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Sources · SPARK Senior Health · Investment Book · Stage 2 · 2025–2026
SPARK Senior Health · Proprietary & Confidential · All Rights Reserved
Model Development
Clinic Design · Clinical Model · Staffing · AI & Technology
4 Sections · Fixed-Clinic Design · NP-Led Clinical Model · Staffing & Compensation · AI & Technology · Investment Book 2025–2026
2.1
Clinic Design
~2,200 sq ft ADA-compliant buildout · CapEx envelope · zone layout
→
2.2
Clinical Model
NP-led care · CCM/APCM/RPM · AWV · billing architecture
→
2.3
Staffing Model
NP + LPN + driver per clinic · compensation · GA NP law
→
2.4
AI & Technology
EHR · RPM · AI documentation · telehealth · billing stack
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Stage 2 · Model Development · Section 2.1
Clinic Design — External & Interior Layout
Fixed-location ADA-compliant clinic buildout — ~2,200 sq ft, leasehold improvement, and interior clinical zone layout. Every zone maps to a billable CPT code or compliance requirement.
§ 2.1SPARK Senior Health Investment Book · 2025–2026
Phase 1 · Launch
Fixed Leasehold Clinic
🏥
~$198K total CapEx (expansion) · ~$242K flagship
~2,200 sq ft commercial lease in county seat commercial corridor. ADA-compliant buildout with exam room, waiting area, lab/diagnostic zone, staff workspace, and intake station. Permanent presence builds community trust and enables full billable service delivery. Leasehold improvement amortized at 15-year useful life.
Activate: Launch Day 1 · All clinics from M1
Phase 2 · Expansion (Year 2)
Expanded Clinic Footprint
🏢
Same CapEx envelope · 2nd exam room addition
At 400+ enrolled members per clinic, a second NP and second exam room are added. This requires either a larger original lease space (preferred — select leases with expansion option) or buildout of an adjacent unit. Two-NP model doubles visit throughput and enables subspecialty telehealth consultations in dedicated room.
Activate: 650+ enrolled members · Two-NP hiring trigger
Phase 3 · Scale (Year 3+)
Full-Panel Clinic (10 sites)
🏛️
No new CapEx Y4/Y5 · all 10 built out by Y3 end
All 10 clinics operating at full panel capacity (up to 1,000 members each). Years 4–5 are steady-state with zero new clinic CapEx. Focus shifts to member panel deepening, PMPM optimization through APCM/CCM maturation, and operational efficiency across the 10-site network.
Steady state: Y4–Y5 · No new clinic CapEx
Interior Clinical Zones — ~2,200 sq ft Fixed Clinic
Six zones · each mapped to a billable CPT code or compliance function
Zone 1 · Intake / Registration
AI Check-In Station + Waiting Area
Front-desk check-in with Klara patient messaging, EHR intake, insurance verification, and care gap flag display. Waiting area with accessibility seating. Delivers structured pre-visit note to NP before exam room opens.
Zone 2 · Exam Room(s)
Adjustable Table · Vitals Station · EHR
ADA-accessible exam table, Vital Signs Station (BP multi-cuff, SpO2, weight scale, temperature), 12-lead ECG, EHR workstation, sink. Primary revenue driver — AWV, E&M, chronic disease visits, acute episodic. Two rooms at 550+ members.
Zone 3 · Lab & Diagnostics
i-STAT POC · CLIA-Waived · Ultrasound
Abbott i-STAT Alinity POC (BMP, HbA1c, INR, glucose, lactate), 10-parameter urinalysis reader, Butterfly iQ+ POCUS (M6), portable spirometer (M6), wound care station (M6), vision screening kit. Results in the visit — eliminates most referral delays.
Zone 4 · Telehealth Room
HIPAA-Compliant AV · Specialist Consult
Dedicated privacy-compliant room, Doxy.me Pro + Zoom for Healthcare link, specialist consult capability via NGHS referral network. The specialist comes to the patient. Doubles as NP-patient telehealth room when the NP is remote.
Zone 5 · Medication & Supply
Locked Cabinet · Vaccine Fridge · Safe
Medical-grade vaccine refrigerator with data logger, locked medication cabinet, DEA-compliant controlled substance safe, PPE and supply storage, sharps/biohazard system. Vaccine revenue (flu, pneumococcal, shingles) — highest-margin per-visit ancillary line.
Zone 6 · Provider Workspace
Fiber + LTE Failover · EHR · Billing
Fiber primary + cellular LTE failover (sub-30-second). EHR workstations × 4, Commure Ambient AI documentation, HIPAA-isolated clinical network, MDM-enrolled devices via Rippling. Clean claims submitted same day via Commure RCM → Palmetto GBA J-J.
Per-Clinic CapEx — Lease vs Own
Expansion (C2–C10) baseline · Flagship adds $39K legal · Own = 20% down · 7% · 20-yr mortgage
Category
Lease
Own
Building (20% down + 3% closing)
—
$78,400
Leasehold improvements
$98,500
$98,500
Furniture & fixtures
$12,500
$12,500
Clinical equipment (D1→M9)
~$34,300
~$34,300
Tech & networking
$10,500
$10,500
Vehicles + wrap
$38,500
$38,500
Software (expansion)
$3,500
$3,500
Legal & formation (C1 only)
$39,000
$39,000
Total expansion (C2–C10)
~$198K
~$276K
Total flagship (C1 incl. legal)
~$242K
~$320K
Annual Building Carrying Cost
Rent / Mortgage payments
$30,000
$26,052
Property tax
—
$4,500
Property insurance
—
$6,000
Maintenance reserve
—
$7,500
Annual total
$30,000
$44,052
+$14,052/yr vs lease · Building $350K · Loan $280K · $2,171/mo · 39-yr MACRS · equity builds over 20 years
ADA & External Requirements
Mandatory before first patient · Medicare enrollment prerequisite
✓ADA entry ramp — 1:12 max slope; van-accessible parking minimum 1 space
ConnectivityFiber primary ($400/clinic/mo, incl. install lead time 4–8 weeks). Cellular LTE failover — sub-30-second automatic switchover. Offline EHR mode for outage resilience. Clinical VLAN isolated from guest WiFi.
HVAC & PowerMedical-grade climate control — vaccine cold chain maintenance. Dedicated UPS for EHR and critical clinical devices. Generator backup recommended for RPM alert continuity during power outages.
BiohazardSharps disposal unit, bloodborne pathogen compliance per OSHA 29 CFR 1910.1030. Licensed hauler contract (Stericycle or Sharps Compliance) — $90/month per clinic.
SecurityManaged firewall with intrusion detection. All devices MDM-enrolled via Rippling. "No Cash On Hand" signage. Video monitoring system recommended.
Stage 2 · Model Development · Section 2.1
Site Acquisition — Ownership & Financing Structure
SPARK defaults to ownership over long-term leasing. A separate single-purpose realty LLC holds each building while the Georgia PC leases at fair market rent — building equity accrues independently of clinical economics and remains CPOM-compliant.
§ 2.1SPARK Senior Health Investment Book · 2025–2026
Entity Structure — SBA Eligible Passive Company
Realty LLC holds title · Georgia PC leases from LLC at FMR · MSO/investors capture building appreciation
→Single-purpose realty LLC (per clinic site) holds title and mortgage debt — legally separate from the professional corporation that delivers clinical services
→PC leases from LLC at fair market rent — a recognized SBA "Eligible Passive Company" structure. The operating tenant (PC) pays rent; the LLC holds debt and title
→CPOM-compliant: Clinical revenue and real estate equity remain legally separate — no commingling that could expose the PC-MSO structure to corporate practice of medicine liability
→Lease-to-own default entry: 12–24 month lease with fixed/capped purchase option or right of first refusal — decouples clinical launch from real estate closing in thin-inventory markets
→Negotiate fixed option price upfront; credit all tenant improvements toward purchase price — SBA 504 and USDA B&I financing remain available after option exercise
→Site selection pacing: launch lease-to-own in counties with thin inventory (Lumpkin, Chattooga, Union) while pursuing SBA 504 purchase in deeper markets (Gordon, Habersham, Gilmer)
Target clinic footprint
2,200–2,500 sq ft
SBA 504 — Primary Path
Structure: 50% bank / 40% CDC debenture / 10% borrower down
Terms: 25-year fixed rate · ~10–15% down payment required
Close: 45–75 days · requires ≥51% owner-occupancy lock-in
Best for: Gordon, Habersham, Gilmer — deeper inventory markets with confirmed comps
USDA Business & Industry
Structure: USDA guaranty on conventional bank loan
Terms: 30-year amortization · 10–20% down · no occupancy lock-in
Eligibility:All 10 SPARK counties qualify — each under 50K population
Best for: Thin-inventory counties; sublease flexibility needed; Lumpkin, Chattooga, Union
Conventional Bank Financing
Terms: 25–30% down · 30–45 day close · no federal occupancy constraints
Best for: Speed-critical launches where SBA timeline is a constraint
Trade-off: Higher equity required upfront; no sublease restrictions
All 10 SPARK counties are rural-eligible for USDA B&I — every site qualifies for at least two financing paths regardless of local inventory depth.
Stage 2 · Model Development · Section 2.1
Site Acquisition — County Inventory & Lease-to-Own Strategy
Inventory depth varies sharply across the 10-county footprint. SPARK segments counties into three tiers and applies a lease-to-own strategy in thin markets to decouple clinical launch from real estate closing timelines.
§ 2.1SPARK Senior Health Investment Book · 2025–2026
County-by-County Pricing & Inventory
10-county footprint · NNN lease rate or purchase price per sq ft where verified
County
Depth
Price / SF
Notes
Gordon
Deep
$8–20/SF/Yr NNN
Largest supply; most comps
Fannin
Moderate
—
4 buildings · 2,040–3,129 SF
Gilmer
Moderate
~$285/SF blended
Active market; mixed-use available
Rabun
Moderate
avg ~$313/SF
Skewed by high-end listings
Stephens
Moderate
—
2,511 SF retail (former attorney)
Habersham
Moderate
—
4,992 SF brick building available
White
Moderate
$173/SF verified
$649K ÷ 3,748 SF · Hwy 129 priority lead
Union
Thin
—
Two 2,474 SF buildings available
Lumpkin
Thin
~$381/SF skewed
Thinnest workable; lease-to-own required
Chattooga
Thin
—
Essentially none; convertible sites only
Lease-to-Own Strategy
Decouples clinical launch from real estate closing — applies in all 10 counties but critical in thin-inventory markets
①Enter on a 12–24 month lease with a fixed or capped purchase option or ROFR negotiated at signing — no obligation to close, but the right to buy is locked in
②Launch clinical operations immediately — SBA 504 and USDA B&I timelines (45–75 days for SBA; longer for USDA) no longer block opening day
③Negotiate TI credits toward purchase: tenant improvements made during the lease period are credited toward the eventual purchase price — reduces effective down payment
④Exercise option via SBA 504 or USDA B&I — both programs remain fully available after option exercise; the lease-to-own structure does not preclude federal financing
⑤White County Hwy 129 is the priority lead: listed "for office or medical building" at $173/SF verified — negotiate immediate option, SBA 504 exercise within 12 months
Statewide Expansion Context
~200 active medical-use listings statewide · broader commercial inventory ~6,276 listings. The constraint in larger county seats shifts from availability to competition — SPARK's rural focus insulates against urban bidding pressure.
Stage 2 · Model Development · Section 2.1
Site Acquisition — Convertible Sites & Risk Mitigations
In thin-inventory counties SPARK targets convertible commercial shells — retail, former restaurant, office — that can be adapted to clinical use. Six identified leads across the footprint, each with a specific conversion rationale and risk profile.
§ 2.1SPARK Senior Health Investment Book · 2025–2026
Convertible Site Candidates — 6 Identified Leads
Commercial shells adaptable to clinical use · each with viable size, access, and conversion path
White County — HWY 129Priority Lead
Listed "for office or medical building" — former Cleveland Small Engine shop. $649K · 3,748 SF · $173/SF verified. Purpose-built conversion, confirmed medical-eligible zoning, priority option negotiation.
Stephens County
Former attorney's office (2,511 SF retail), former restaurant shell, and retail shell — three distinct candidates in Toccoa. Attorney office is cleanest conversion; restaurant shell requires MEP upgrade.
Union County
Retail/warehouse 3,824 SF near Young Harris — convertible with MEP buildout. Thin market; this is the primary candidate. Lease-to-own entry with USDA B&I exercise path.
Gilmer County
Mixed-use retail/loft in downtown Ellijay — active market with confirmed comps (~$285/SF blended). Moderate-depth inventory means multiple fallback options if primary doesn't close.
Gordon County
Retail/office shell on Hwy 41; former restaurant near I-75. Deepest inventory in the footprint ($8–20/SF/Yr NNN lease) — most direct-purchase opportunities. Convertible sites are backup options.
Chattooga County — 29 E Washington St
3,200 SF commercial shell in Summerville. Thinnest overall inventory — essentially no direct-purchase options. Lease-to-own on this site is the primary path; USDA B&I required for purchase.
Acquisition Risks & Mitigations
Four risk categories specific to rural medical-use real estate in North Georgia
Appraisal Risk
Risk: Rural medical-use comparables are thin — standard appraisals may undervalue the property, reducing loan proceeds. Mitigation: Engage appraisers with verified rural Georgia commercial experience before submitting to lender; negotiate seller on appraisal gap clause.
Condition Risk (Convertible Sites)
Risk: HVAC, electrical, and ADA compliance requirements in older shells can exceed initial estimates. Mitigation: Budget 10–15% renovation contingency on all convertible site buildouts; commission MEP inspection before option exercise.
SBA 504 Occupancy Lock-In
Risk: SBA 504 requires ≥51% owner-occupancy — constrains ability to sublease unused space post-purchase. Mitigation: Size clinics at 2,200–2,500 SF (not oversized); use USDA B&I in markets where sublease flexibility is needed (Lumpkin, Chattooga).
Inventory Timing (Lumpkin & Chattooga)
Risk: No direct-purchase inventory exists at launch — clinical opening contingent on converting a shell or waiting for listings. Mitigation: Lease-to-own entry with convertible site identified in advance; Chattooga's 29 E Washington St is the designated backup option.
Active Medical Listings · Statewide
Broader commercial inventory at ~6,276 listings — constraint shifts from availability to competition outside rural footprint
~200+
Stage 2 · Model Development · Section 2.2
Clinical Model & Care Protocols
Scope of services, CCM/APCM/RPM enrollment protocols, and the visit-first clinical philosophy. Increasing visits and managing chronic conditions is the entire economic engine.
§ 2.2SPARK Senior Health Investment Book · 2025–2026
Scope of Services
What we do · what we refer · built to maximize visits and chronic care maintenance
Core Services (fixed clinic)
Annual Wellness Visit — attribution anchor
Well + preventive + screening visits
Chronic disease management (HTN, DM, COPD, CHF)
CLIA-waived POC labs (i-STAT Alinity)
Vaccines: flu, pneumococcal, shingles, COVID
Acute episodic (within LPN/NP scope)
CCM enrollment + monthly 20-min protocol
APCM (G0556/G0557/G0558) monthly billing
RPM device setup + monthly data review
Transition of Care (7-day call, 30-day visit)
FFS-Duals Care Coordination
LTSS navigation for Medicaid-covered services (non-billing)
SDOH screening + follow-up
NEMT coordination for transport-dependent members
Dental / vision referral pathway
Telehealth-Supported (NP remote)
Specialist consult via Zone 4 telehealth room
Complex Dx/Rx — NP via Doxy.me (GA SB 128 compliant)
APCM advantage: No monthly time tracking required. Billing-friendly — especially on visit months when CCM time is harder to document separately. Mutual exclusion with CCM in same month for same patient.
CCM Protocol — 2026 CMS Rates
Chronic Care Management · 45% of panel · 82% billing success · Chronic Care IQ auto-logs time
99490 · 20 min non-complex/month
55% of CCM panel · clinical staff time
~$56/mo
99439 · each add'l 20 min
No monthly limit on additional units
~$43/mo
99487 · complex CCM, 60 min
35% of CCM panel · multiple chronic, complex plan
~$123/mo
99489 · complex add-on 30 min
10% of CCM panel add-on
~$66/mo
CCM eligibility: ~45% of panel — 2+ chronic conditions, documented 20 min/month non-face-to-face care management. Chronic Care IQ auto-populates time logs. Top OIG audit risk — EHR-integrated documentation is non-negotiable.
The Visit-to-Revenue Chain
Rural NE Georgia FFS seniors average only 1.4 PCP visits/year vs 3.2 nationally. Every visit we generate drives the entire downstream revenue chain: AWV establishes attribution → CCM/APCM enrollment ($13–$91/mo recurring) → RPM enrollment (net ~$27/mo after device COGS) → chronic disease management improves → ER visits drop → CMS saves → CMMI funds us. Visits are the root metric. Everything else follows. Transportation to the clinic removes the last barrier — a van comes to pick you up.
1.4
Current PCP visits/yr rural NE GA FFS
→ 4.0–6.5
Our Y1→Y2 target ramp
~$239
Blended PMPM at full enrollment (base scenario)
Runs every month between visits
60%+
Of steady-state revenue from non-visit programs
Visit enables enrollment; enrollment pays monthly
Stage 2 · Model Development · Section 2.3
Staffing Model — Stage-Driven Clinic + MSO
Per-clinic staffing scales with member count through five stages. MSO staffing grows annually with 5 named Y1 hires ramping to 16 by Y3. Georgia scope-of-practice analysis and compensation benchmarks included.
§ 2.3SPARK Senior Health Investment Book · 2025–2026
Per-Clinic Clinical Staffing Roles
Stage-driven hiring · GA scope of practice · 25% benefits load on all roles
NP / APRN — Primary Clinician
NP conducts all clinical assessments — diagnoses, prescribes (including Schedule II under 2024 GA law expansion), orders labs, manages chronic disease, supervises field team. Telehealth or in-clinic. Must sign Nurse Protocol Agreement with Medical Director before any clinical activity. NPI triggers PECOS enrollment clock — hire first.
NP base: $125,000 · Loaded ×1.25: $156,250/yr
Medical Director / MD — Supervising Physician
Signs Nurse Protocol Agreement. Available via audio/video during all clinical hours (GA requirement). Handles escalated complex cases, incident-to billing NPI optimization, co-signature requirements. Does NOT require physical presence. Billing: E&M/AWV/TOC billed under MD NPI for 100% rate + 10% HPSA bonus.
MD retainer: $30K–$54K/yr (launch → full panel) · Part-time/fractional
LPN — Field Clinical Support
Conducts intake vitals (Vital Signs Station), POC testing, vaccination administration, CCM/RPM enrollment support, specimen collection, basic wound care. GA law permits LPN to draw blood — phlebotomy training required, no separate phlebotomist needed at launch. Works under NP supervision. Adds Part-Time Care Coordinator at Stage 2 (200–400 members).
LPN base: $52,000 · Loaded ×1.25: $65,000/yr
Care Coordinator — Remote
Manages CCM panel (300–600 active members per FTE), RPM alert monitoring (Tenovi dashboard), TOC outreach cadence, specialty referral tracking. For FFS-Duals: LTSS navigation, SDOH screening follow-up, NEMT coordination. Critical for CCM revenue — each missed 20-min monthly contact is lost billing. Time logged in Chronic Care IQ (auto-populates from activity).
Care Coordinator base: $55,000 · Loaded ×1.25: $68,750/yr · Added at Stage 2
Driver — Transportation & Logistics
Handles member transport (picks up members who cannot self-transport to the clinic), vehicle logistics, and route optimization. Does not provide clinical care. Routes planned prior afternoon via route optimization software. Breakdown response: rental standby contract within 2 hours. 1 driver per active clinic — every clinic, from Day 1.
Driver base: $45,000 · Loaded ×1.25: $56,250/yr · Every active clinic
Five-Stage Per-Clinic Staffing
Member-count triggered · each clinic runs its own stage clock independently
Stage
Members · Staff Added
Launch
0–200 members · Remote NP + LPN + Driver
Building
200–400 members · + Care Coord (0.5)
Steady State
400–650 members · + FT Care Coordinator + PT Admin
Two-NP
650–800 members · + 2nd NP + 2nd LPN
Full Clinic
800–1,000 members · Full team · Terminal PMPM
Georgia Scope of Practice — Key Rules
What each role can do in clinic · GA 2024 rules
NP in GA (2024):Diagnose, prescribe (Schedules II–V), order diagnostics under collaborative agreement. Supervision ratio 8:1. No physician physically on-site required — audio/video presence satisfies requirement.
LPN in GA:Administer medications (including injections/vaccines), collect specimens, draw blood, perform ECG. Cannot independently diagnose or prescribe. Works under NP supervision at all times.
Telehealth (GA SB 128):NP may prescribe via telehealth without in-person prior visit for most conditions. Audio-video required; audio-only limited to specific circumstances. Hub-and-spoke model fully compliant.
Escalation Protocol:Field LPN → remote NP → supervising MD → 911/ER. Decision tree by condition type must be documented before first patient. LPN cannot independently manage uncontrolled acute conditions.
Stage 2 · Model Development · §2.3 Physician Staffing · Part 1 of 2
Physician Staffing — Compliance Cadence & Phase 1
Telemedicine-based physician supervision is legally sound in Georgia — but "remote" does not mean "zero in-person." One compliance element cannot be satisfied remotely. Phase 1 uses vendor-sourced placement to reach compliance immediately without direct-hire risk.
§ 2.3SPARK Senior Health Investment Book · 2025–2026
Required Compliance Cadence
Per Ga. Comp. R. & Regs. R. 360-32-.02 and R. 360-32-.05
Requirement
Frequency
Remote OK?
Immediate consultation availability
Continuous
Yes
Clinical collaboration meeting
Quarterly (min)
Yes
Medical records / chart review
Quarterly (min 10%)
Yes
Controlled-substance patient eval
Quarterly (min)
Ambiguous
Direct onsite observation of APRN practice
At least annually
No — in-person required
Physicians who "never visit" their delegated sites are documented enforcement targets. Each Regional MD's contract must calendar the annual onsite visit as a firm obligation, not a best-effort commitment.
Geographic Constraint
GA-based or within 50 miles · telehealth doesn't override this
Georgia defines an eligible delegating physician as one whose principal place of practice is within Georgia, or outside Georgia but within 50 miles of where the nurse protocol agreement is being utilized. A nationwide telehealth roster does not satisfy this. SPARK's sourcing pool is Georgia-licensed physicians — border county NPs (Rabun, Union, Fannin) may use physicians in adjacent NC/TN within the 50-mile band.
8:1 Ratio — Confirmed by Statute
O.C.G.A. § 43-34-25 · combined NPs + PAs
8:1
Combined NPs + PAs per physician
PAs and NPs draw from the same shared pool — mixing credentials does not create or cost extra physician capacity. 3 MDs cover all 20 NPs across 10 clinics at this ratio.
Phase 1 · Vendor-Sourced Collaborating Physicians
Clinics 1–2 (~4 NPs) · use established GA-focused placement service · not direct-hire
Why vendor placement at launch?
Firms such as Medical Director Co. and Zivian Health specifically match APRNs with Georgia-licensed physicians, prepare the nurse protocol agreement paperwork, and manage board filing — turning a multi-month sourcing problem into a matter of days. SPARK has the least infrastructure to absorb delay at launch.
Retainer — Launch Budget
$2,500–$5,000
per month · per clinic · fixed fee only
Why not the $700–$900 range?
Those rates are weighted toward low-liability med-spa/GLP-1 clinics. SPARK's high-chronic-disease elderly Medicare population carries materially higher liability — budget to the upper range.
Fee Structure Rules
✓Fixed monthly retainer — not a percentage of revenue or per-patient fee. Anti-kickback exposure attaches to percentage-of-profit arrangements when the physician relationship overlaps with referral patterns.
✓No revenue sharing, no equity — clean structure, no long-term physician economic dependency.
⚠Confirm GA licensure + geography — some national placement services default to nationwide rosters. Verify the placed physician is Georgia-licensed and within the 50-mile rule for each specific clinic address.
Transition trigger: Move from vendor placement to contracted Regional Medical Directors (Phase 2 hub model) as clinic count reaches 3–5 and multiple physician relationships need centralized standardization.
Stage 2 · Model Development · §2.3 Physician Staffing · Part 2 of 2
Physician Staffing — Regional Hubs, CMO Timing & PC Mechanics
Phase 2 transitions to three contracted Regional MD hubs. CMO hire has two distinct milestones — nominal PC owner (immediate) vs working paid function (Phase 2 transition). PC must be 100% physician-owned by Georgia statute with a stock transfer restriction mechanism for continuity.
§ 2.3SPARK Senior Health Investment Book · 2025–2026
Each Regional MD contract must explicitly schedule the compliance cadence (quarterly chart review, quarterly collaboration meeting, annual onsite visit per clinic) as calendared obligations — not best-effort commitments. Illustrative clustering; rural physician supply per hub should be validated before finalizing territory assignments.
CMO — Two Milestones, Not One Hire
Nominal PC owner = immediate · Working paid CMO = Phase 2 transition trigger
Milestone 1: Nominal PC Physician-Owner — Day 1
Georgia's CPOM framework requires the PC to be 100% physician-owned from formation. This is a prerequisite for operating at all, not a future hire. This physician holds nominal ownership but is not a working CMO.
Milestone 2: Working Fractional CMO — Phase 2 (~3–5 clinics)
Multiple contracted physicians first need centralized standardization. Convert the role from a passive nominee into a working fractional CMO at $5,000–$20,000/month depending on scope.
Milestone 3: Full-Time W-2 CMO — Pre-Institutional Raise
Convert fractional to full-time no later than the point SPARK pursues accreditation or an institutional capital raise. Investors expect a credible, named clinical executive as a governance signal. Unlocks ISO equity eligibility vs NSO for contractors.
Governance — Two Independent Tracks
Clinical track and administrative track must never be conflated — that is what CPOM compliance requires
Clinical Track
CMO (as Georgia PC physician-owner) sits at the top of the clinical chain and answers to no one at the MSO on clinical judgment. CMO → Regional MDs → NPs (via nurse protocol agreements). This independence is the entire basis for CPOM compliance.
Administrative Track
CMO (in a separate capacity as MSO officer) is accountable to the CEO and board for budget, growth targets, and compliance reporting. This accountability must stop at the CPOM boundary — it cannot extend into directing patient care or physician supervision.
The dashed line on governance charts marks what must never exist: a direct clinical-authority connection from the MSO to the delegating physicians or NPs.
PC Ownership Mechanics
O.C.G.A. § 14-7-4 · 100% physician-owned · ongoing dependency · 3-month grace period on license expiration
1.File Articles of Incorporation naming the CMO as incorporator; PC issues shares at nominal value (PC has little independent economic value once the MSA channels most revenue to the MSO).
2.Execute a Stock Transfer Restriction Agreement between the CMO and the MSO — restricts who the CMO may transfer shares to, and gives the MSO the right to force a transfer to an MSO-approved replacement physician at nominal price on exit, death, disability, license loss, or breach. This is the actual compliance mechanism that keeps the PC "friendly."
3.Execute a Physician Services / Medical Director Agreement (CMO ↔ PC, Track 1 FMV compensation) and the MSA (PC ↔ MSO, the business-services contract).
⚠Georgia allows only a 3-month grace period after a physician's license expires before ownership is automatically disqualified. License-renewal monitoring must be built into SPARK's compliance calendar — not a one-time formation check.
Structuring Flags for Counsel
→Draft NPA agreements to take advantage of the full combined 8-APRN/PA cap — not separate 4+4 limits from the prior rule.
→Ensure Regional MD relationship runs through the Georgia PC, not in a way that inverts the supervisory relationship (GA prohibits a physician from being effectively employed by the APP they supervise — May 2026 position statement).
→Confirm whether quarterly controlled-substance patient evaluation can be satisfied via telehealth — affects both compliance calendar and physician time commitment materially for SPARK's high-chronic-disease population.
Stage 2 · Model Development · §2.3 NP & PA Recruitment · Part 1 of 3
NP & PA Recruitment — Why It's a Top-Tier Risk & Six-Pillar Strategy
Georgia is a restricted-practice state ranking near the bottom nationally for NP compensation. Each SPARK clinic needs 2 NPs to operate — clinical throughput, CCM/APCM/RPM billing, and patient experience all depend directly on filling and retaining these roles.
§ 2.3SPARK Senior Health Investment Book · 2025–2026
Restricted
GA practice state — NP must have collaborative agreement with MD before first patient encounter
Bottom 10
GA NP compensation nationally — directly linked to restricted-practice suppression of comp
2 per clinic
NPs required per 1,000-member clinic — the entire revenue model depends on filling these roles
$7,500
Preceptor tax credit per student starting Jan 2026 — converts rotation hosting into a recruiting subsidy
Pillar 1
Grow-Your-Own Pipeline
Precept students from three NP programs anchored in or adjacent to SPARK's footprint. Host clinical rotations and claim the $7,500/preceptor state tax credit starting Jan 2026. Note: none of these three offers an AGPCNP track — closest AGPCNP programs are 3+ hours away (Savannah, Statesboro), though their online format allows in-region clinical placement if SPARK registers as an approved preceptor site.
UNG — Dahlonega (Lumpkin Co.) · FNP only
Piedmont University — Demorest (Habersham Co.) · FNP only
Brenau University — Gainesville (adjacent) · FNP + AGACNP · guarantees GA-resident placement within 100 miles
Pillar 2
SPARK Geriatric Residency
Model the onboarding mechanism on HRSA's NoGAPP FNP residency (structured year, phased autonomy, FQHC/Emory partnership active in this exact NE Georgia region) — but substitute a geriatric-specific curriculum (polypharmacy, multi-morbidity, dementia/fall-risk screening, CCM/APCM/RPM workflows) for NoGAPP's general-lifespan content. SPARK's panel is Medicare FFS-only and does not include pediatrics or obstetrics.
Addresses the #1 reason new NPs avoid rural posts: lack of structured support. Also the single highest-leverage retention lever — new-grad discomfort with rural isolation is a primary driver of early attrition.
Pillar 3
Debt-Relief Sequencing
Candidates can apply to multiple programs simultaneously but may only hold one active service-obligation contract at a time — these sequence, they don't stack. Present as a multi-year path during offer negotiation.
GA APRN LRP — up to $10K/yr × 4 yrs ($40K max) · full-time practice in eligible rural county with active Medicaid
NHSC LRP — up to $50K for 2-yr full-time · requires SPARK clinic registered as NHSC-approved HPSA site (pursue proactively)
Nurse Corps LRP — up to 85% of unpaid nursing education debt · critical-shortage facilities
Pillar 4
Market-Aware Compensation
Price above the rural GA NP average (GA ranks near the bottom nationally partly due to restricted-practice comp suppression) with base + productivity bonus tied to panel outcomes, plus a relocation/signing bonus explicit about the rural trade-off. Avoid the trap of matching urban NP comp without acknowledging the rural cost-of-living advantage and debt relief overlay.
Structure
Base + productivity bonus
Positioning
Above rural GA average
Pillar 5
Physician Delegation Architecture
Build the medical director / supervising physician relationship as core infrastructure, not an afterthought. Hub-and-spoke MD model with telehealth-enabled oversight removes the structural barrier candidates otherwise have to solve themselves — a leading friction point for NPs evaluating rural offers in GA. Nurse Protocol Agreements pre-structured with clear scope, escalation paths, and MD availability protocols before the first hire offer goes out.
Pillar 6
National Sourcing (Bridge Strategy)
Run LinkedIn Recruiter and healthcare staffing-agency search in parallel with Pillars 1–2 to fill early clinics while the regional pipeline matures over its 12–24 month build-out. Primary channel for AGPCNP-credentialed candidates specifically, since that credential has no regional program feeder. Budget as a real cost — agency contingency fees run $18,750–$25,000 per NP placement. Set candidate expectations early on Georgia's restricted-practice supervision requirement.
LinkedIn RecruiterStaffing agencies (contingency)Bridge only — not default channel
Stage 2 · Model Development · §2.3 NP & PA Recruitment · Part 2 of 3
NP & PA Recruitment — County Eligibility, Debt Relief & Credential Targeting
Nine of ten SPARK counties qualify for Georgia's state APRN Loan Repayment Program — a direct recruiting subsidy funded by the state, not SPARK. Credential targeting distinguishes AGPCNP, FNP, and PA to optimize fill speed and avoid common mismatch errors.
§ 2.3SPARK Senior Health Investment Book · 2025–2026
County-by-County State APRN LRP Eligibility
GA APRN Loan Repayment Program · counties ≤50,000 population · 2024 ACS 5-yr estimates
County
Pop.
LRP Status
Note
Rabun
17,312
Eligible
Confirm HRSA HPSA score
Chattooga
25,036
Eligible
Confirm HRSA HPSA score
Fannin
25,742
Eligible
Confirm HRSA HPSA score
Union
26,304
Eligible
Confirm HRSA HPSA score
Stephens
27,012
Eligible
Confirmed SPARK site
White
28,810
Eligible
Confirm HRSA HPSA score
Gilmer
32,426
Eligible
Confirm HRSA HPSA score
Lumpkin
34,505
Eligible
Confirmed SPARK site
Habersham
47,793
Near threshold
Confirmed SPARK site · verify current count
Gordon
59,100
Verify — over 50K
May be excluded from state APRN LRP
Pop. = 2024 ACS 5-yr estimates. Confirm each county against the current official map before finalizing offer terms — program rules subject to change. NHSC LRP also requires the hiring site to be a registered NHSC-approved HPSA site — pursue registration for each clinic proactively, not at offer stage.
Credential Targeting: AGPCNP + FNP + PA
Not all NP credentials are equal fits · avoid the AGACNP mismatch trap
AGPCNP — Adult-Gerontology Primary Care NP
Closest purpose-built match — primary care spanning adolescents through older adults, chronic and multi-morbid outpatient conditions. Trade-off: smaller candidate pool nationally.
FNP — Family Nurse Practitioner
~70% of all practicing NPs. Fully qualified to treat seniors; less age-specialized than AGPCNP but the workhorse credential SPARK will fill most positions from in practice. Has regional program feeders.
AGACNP — Exclude from Panel Postings
Despite the similar name, AGACNP trains for hospital/ICU-level acute care — not outpatient primary care. Exclude from panel NP job postings entirely.
PMHNP — Targeted Specialist Only
Track for Behavioral Health Integration program line as it scales — not a general panel NP credential. Do not include in primary panel postings.
Debt Relief as a Recruiting Lever — Sequential, Not Stacked
Programs sequence · HRSA rules prohibit concurrent service obligations
Per HRSA's own program rules, clinicians may apply to as many programs as they're eligible for but may not hold more than one active service obligation at the same time. A new federal award will not be granted until any existing service obligation is complete.
Realistic candidate path: Complete GA APRN LRP (2–4 yr commitment, up to $40K) → apply remaining debt against NHSC LRP (2-yr, up to $50K) → Nurse Corps LRP (up to 85% of nursing education debt). Present as a multi-year sequence during offer negotiation — compounding over a SPARK tenure, not a single year-one stack.
Stage 2 · Model Development · §2.3 NP & PA Recruitment · Part 3 of 3
NP & PA Recruitment — NP vs PA Parity, Sourcing Costs & Regulatory Architecture
PAs are a real alternative — not a fallback. Ratio parity is confirmed by statute. Two regional PA programs are closer to SPARK's footprint than any AGPCNP program. National sourcing has real, budgetable costs. GA HB213 (full practice authority) is a policy tailwind, not a planning dependency.
§ 2.3SPARK Senior Health Investment Book · 2025–2026
NP vs PA — Rough Parity for SPARK
Several factors resolve to parity or a slight PA advantage · widen postings to include PA
Ratio — identical: O.C.G.A. § 43-34-25 confirms combined 8-provider cap for NPs + PAs. Hiring a PA instead of an NP does not free up or cost any additional physician-supervision capacity.
Authority mechanism — different (but clinical outcome same): PA's authority is a derivative grant from the supervising physician's license. NP's authority comes from the APRN's own nursing licensure, with the protocol agreement as a required linkage. Matters for liability attachment and payer credentialing framing — not for day-to-day clinical work.
Training model — PA advantage: PA programs use a generalist medical-school-style curriculum with one national exam (PANCE). No credential-mismatch risk equivalent to AGPCNP vs AGACNP — a PA candidate doesn't need to be sorted into the "right" age-specific track.
Compensation — wash: National medians run close (NP ~$129–133K vs PA ~$130–134K). GA-specific sources disagree enough that no single source supports a confident cost advantage. Decide by candidate fit, not credential.
Regional PA programs: Berry College (Mount Berry, Floyd Co. — 24 months, near Gordon/Chattooga hub) and Brenau University (Gainesville — 28 months, adjacent to Habersham/White/Lumpkin hub). Closer than any out-of-region AGPCNP option.
Practical recommendation: Include PA alongside AGPCNP and FNP in all clinical job postings. Regulatory and cost parity means this is a pure sourcing decision — more open credentials searched simultaneously means faster fills.
National Sourcing — Real Costs, Not Free Channel
Budget accurately · use selectively for AGPCNP credential gap and Year 1–2 bridge
LinkedIn Recruiter
Tier
Annual Cost
Lite (1st–3rd connections only)
~$1,680–$2,040/seat
Corporate (full database)
~$9,000–$15,000/seat + InMail overages (~$10/msg)
Lite restricts search to 1st–3rd-degree connections, limiting reach into a national passive-candidate pool. Corporate tier needed for genuine national AGPCNP sourcing.
Agency Contingency Fees
$18,750–$25,000
per NP/PA placement · 15–20% of first-year base ($125K base) · rural and underserved locations sit at the high end of this range · paid only on placement
Recruiter and regional-pipeline hires can run in parallel per role without conflict (fee is contingent on placement). Use agencies selectively for the AGPCNP credential gap and Year 1–2 bridge — not as the default channel for every opening.
Policy Tailwind
GA HB213 (proposed full practice authority) — if enacted, would remove the delegation requirement and materially widen SPARK's addressable NP labor pool. Monitor as a tailwind, not a planning dependency. Recruiting plan above is fully viable under current restricted-practice law.
Regulatory Architecture as Competitive Advantage
Turning the supervision requirement into structured onboarding rather than a bare compliance cost
Hub-and-Spoke MD Model
Build toward the 8-APRN/PA-per-physician ceiling using telehealth-enabled oversight connecting physicians to NPs across multiple rural sites rather than requiring daily on-site presence. Pre-structured Nurse Protocol Agreements with clear scope and escalation paths removes the structural barrier candidates otherwise have to solve themselves.
SPARK Geriatric Residency Model
Frame the first year as a structured on-ramp (NoGAPP model: rotating exposure, defined mentorship, phased autonomy) with a geriatric-specific curriculum substituted for NoGAPP's general-lifespan content. Single highest-leverage retention lever — new-grad discomfort with rural isolation is the primary driver of early attrition.
Statewide Scalability
GA loan repayment programs, preceptor tax credit, and AHEC-supported rural residency infrastructure are statewide resources, not regional pilots. Pipeline relationships SPARK builds now (regional NP programs, FQHC residency partners, state workforce board) scale directly into the next phase of county expansion without rebuilding the recruiting model from scratch.
GA HB213 tailwind: Full practice authority bill currently being monitored. If enacted, removes physician delegation requirement and materially widens addressable NP labor pool. Plan is fully viable under current law — treat as upside, not prerequisite.
Stage 2 · Model Development · §2.3 LPN Recruitment & Retention · Part 1 of 2
LPN Recruitment — A Different Problem: Strong Local Pipeline, Real Retention Risk
LPN staffing is structurally easier than NP recruiting — Georgia's restricted-practice law does not apply to LPNs. The real constraint is retention: LPN is widely used as a stepping-stone to RN, and Georgia's technical college system makes that transition easy and local.
§ 2.3SPARK Senior Health Investment Book · 2025–2026
10 / 10
SPARK counties served by a TCSG LPN program — stronger in-county coverage than the NP pipeline
$49,530
Georgia median LPN salary — workable without the loan-repayment stacking NP recruiting requires
12 months
TCSG LPN training timeline vs ~8–9 years for AGPCNP/FNP — never the long pole in clinic staffing
Retention
The real LPN risk — not recruiting scarcity but LPN-to-RN attrition via the local NGTC bridge program
TCSG LPN Program Coverage — All 10 SPARK Counties
In-county campuses at 4 counties · all 10 in service area · 12-month Certificate of Credit program
County
TCSG College
Nearest Campus
Coverage
Stephens
North Georgia Technical College
Currahee Campus — Toccoa
In-county ★
Habersham
North Georgia Technical College
Clarkesville (in-county)
In-county ★
Union
North Georgia Technical College
Blairsville (in-county)
In-county ★
Gordon
Georgia Northwestern TC
Calhoun (in-county)
In-county ★
Rabun
North Georgia Technical College
Clarkesville / Toccoa
In service area
Fannin
North Georgia Technical College
Clarkesville / Blairsville
In service area
White
North Georgia Technical College
Clarkesville / Toccoa
In service area
Lumpkin
Lanier Technical College
Oakwood, Hall Co.
In service area
Gilmer
Chattahoochee Technical College
Appalachian Campus — Jasper
In service area
Chattooga
Georgia Northwestern TC
Rome / Calhoun
In service area
★ = in-county campus. "In service area, no in-county campus" counties are still served — Georgia's technical college tuition and admission structure applies statewide, but students commute to a neighboring county's campus.
Training Timeline Comparison
12 months vs 8–9 years — LPN should never be the long pole in clinic staffing
12 mo
LPN
TCSG Practical Nursing Certificate of Credit
8–9 yr
AGPCNP / FNP
BSN → RN experience → MSN/DNP
Compensation Context
No loan-repayment stacking required · rural technical-college-trained LPNs hired locally
GA Median LPN
$49,530
BLS May 2024 OEWS (SOC 29-2061)
SPARK Loaded Rate
$65,000
$52K base × 1.25 benefits load
Rural technical-college-trained LPNs are generally hired locally rather than recruited from a distance — reduces reliance on the relocation incentives central to the NP strategy. Wage progression (see Part 2) is more effective than a high signing bonus for this population.
GA Law: What LPNs Can Do
✓Administer medications (including injections and vaccines)
✓Collect specimens, draw blood — phlebotomy training required but no separate phlebotomist needed at launch
✓Perform ECG, basic wound care
✗Cannot independently diagnose or prescribe — works under NP supervision at all times
Stage 2 · Model Development · §2.3 LPN Recruitment & Retention · Part 2 of 2
LPN Retention — Four Levers, Recruitment Channels & Role Design
NGTC's LPN-to-ASN bridge program at Toccoa is the primary retention risk — the same local infrastructure that makes LPNs easy to recruit also makes it easy for them to leave for RN status within 1–2 years. The strategy below treats the bridge pathway as something to sponsor and route back into SPARK, not something to block.
§ 2.3SPARK Senior Health Investment Book · 2025–2026
Four Retention Levers
Each addresses a distinct reason LPNs leave rural healthcare employers within 1–2 years
Fund an LPN's RN bridge program (available at NGTC's Currahee / Toccoa campus and other TCSG sites) in exchange for a 1–2 year post-completion service commitment at SPARK, ideally into a higher-value role. Converts the attrition risk into a retention and internal-promotion tool. Staff who see SPARK funding their advancement are far less likely to resign mid-program.
2. Structured Wage Progression
Step increases at defined milestones — 12, 24, and 36 months — tied to competency checkpoints, not just tenure. LPNs who would otherwise leave for a $2/hr raise at a competing facility see a better path staying with SPARK. The highest-attrition window is months 6–18 after hire; the 12-month step must be meaningful enough to bridge that window.
3. Clinical Rotation Hosting
Formal clinical site partnerships with NGTC and Georgia Northwestern TC for TCSG Practical Nursing rotations — the LPN-program equivalent of the NP preceptor relationship. Students rotate through SPARK clinics and meet their future employer before graduation. No formal tax-credit mechanism (unlike NP preceptors), but first-offer conversion rate from rotation hosts typically exceeds 60% in small local labor markets.
4. Role Design — LPN + Care Coordinator Combined
Combine the LPN and Care Coordinator functions into a single, broader role. The combined ~2.0 FTE support ratio is consistent with benchmarks for chronic-care-management-intensive practices. A more clinically engaged, higher-scope role is more resistant to attrition than a narrowly-scoped clinical assistant role — independent of the cost question. Particularly effective for LPNs with social work or case management inclinations.
Recruitment Channels
Local-first approach · rotation hosting is the highest-leverage first-look channel
Clinical Rotation Hosting
Offer SPARK clinics as rotation sites for TCSG Practical Nursing students — particularly NGTC's three in-footprint campuses (Clarkesville, Toccoa, Blairsville). Students see the working environment before graduation; SPARK sees candidates before the broader job market does.
TCSG Career Services
Each technical college maintains job placement support for graduating cohorts. Direct relationships with program directors at NGTC, Lanier TC, Chattahoochee TC, and Georgia Northwestern TC — a low-cost, high-relevance channel given the local, non-relocating nature of most LPN hires.
Internal Pipeline — CNA / Nurse Aide Roles
Several TCSG colleges offer nurse aide-to-LPN progression tracks. If SPARK ever staffs any lower-tier clinical support roles, these can double as an internal LPN pipeline — motivated individuals already oriented to SPARK's workflows and culture.
The Retention Risk in Detail
NGTC Toccoa — LPN-to-ASN bridge is inside SPARK's primary footprint
North Georgia Technical College runs an LPN-to-ASN (RN) bridge program based at its own Currahee campus in Toccoa — inside SPARK's footprint. That is convenient for the individual nurse's career and a direct turnover exposure for SPARK: train an LPN into clinic-specific CCM/APCM/RPM workflows, and the same local infrastructure that made them easy to hire also makes it easy for them to leave for RN status within a year or two.
Risk scenario without intervention:
SPARK invests 12–18 months training an LPN into CCM/APCM/RPM workflows → LPN enrolls in NGTC's ASN bridge → exits at the 18–24 month mark for a hospital RN role at 40% higher pay → SPARK restarts the pipeline.
With Lever 1 (Tuition-for-Service):
SPARK sponsors the ASN bridge in exchange for a service commitment → LPN completes RN → returns to SPARK in a higher-value care coordinator or team lead role → net outcome is a more capable, more loyal employee with a 3+ year tenure.
Staffing Capacity Context
The combined LPN + Care Coordinator workload for a 500-member / 70–80% APCM-CCM-penetration clinic is approximately 2.0 FTE support staff. This is consistent with chronic-care-management-intensive practice benchmarks — not excessive staffing for a standard visit-based clinic. Combining the LPN and Care Coordinator into a single broader role (see Lever 4) addresses both the retention and capacity questions simultaneously: fewer distinct roles to fill, higher scope per role, and better economics per member served.
Stage 2 · Model Development · Section 2.4
AI & Technology Integration
The finalized technology stack — EHR, CCM platform, AI documentation, RCM, RPM, telehealth, connectivity, and operations. Technology serves the clinician; every vendor selection maps to a specific billing or compliance function.
§ 2.4SPARK Senior Health Investment Book · 2025–2026
Morning huddle (7:30 AM): LPN + NP teleconference. Day's schedule, overnight RPM threshold breaches, care gap alerts surfaced from EHR. Patient context delivered before clinic opens.
2
Check-in (Klara + EHR): Patient SMS check-in via Klara ($300/clinic/mo flat). Insurance verification, last-visit summary, care gaps (missing AWV, overdue A1c, lapsed CCM) flagged in EHR before exam room opens.
3
Vitals (Vital Signs Station): LPN captures BP, weight, SpO2, temperature. i-STAT POC lab if ordered. All values auto-integrate into Commure pre-visit structured note delivered to NP via Doxy.me or in-clinic.
4
Encounter (Commure Ambient): AI ambient scribing during exam. CPT coding suggestions validated by NP. CCM time auto-logged in Chronic Care IQ from coordinator activity. Documentation complete before patient exits.
5
Checkout + claims (5:00 PM): Next visit scheduled, RPM reading confirmed, CCM follow-up queued. Clean claim submitted same day: Commure RCM → Palmetto GBA J-J. QMB status verified before submission. Target: $0 next-day unbilled encounters.
AI capacity multiplier: Commure Ambient enables one NP to supervise 10–14 encounters/day vs 4–6 in a traditional non-AI model — a 2–3× throughput improvement. Critical for the per-clinic unit economics.
Open Item — EHR SelectionAthelas AIR vs Athenahealth. Must demo CCM time tracking, offline mode, Palmetto GBA J-J EDI compatibility, and Commure integration before deciding. EHR must be live before PECOS enrollment is finalized. $750/provider/month for either option.
Technology Stack — Core Clinical
Finalized vendors · pricing included in financial model · EHR selection is final open item
Category
Vendor
Pricing
EHR
Athelas AIR or Athenahealth (open item)
$750/provider/mo
CCM/APCM Platform
Chronic Care IQ — auto time-logs, care plan templates
Rippling — all devices MDM-enrolled, payroll unified
$12/employee/mo + $35 base
Business Email
Proton Business — HIPAA-compliant encrypted email
$9/user/mo
Knowledge Base
Notion — clinical protocols, SOP library
$13/user/mo
HIPAA Compliance
Compliancy Group — BAA management, audit readiness
$400/mo flat
Analytics
Looker Studio — PMPM, utilization, claims dashboards
$0 (free tier)
Architecture Principles
→EHR is the system of record. All other platforms connect via API. No manual dual-entry anywhere in the stack.
→Offline capability required. Rural dead zones in NE Georgia are real. EHR must function offline and sync on reconnection.
→Palmetto GBA J-J MAC. All GA Medicare claims route through Palmetto GBA J-J. Clearinghouse EDI compatibility confirmed before first claim.
→Fiber lead time. 4–8 week installation. Initiate fiber order during clinic buildout — not after lease signing.
Stage 2 · Model Development · Summary
Stage 2 Key Decisions & Open Items
Model defined across clinic design, clinical protocols, staffing, and technology stack. One open flag remains before go-live. Proceed to Stage 3 — Financial Model.
SummarySPARK Senior Health Investment Book · 2025–2026
~2,200
Sq ft per fixed clinic · ADA-compliant · 6 clinical zones · leasehold ~$98.5K
6 Zones
Clinical zones mapped to billable CPT codes · intake → exam → lab → telehealth → meds → workspace
NP + LPN
Stage-driven hiring · MD retainer for supervision · driver at every active clinic from Day 1
~$239
Blended PMPM at full enrollment · base scenario · APCM + CCM + RPM + E&M + AWV
10–14
Visits per day per clinic · ~200/month · transport van brings non-driving members in
1 Open
EHR selection (Athelas AIR vs Athenahealth) — must resolve before PECOS enrollment
§2.1–2.2 · Clinic Design & Clinical
Fixed ~2,200 sq ft ADA-compliant clinic at ~$198K expansion CapEx. Six interior zones mapped directly to billable CPT codes. APCM (G0556/G0557/G0558), CCM (99490 series), and RPM (99454/99457) protocols at 2026 rates yield ~$239 blended PMPM. Escalation protocol (LPN → NP → MD → 911) documented before first patient. FFS-Duals LTSS navigation is care coordination, not a separate billing line.
§2.3–2.4 · Staffing & Technology
Stage-driven per-clinic staffing (Launch → Full Clinic, 5 stages by member count · ranges 0–200 through 800–1,000). MSO scales from 5 named Y1 hires to 16 by Y3. Finalized tech stack: Commure Ambient + RCM, Chronic Care IQ, Tenovi RPM, Klara, Doxy.me, Bamboo PatientPing, Samsara, Rippling. AI multiplier: 10–14 visits/day per NP vs 4–6 without AI. EHR selection is the final open item before PECOS enrollment.
Next Stage
Stage 3 — Financial Model
Revenue model · Reimbursement schedule · CCM/APCM/RPM PMPM detail · 5-year P&L · Capital structure · Investor ROI scenarios