The healthcare industry has recently become the target of increased scrutiny from multistate unclaimed property audits, likely due to the high volume of mergers, acquisitions, and private equity deals. These audits have shed light on the many complexities and challenges within the sector. Healthcare industry holders are often pressured by state auditors and administrators to fit a square peg in a round hole – something both they and their advocates should continue to actively push back against.

Identifying whether any “property” needs to be reported can be a significant challenge in an industry where a single patient transaction involves multiple parties and is governed by intricate business agreements, which are continuously updated and managed. Unclaimed property audits, however, are typically conducted with a narrow focus on a single holder and use standardized document requests designed for a broad range of businesses. This approach often leads to unrealistic expectations for record retention and management, which rarely align with the specific laws and practices of the healthcare industry.

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