A nationally recognized health system was in discussions to acquire a physician-owned ambulatory surgery center (ASC) in a new market. Stout was engaged by the health system to serve as its valuation advisor and prepare both a fair market value and commercial reasonableness opinion for purposes of compliance with the Stark and Anti-Kickback Laws. We reviewed and analyzed the historical financial performance, procedure and payer mix, case volume, and expense structure of the ASC and interviewed the physician owners to develop a discounted cash flow analysis. We also researched and analyzed comparable surgery center transactions for a merger and acquisition analysis. Our opinion was used by the system’s deal team to negotiate and complete the transaction.