How shared procedure suites work, in general

Every arrangement is different, and this guide does not describe the terms of any particular one. In general, a shared-suite agreement answers a handful of questions:

• Time. Which days or blocks does each physician have? Is the schedule fixed in advance? What happens to unused time?
• Space and equipment. Exactly which rooms and equipment are included, and does the user have exclusive use during their block?
• People. Does the visiting physician bring their own staff, or are staff provided as part of the arrangement? Who supervises them?
• Supplies. Who furnishes supplies and devices, and on what terms?
• Billing. Who bills payers for what? The professional fee and any technical or facility component must be billed correctly by the party entitled to bill it, consistent with how the space is licensed and enrolled.
• Fees. What does the user pay the owner, and how was that amount set?
• Quality and safety. Credentialing of users, protocols, emergency response and transfer arrangements, and incident reporting.
• Records and privacy. Who keeps the medical records, and how protected health information is handled under HIPAA.

Who benefits, and how

• The owner spreads the fixed costs of space and equipment over more hours of use.
• The visiting physician gains access to a properly equipped suite without the capital, construction and regulatory work of building one.
• Patients may gain access to outpatient procedures closer to home and outside the hospital.
• Payers may pay less when appropriate procedures move from a hospital setting to an outpatient one, a theme Dr. Siddiqui also develops in his Private Insurance Operating Cardiac Model. See outpatient labs and ASCs.

The legal guardrails

Shared space between physicians who may refer patients to each other is exactly the kind of relationship federal fraud-and-abuse laws examine. In general terms:

Stark Law. If the arrangement involves a financial relationship between a physician and an entity that furnishes Medicare designated health services, it must fit an exception. CMS created a specific timeshare arrangements exception in 2016, but it is narrow: the premises and equipment must be used predominantly for evaluation and management services, it does not cover advanced imaging, radiation therapy or most clinical laboratory equipment, and fees cannot be a percentage of revenue or a per-unit-of-service charge. Many procedure-suite arrangements therefore rely instead on the exceptions for rental of office space and equipment, which generally require a written lease of at least one year, exclusive use during the lease periods, and rent set in advance at fair market value without regard to referrals.

Anti-Kickback Statute. The OIG's safe harbors for space and equipment rental protect part-time arrangements only when the agreement specifies the exact schedule of intervals, their precise length and the exact rent for them, and when total rent is set in advance, consistent with fair market value and not tied to referrals. An arrangement outside a safe harbor is judged on its facts and intent.

Licensing and payer rules. If the suite is a licensed facility or a Medicare-certified ambulatory surgery center, state licensure and Medicare rules govern how it operates and who may bill for what. Some states also have their own self-referral or fee-splitting laws.

The practical lesson: fees for defined blocks of time, set in advance and supported by an independent fair-market-value analysis, are the general pattern. Fees that rise with the number of patients a physician brings in are not. Healthcare counsel should design and review the agreement before the first case is scheduled.

Is a shared suite right for you?

If you are considering building a suite, ask whether you can realistically fill it yourself, and whether sharing time could bridge the gap while your practice grows. If you are considering using someone else's suite, compare it with hospital privileges and with joining an existing ASC, and look closely at the quality systems you would be relying on. In either role, the value of the arrangement depends on clear scheduling, good operations and a compliant written agreement.

Operational details decide whether sharing works day to day. Agree on turnover time between sessions, how cancellations and late-running cases are handled, who restocks and cleans the room, how equipment faults are reported and fixed, and how disputes are resolved. Put these rules in writing alongside the legal agreement, review them after the first few months, and keep the schedule visible to everyone who uses the suite. Shared space works best when every user knows exactly what they are responsible for.

Educational information only — not legal, financial, tax or billing advice. Consult qualified advisors. Laws and payer rules differ by state and change often; the descriptions here are general.