Model study · SBA 504

    Owner-Occupied Medical Office Building Under SBA 504 in Hennepin County, Minnesota: A Model Study

    By Sarrah Allen, MAI, Principal · Updated

    Model study: an illustrative feasibility analysis built on public data for Hennepin County, Minnesota; not a client engagement.

    Project summary

    ItemModelled position
    AssetNew two-storey medical office building, owner-occupied
    Size19,200 gross sq ft; 18,000 rentable sq ft (rsf)
    OccupancyMulti-specialty group 14,400 rsf (80.0%); 3,600 rsf (20.0%) permanently subleased
    LocationHennepin County, Minnesota; suburban site, not specified
    ProgramSBA 504; real estate in an Eligible Passive Company (EPC), physician group as Operating Company (OC) and co-borrower
    Total project cost$10,206,160 504 project ($567.01 per rsf); $10,476,160 all-in
    Loan structureBank first mortgage $5,103,080 (50%); 504 debenture $3,572,156 net, $3,671,000 gross (35%); borrower cash $1,530,924 (15%)
    Stabilized DSCR1.72x global in Year 3; 1.00x in Year 1; 1.44x historical
    IRRUnlevered 6.65%; levered 5.39%; equity multiple 1.85x (real estate at imputed market rent)
    DeterminationFinanceable as structured, with a funded Year 1 reserve, physician retention terms and a distribution covenant

    The credit question

    A lender here is not lending against a building. It is lending to a physician practice that wants to own one. Repayment comes from the group's cash flow after paying its physicians market compensation. The building is collateral, and its value is partly tied to the tenant whose failure would put it on the market.

    Three things must be true. The group's cash flow must cover the new combined debt service with a margin that survives realistic hits to physician income: reimbursement cuts, payer-mix drift and the loss of productive physicians. The transaction must meet SBA's rules for owner-occupied new construction, including the 60% occupancy and 20% leasing limits and the equity SBA requires for medical facilities. And if the group fails, another medical user must value the building enough to cover the first lien. This study finds the first two met with conditions, and the third met only for the first lien, which is the normal shape of a 504 medical office credit.

    There is a fourth, procedural question that shapes the structure. SBA lends only where credit is not available elsewhere, and the lender must state in its credit memorandum the identifiable weakness that keeps a conventional loan out [1]. Here the weakness is plain: a new medical building is worth less than it costs, so a conventional loan at 80% to 85% of cost would exceed prudent loan-to-value limits. The 504 second lien fills that gap, and the rest of this study asks whether the cash flow justifies it.

    Location and county economy

    Population and age structure

    Hennepin County had an estimated 1,284,784 residents in 2025, up only 3,218 (0.3%) since 2020 [2]. From April 2020 to July 2025 it recorded 22,515 more births than deaths and 35,776 net international arrivals, but lost 54,951 residents to domestic out-migration [2]. A practice here cannot rely on population growth. It can rely on aging.

    Age group, 2025ResidentsShare
    Under 15230,53017.9%
    15 to 34359,92228.0%
    35 to 54338,35126.3%
    55 to 64155,54512.1%
    65 to 74120,4059.4%
    75 to 8455,0704.3%
    85 and over24,9611.9%
    Total1,284,784100.0%

    Source: Minnesota DEED county profile, Census 2025 estimates [2]; ten-year bands combined; shares rounded.

    The median age is 37.6, younger than the state's 38.8 [2]. That supports a commercially insured payer base today. The State Demographic Center projection, published in the same profile, changes the picture over the loan term:

    Projection band20252035Change
    Under 651,055,4611,031,698-2.3%
    65 to 74124,294116,566-6.2%
    75 to 8466,69489,90834.8%
    85 and over25,18834,06935.3%
    Total1,271,6371,272,2410.0%

    Source: State Demographic Center projections in [2]; under-65 row by subtraction.

    Population is flat, but residents over 75 rise by 32,095, or 34.9% [2]. They see physicians more often and carry more chronic disease, which suits a multi-specialty group. They also move revenue toward Medicare, whose rates are set federally rather than negotiated. That trade-off drives the reimbursement analysis below.

    Income, employment and unemployment

    Median household income was $97,653 in the 2020 to 2024 American Community Survey, against $89,062 statewide, ninth of 87 counties [2]. Median family income was $134,878 and per capita income $59,401 [2]. Higher incomes go with employer coverage, the payer category with negotiable rates, but also with a wage base above the state average: DEED estimates a single adult needs $20.33 an hour to meet basic costs in Hennepin, against $18.45 statewide [2].

    Sector, Hennepin 2025JobsShareAverage wageChange 2024 to 2025
    Health care and social assistance166,53218.1%$71,240+5.5%
    Professional and technical services89,6659.8%$137,592-1.5%
    Manufacturing73,9858.1%$98,800-2.1%
    Finance and insurance68,3847.4%$167,492-1.6%
    All industries918,267100.0%$92,352+0.1%

    Source: DEED Quarterly Census of Employment and Wages in [2].

    Health care is the largest sector and added 5.5% in a year when county employment was flat [2]. DEED projects health care and social assistance in the Twin Cities region to grow 9.2% from 2022 to 2032, adding 25,326 jobs, the largest gain of any industry [2]. The group competes with the region's large health systems for staff.

    Unemployment averaged 3.6% in 2025, below the state's 3.9% [2]. A looser labour market would ease hiring of support staff but put some commercially insured patients at risk of losing coverage. Some 83.8% of employed residents work inside the county and the mean commute is 21.9 minutes [2], so patients choose clinics near home or work. Site visibility on an arterial road matters more than proximity to the core; a site study would add state traffic counts.

    Healthcare workforce

    MeasureValue
    Healthcare practitioner jobs, Region 11, 2025 (median wage)105,470 ($48.50/hr)
    Healthcare support jobs, Region 11, 2025 (median wage)110,250 ($18.64/hr)
    Twin Cities healthcare practitioner vacancies, 20247,696
    Twin Cities healthcare support vacancies, 20244,904
    Registered nurse, in-demand wage, 2025$103,822/yr
    Medical assistant, in-demand wage, 2025$51,095/yr

    Source: DEED wage, vacancy and occupations-in-demand data in [2].

    Support staff are about a quarter of the modelled group's revenue, and the region carries 12,600 open healthcare jobs [2]. Health care and social assistance accounted for about a quarter (26%) of all Twin Cities vacancies in 2024 [2]. A clinic that cannot staff its exam rooms cannot bill for them, so staffing is a revenue risk as well as a cost risk. That is why this study stress-tests an 8% wage step rather than assuming staff costs track inflation.

    Physician supply

    Hennepin is home to academic and system hospitals, so a new practice should not count on unmet demand; this model is built for an established group bringing its patient panel. A departing physician also has local options, which makes retention agreements a credit term, not an HR detail.

    Taken together, the county data support an owner-occupied clinic for an established group and argue against a speculative medical building. Demand growth comes from aging inside a flat population and the workforce is contested. The credit therefore rests on the group's existing revenue and its ability to keep its physicians, not on market growth.

    Market analysis

    Demand drivers

    Two sourced drivers support outpatient demand: growth of the 75-plus population [2] and health care job growth [2]. The counter-driver is Medicaid. Public Law 119-21, enacted July 4, 2025 [3], requires states, from the first quarter beginning after December 31, 2026 at the latest, to condition Medicaid for expansion adults on at least 80 hours a month of work or other community engagement, to redetermine their eligibility every six months, and to shorten retroactive coverage to one month for expansion adults and two months for others [3]. The county's 2025 financial report expects rising uncompensated care pressures from late 2026, and its safety-net medical center recorded a $38.1 million operating loss in 2025, excluding a pension adjustment, related to elevated uncompensated care [4]. A private group's exposure is smaller, but its Medical Assistance and MinnesotaCare patients will churn.

    Demand method: age-weighted visit demand

    The primary test is whether the group's existing panel fills 12 physicians and 6 advanced practice providers (APPs). The secondary test is whether county demand supports volume growth after stabilization. This study weights residents by age, with the weights as assumptions reflecting higher visit frequency in older groups.

    BandWeight (assumption)2025 demand units2035 demand unitsChange
    Under 651.01,055,4611,031,698-2.3%
    65 to 741.8223,729209,819-6.2%
    75 to 842.3153,396206,78834.8%
    85 and over2.665,48988,57935.3%
    Total (modelled)n/a1,498,0751,536,8852.6%

    Demand rises 2.6% over the decade, about 0.26% a year, with population flat. The pro forma holds per-provider volume growth after Year 3 to 0.25% a year, so the practice grows with its market, not faster.

    Existing supply, rents and construction cost

    No public source tracks medical office vacancy and rents for buildings of this size in the county, so the model's current rent, the sublease rent, the valuation rent and the re-leasing cases are assumptions, listed in the assumptions table. A survey of local medical office comparables, including smaller buildings, is a condition of the model's determination.

    The model's $205 per gross sq ft shell and $180 per rsf owner improvements are illustrative assumptions to be replaced with a contractor's guaranteed maximum price.

    Sublease absorption and forecast

    The 3,600 rsf sublease suite is small, so the risk is tenant quality and timing more than market depth. The best candidates are complementary users that send or receive referrals, such as physical therapy or a specialty practice the group does not offer, because their patients add traffic to the group's imaging. The model assumes a lease from opening and tests a scenario where the suite stays empty for three years. The forecast holds the group at 10.5 physician FTE in Year 1, 11.5 in Year 2 and 12.0 from Year 3, with APPs rising from 5.0 to 6.0. Productivity dips to 95% in Year 1 for the move and recovers to 100% by Year 3.

    Site and technical

    A 19,200 gross sq ft, two-storey clinic needs about 1.75 acres with roughly 90 parking stalls (5.0 per 1,000 rsf), arterial frontage, an elevator, service access for supplies and medical waste, and structural and shielding allowances for imaging. Zoning is a city matter: Minnesota law lets each municipality regulate the location, height, width and bulk of buildings and the uses of land [5]. Clinics are commonly permitted or conditional uses in office and commercial districts. Minnesota's 60-day rule treats a zoning request as approved if the agency fails to deny it within 60 days, and an extension may not exceed 60 days unless the applicant agrees [6], which bounds the entitlement period. The Department of Labor and Industry states that the 2020 Minnesota Building Code remains in effect and that the 2024 Minnesota Commercial Energy Code took effect January 5, 2024 [7]. Sewer and water connection charges are carried in the permits line.

    The group's space program drives the building size:

    SpaceRentable sq ft
    Exam, procedure and nurse stations for 12 physicians and 6 APPs9,000
    Imaging and laboratory1,800
    Reception and waiting1,400
    Administration, billing and staff areas1,500
    Allocated common area (corridors, lobby, restrooms)700
    Group total14,400
    Sublease suite3,600
    Rentable total18,000
    Stairs, elevator and mechanical (excluded from rentable)1,200
    Gross building area19,200

    At 800 rsf per provider the plan is efficient but not tight. SBA counts common areas toward rentable property and excludes stairways, elevators and mechanical space [1], so the group's 80% share is measured on 18,000 rsf, not 19,200.

    The model assumes a guaranteed maximum price contract, which most banks require before closing an interim loan. The sublease suite is delivered as a warm shell with a $75 per rsf allowance paid in sponsor cash, because the costs of interior finishing of space to be leased to another business are not eligible 504 project costs [8].

    PhaseMonthsMilestone
    Design, CDC and bank applications0 to 4Bank letter of intent, term sheet or commitment letter in the 504 application [1]
    Zoning approval; SBA authorization3 to 660-day decision window [6]
    Permits, guaranteed maximum price5 to 7Interim loan closes
    Construction7 to 1912-month build
    Occupancy, move, debenture sale19 to 21Year 1 of operations is 2028

    Development budget and sources and uses

    Development budget

    Line itemAmountPer rsf (18,000)Share of project
    Land, 1.75 acres (76,230 sf at $15.00/sf)$1,143,450$63.5211.2%
    Site work, parking (about 90 stalls), stormwater, landscaping$640,000$35.566.3%
    Building shell and core, 19,200 gsf at $205/gsf$3,936,000$218.6738.6%
    Medical tenant improvements, owner-occupied 14,400 rsf at $180/rsf$2,592,000$144.0025.4%
    Hard-cost contingency, 6.0% of hard costs$430,080$23.894.2%
    Architecture, engineering, medical planning, 6.5% of hard costs$465,920$25.884.6%
    Permits, plan review, sewer and water charges and municipal fees$210,000$11.672.1%
    Survey, geotechnical, Phase I ESA, special inspections$95,000$5.280.9%
    Legal, title, appraisal, interim lender costs$120,000$6.671.2%
    Builder's risk and construction-period property tax$60,000$3.330.6%
    Interim interest (7.25%, 12-month build plus 2 months to debenture sale)$419,303$23.294.1%
    Interim loan fee, bank fee and SBA third-party lender participation fee$94,407$5.240.9%
    Total eligible 504 project cost (modelled)$10,206,160$567.01100.0%
    Outside the project: leased-suite improvement allowance (3,600 rsf at $75), sponsor cash$270,000n/an/a
    All-in development cost$10,476,160$582.01n/a

    Contingency of 6.0% sits within the 10% of construction cost that 504 rules allow [8]. Interim interest is financed, so the model iterates it to a fixed point.

    Sources and uses

    Source (modelled)AmountShare of 504 projectLien / role
    Third-party lender first mortgage$5,103,08050.0%First lien on land and building
    SBA 504 debenture, net proceeds to project$3,572,15635.0%Second lien, 100% SBA-guaranteed debenture
    Borrower cash contribution$1,530,92415.0%Equity, first in
    Total sources for the 504 project$10,206,160100.0%n/a
    Sponsor cash outside the project (leased-suite allowance)$270,000n/aNot financeable with loan proceeds
    Total sponsor cash$1,800,924n/an/a
    Use (modelled)Amount
    Land and site$1,783,450
    Building shell, core and owner TI$6,528,000
    Contingency$430,080
    Soft costs$950,920
    Interim interest and financing fees$513,710
    Total uses (504 project)$10,206,160

    The 50/35/15 split is not the standard 504 split. SOP 50 10 8.1 lists "hospitals, surgery centers, urgent care centers, and other health or medical facilities" as examples of limited or special purpose property and requires the CDC to address the question in its credit memorandum and explain its conclusion [1]. Such projects need at least 15% borrower cash, a debenture of no more than 35% and a bank share of at least 50% [8], [1]. A medical building with a conventional shell could be argued general purpose, allowing 50/40/10:

    Structure (modelled)TPL504 gross debentureBorrower cashY1 DSCRY3 DSCR
    Base: limited or special purpose, 50/35/15$5,103,080$3,671,000$1,530,9241.00x1.72x
    Alternative if the CDC documents general-purpose: 50/40/10$5,117,450$4,206,000$1,023,4900.96x1.64x

    The lower-equity version saves about $507,000 of cash, adds about $46,000 of annual debt service and cuts Year 1 coverage to 0.96x. The 15% structure is the better credit either way.

    Revenue build and operating expenses

    Payer mix and reimbursement as operating-company risk

    PayerShare of net revenue (assumption)Annual rate change (assumption)Basis
    Medicare fee-for-service20%-1.68% in 2027, then +0.25%Assumption; check against the CY 2027 final rule
    Medicare Advantage15%Follows MedicareAssumption
    Commercial47%+3.0%Assumption
    Medical Assistance and MinnesotaCare14%0%Assumption
    Self-pay and other4%0%Assumption

    CMS published its CY 2027 physician fee schedule final rule on November 9, 2026, effective January 1, 2027 [9]. The model assumes Medicare rates fall 1.68% in 2027 and then rise 0.25% a year; a lender should re-run the model with the final rule's conversion factor. Minnesota adds a 1.8% MinnesotaCare provider tax on a health care provider's gross revenues [10]; payments for services under the Medicare program, including payments from Medicare Advantage organizations, are exempt, and payments for services not covered by Medicare are taxable [11]. The model taxes all non-Medicare revenue, $147,420 in the base year.

    The weighted rate index rises 0.82% in 2027 and 1.5% to 1.7% a year after, against cost inflation of 3.0% to 3.25%. Physician pay moves with collections; staff and overhead do not. The base case therefore squeezes EBITDAR from 10.8% of revenue in Year 3 to 7.2% in Year 10, about 0.5 points a year. That is what happens to a practice when reimbursement grows slower than wages, and it is why coverage must be tested annually.

    Revenue build, year by year

    YearCalendarPhysician FTEAPP FTEProductivityRate indexProfessional revenueAncillary revenueNet patient revenue
    Base (trailing)202610.05.0100.0%1.0000$10,500,000$2,100,000$12,600,000
    Year 1202810.55.595.0%1.0236$10,813,345$2,450,506$13,263,852
    Year 2202911.56.098.0%1.0394$12,396,800$2,811,435$15,208,235
    Year 3203012.06.0100.0%1.0557$13,301,776$3,040,406$16,342,182
    Year 4203112.06.0100.2%1.0724$13,546,437$3,096,328$16,642,765
    Year 5203212.06.0100.5%1.0896$13,798,290$3,153,895$16,952,185
    Year 6203312.06.0100.8%1.1074$14,057,582$3,213,162$17,270,743
    Year 7203412.06.0101.0%1.1256$14,324,535$3,274,179$17,598,714
    Year 8203512.06.0101.3%1.1443$14,599,396$3,337,005$17,936,401
    Year 9203612.06.0101.5%1.1636$14,882,419$3,401,696$18,284,115
    Year 10203712.06.0101.8%1.1834$15,173,881$3,468,316$18,642,196

    All figures are modelled.

    Operating expense structure

    Expense (modelled)Base year% of revenueYear 3 (stabilized)% of revenueBehaviour
    Physician compensation and benefits$5,365,00042.6%$6,872,58442.1%57.5% of physician professional revenue plus 20% of ancillary
    APP compensation and benefits$825,0006.5%$1,114,2546.8%$165,000 per FTE, +3.0%/yr
    Clinical and support staff$3,150,00025.0%$4,295,87926.3%$252,000 per provider unit, +3.25%/yr
    Medical supplies and drugs$630,0005.0%$817,1095.0%5.0% of revenue
    Administration, IT, billing, malpractice$1,102,0008.7%$1,283,5267.9%$850,000 fixed +3.0%/yr, plus 2.0% of revenue
    MinnesotaCare provider tax (1.8% of non-Medicare revenue)$147,4201.2%$197,5531.2%Statutory rate on taxable revenue
    Operating EBITDAR$1,380,58011.0%$1,761,27710.8%n/a
    Rent in leased space (11,000 sf at $31.53 FSG)$346,8302.8%n/an/aEliminated on move
    Building operating cost, 18,000 rsf incl. reservesn/an/a$271,1661.7%$14.20/rsf in Year 1, +3.0%/yr
    Sublease rent plus expense recovery, net of 5% vacancyn/an/a$162,0021.0%$31.00/rsf NNN, +2.5%/yr

    Physician compensation is 57.5% of physician professional collections plus 20% of ancillary income, about $536,500 per physician including benefits. That is the market-rate normalization a CDC applies when SBA directs it to make prudent adjustments to cash flow for items such as distributions and ownership compensation [1]. Anything physicians draw above that is a distribution, which a covenant can hold back.

    Assumptions

    AssumptionValueRationale
    Land$15.00/sf, 1.75 acresSuburban commercial pad; replace with an appraisal
    Shell; owner improvements$205/gsf; $180/rsfAssumptions; replace with a contractor's guaranteed maximum price
    Site work; contingency; design$640,000; 6.0%; 6.5%Guaranteed maximum price contract
    Interim loan7.25%Prime of 7.00% [12] plus 0.25 (assumption)
    Bank loan7.00% fixed 10 years, 25-year amortizationAssumption; about 2.1 points over the 10-year Treasury yield of 4.88% on November 9, 2026 [12]
    504 debenture6.95% effective, 25 yearsAssumption; about 2.1 points over the same yield [12]
    Equipment debtExisting $96,000/yr to Year 4; new $650,000 at 7.50%, 7 yearsImaging for the new building
    Providers, base year10.0 physician FTE, 5.0 APP FTEEstablished group
    Collections$860,000 per physician; $380,000 per APP; ancillary $210,000, then $240,000 per physicianIllustrative multi-specialty mix
    Physician pay57.5% of professional plus 20% of ancillaryMarket normalization
    APP pay; staff$165,000 per FTE (+3.0%); $252,000 per provider unit (+3.25%)Regional wage pressure [2]
    Supplies; administration5.0% of revenue; $850,000 plus 2.0% of revenueGroup practice norms
    Medicare rate change-1.68% in 2027, then +0.25% a yearAssumption; check against the final rule [9]
    Existing rent11,000 sf at $31.53 full serviceAssumption for the group's current lease
    Building operating cost$13.95/rsf plus $0.25 reserves (+3.0%)Assumption for a new building
    Sublease$31.00 triple net (+2.5%), 5% vacancyAssumption
    Relocation$150,000 in Year 1Move and overlap
    Productivity95%, 98%, 100%, then +0.25%/yrMatched to demand index
    Valuation$37.00 triple net (+2.75%); caps 6.75% in, 7.00% outAssumptions
    Re-leasingMedical $30.00, 90%, 7.50% cap; office $17.00, 75%, 9.00% capAssumptions; weak general office demand assumed

    Ramp to stabilization

    Year 1 carries the move, 95% productivity, a $150,000 relocation cost and a full year of new debt service: global cash flow of $961,967 against $958,395, a 1.00x DSCR. Added physicians and imaging lift coverage to 1.53x in Year 2 and 1.72x in Year 3.

    10-year pro forma

    ($000, modelled)BaseY1Y2Y3Y4Y5Y6Y7Y8Y9Y10
    Net patient revenue12,60013,26415,20816,34216,64316,95217,27117,59917,93618,28418,642
    Operating expenses before occupancy11,21912,05013,63514,58114,93515,30015,67616,06416,46416,87617,301
    Operating EBITDAR1,3811,2141,5731,7611,7081,6521,5941,5351,4721,4081,341
    Rent paid in existing leased space3470000000000
    Building operating cost and reserves0256263271279288296305314324334
    Sublease rent and recoveries0154158162166171175180185190195
    One-time relocation cost0150000000000
    Global cash flow available for debt service1,0349621,4681,6521,5951,5351,4731,4091,3431,2741,202
    Third-party lender debt service0433433433433433433433433433433
    504 debenture debt service0310310310310310310310310310310
    Other operating-company debt service96216216216216120120120000
    Total debt service96958958958958862862862743743743
    Cash flow after debt service9384510694636673611547600531459
    DSCR (global)n/a1.00x1.53x1.72x1.66x1.78x1.71x1.63x1.81x1.71x1.62x

    Global cash flow is the group's EBITDAR, less the whole building's operating cost, plus sublease rent and recoveries, less one-time costs. SBA caps the EPC's rent at the loan payment plus the EPC's direct costs of holding the property [8], so the consolidated view is the right one for coverage.

    Debt structure

    TrancheAmountRateAmortization / termAnnual debt service
    Third-party lender first mortgage$5,103,0807.00% fixed for 10 years (assumption)25-year amortization, 10-year term, balloon$432,810
    504 debenture (gross)$3,671,0006.95% effective, fees included (assumption)25-year, fully amortizing$309,947
    Existing operating-company equipment debtn/aas contractedretires after Year 4$96,000
    New imaging and clinical equipment loan, $650,000$650,0007.50% (assumption)7 years$119,639
    Combined debt service, Year 1 (modelled)n/an/an/a$958,395

    The 504 debenture

    Debenture build (SOP 50 10 8.1, Section C, Ch. 3 method; modelled)Amount
    Net debenture (35% of project)$3,572,156
    SBA guaranty fee, 0.50% of net$17,861
    Funding fee, 0.25% of net$8,930
    CDC processing fee, 1.50% of net$53,582
    CDC closing costs (assumption)$3,000
    Subtotal$3,655,530
    Divided by 0.996, rounded up to the next $1,000 = gross debenture$3,671,000
    Debenture sale fee, 0.40% of gross$14,684
    Rounding residual$786

    The debenture follows the SOP pricing method: net debenture plus the guaranty fee, funding fee, CDC processing fee and closing costs, divided by 0.996 to add the 0.4% fee charged when a 20- or 25-year debenture is sold, and rounded up to the next even thousand [1]; the fee rates match the regulation's 0.5% guaranty fee, funding fee of up to 0.25% and processing fee of up to 1.5% [8]. The 6.95% rate is an assumption: debentures are priced at sale against long-term government debt, usually the 10-year Treasury [1], which yielded 4.88% on November 9, 2026 [12].

    Bank loan, equity and guaranties

    The bank loan's 7.00% is an assumption, not a quote; prime was 7.00% in November 2026 [12]. The loan must run at least 10 years beside a 20- or 25-year debenture [1], with no early call and no open-ended advances [8]. Because project cost is at least $5,000,000, SBA requires the bank's credit memorandum or credit analysis with the CDC's submission [1]. The 15.0% borrower contribution is measured on project cost excluding administrative costs [8]; it may be borrowed only if subordinate to the third-party loan and the debenture and, without SBA's written approval, not repaid faster than the 504 loan [1]. Any individual owning 20% or more must give an unlimited full guaranty, and if no one owns 20%, at least one owner must give a full unconditional guaranty [1]. A ten-physician group with equal shares has no 20% owner, so a lender would ask for guaranties from several physicians on an $8.8 million debt package.

    The job test is easy to meet but must be documented. At one job opportunity per $95,000 guaranteed by SBA [1], the $3,671,000 gross debenture requires 39 jobs created or retained. An established group with 10 physicians, 5 APPs and the support staff its cost base implies retains well over that number, and the move adds two physicians, an APP and their staff.

    DSCR and break-even

    Historical test

    Historical test (base year, SOP 1.15x minimum; modelled)Amount
    Base-year EBITDA after rent$1,033,750
    Add back rent eliminated by the move$346,830
    Adjusted EBITDAR$1,380,580
    Less net building cost the group will carry (Year 1 opex less sublease income)$101,871
    Adjusted cash flow$1,278,709
    Post-transaction debt service (TPL, 504, existing and new equipment debt)$958,395
    DSC, rent add-back only1.44x
    DSC, rent add-back less net building cost1.33x

    SOP 50 10 8.1 requires historical debt service coverage of at least 1.15, measured as EBITDA over combined post-transaction debt service [1]. With eliminated rent added back, the base year covers 1.44x; after charging the net cost of the new building, 1.33x. The credit qualifies on history; the projections test the transition.

    Year 1 liquidity

    Year 1 is 1.00x. Where projections show repayment in Year 2 but not Year 1, the SOP requires sufficient liquidity to cover the Year 1 shortfall [1]. Lifting Year 1 to 1.15x takes $140,187. A reserve of six months of real estate debt service, $371,378, covers that more than twice and absorbs a delayed move.

    Break-even

    Break-even measure (modelled)Year 1Year 3 (stabilized)Year 7
    Revenue decline from base case that leaves DSCR at 1.00x0.1%8.5%6.3%
    Revenue decline from base case that leaves DSCR at 1.15xnone: needs 2.1% more revenue6.8%4.8%
    Break-even net patient revenue (DSCR 1.00x)$13,256,714$14,947,407$16,498,487
    Physician FTE that leaves DSCR at 1.00x (APPs held at 6.0)n/a8.6 of 12.0n/a
    Physician FTE that leaves DSCR at 1.15xn/a9.3 of 12.0n/a

    At stabilization the group can lose 8.5% of revenue before coverage hits 1.00x, or about 8.6 physician FTE out of 12 with APPs held constant. Losing three physicians without replacement consumes the margin. By Year 7 the cushion narrows to 6.3% as the base-case squeeze builds.

    Returns

    The EPC's rent is capped [8], so this study tests whether owning beats leasing by imputing an assumed market rent to the group's space: $37.00 triple net.

    Return measure (economic view: owner space imputed at market rent; modelled)Result
    All-in cost basis (504 project plus leased-suite allowance)$10,476,160
    Year 1 imputed NOI (14,400 rsf at $37.00 NNN, 3,600 rsf at $31.00 NNN, 5% vacancy, $0.85/rsf non-recoverable)$596,880
    Yield on cost, Year 15.70%
    As-complete value at a 6.75% cap rate$8,842,667
    Value as a share of all-in cost84.4%
    Exit value, end of Year 10 (Year 11 NOI $779,058 at 7.00%)$11,129,399
    Net sale proceeds after 2% costs$10,906,811
    Loan balances at Year 10 (TPL $4,012,725; 504 $2,882,575)$6,895,300
    Unlevered IRR, 10 years6.65%
    Levered IRR on sponsor cash of $1,800,9245.39%
    Equity multiple1.85x
    Payback year (cumulative levered cash flow turns positive)Year 10 (on sale)

    The building opens worth 84.4% of its all-in cost. Imputed income of $596,880 covers real estate debt service of $742,757 only 0.80x, so owning costs the physicians $145,877 more than leasing in Year 1, a gap that closes by Year 9. Debt at about 7% costs more than the 5.70% initial yield, so borrowing lowers the equity return (5.39%) below the unlevered return (6.65%); the 1.85x multiple arrives only on sale. For the physicians, ownership buys control and protection from rent resets, not early cash. For the lender, it confirms the building cannot be the repayment source.

    ($000, modelled)Y0Y1Y2Y3Y4Y5Y6Y7Y8Y9Y10
    Imputed NOI0597613630647664682700719739759
    Unlevered cash flow-10,47659761363064766468270071973911,665
    Real estate debt service0743743743743743743743743743743
    Levered cash flow-1,801-146-130-113-96-79-61-42-24-44,027

    The annual levered line shows what the physicians actually feel: a contribution of $145,877 in Year 1 above what market rent would cost, shrinking each year as rent grows against fixed debt service, and a single large inflow at sale. A practice that might sell the building or relocate within five years would do better leasing.

    Re-leasing value as collateral

    Collateral measure (modelled)AmountRatio
    As-complete value, income approach (Year 1 imputed NOI at 6.75%)$8,842,66786.6% of 504 project cost
    TPL first mortgage at closing$5,103,08057.7% LTV
    TPL plus gross 504 debenture at closing$8,774,08099.2% combined LTV
    TPL balance after 36 months$4,851,539n/a
    504 debenture balance after 36 months$3,488,749n/a
    Re-leasing case if the group fails in Year 3 (modelled)Re-let to medical usersFallback to general office
    Rent, NNN per rsf$30.00$17.00
    Stabilized occupancy90%75%
    Non-recoverable cost per rsf$1.50$2.50
    Cap rate7.50%9.00%
    Stabilized NOI$459,000$184,500
    Stabilized value$6,120,000$2,050,000
    Downtime carry, per rsf$9.00 (12 months)$13.50 (18 months)
    Re-tenanting improvements, per rsf$25.00$40.00
    Leasing commissions, per rsf$4.50$3.00
    Re-leasing costs$693,000$1,017,000
    Re-leasing value$5,427,000$1,033,000
    Less liquidation and holding costs, 8%$434,160$82,640
    Net recovery to lienholders$4,992,840$950,360
    Coverage of TPL balance ($4,851,539)1.03x0.20x
    Recovery left for the 504 debenture ($3,488,749)$141,301$0
    504 recovery rate4.1%0.0%

    The first mortgage starts at 57.7% of value, but combined debt is 99.2%. If the group fails in Year 3 and other medical users take the space at $30.00, recovery covers the bank loan 1.03x and leaves the debenture a 4.1% recovery. Marketed as general office at the model's assumed $17.00 rent and 75% occupancy, recovery covers 0.20x of the bank loan. Design that keeps the building medical-ready is therefore collateral protection: a divisible floor plate, plumbing and electrical capacity for three suites, and reusable imaging shielding.

    Sensitivity and stress tests

    Revenue vs base \ rate shift (both tranches)-100 bp-50 bp+0 bp+50 bp+100 bp+150 bp
    -10.0%0.94x0.91x0.88x0.85x0.82x0.79x
    -7.5%1.17x1.13x1.09x1.05x1.02x0.98x
    -5.0%1.40x1.35x1.30x1.26x1.21x1.17x
    -2.5%1.62x1.57x1.51x1.46x1.41x1.36x
    +0.0%1.85x1.79x1.72x1.66x1.61x1.56x
    +2.5%2.08x2.01x1.94x1.87x1.81x1.75x

    The grid shows modelled stabilized Year 3 coverage. A 150 basis point rise in both rates costs about 0.16x; a 5% revenue shortfall costs about 0.42x. Both loans are fixed, so rate risk ends at closing except for the bank reset in Year 10; revenue risk lasts the life of the loan.

    Scenario (modelled)Y1 DSCRY2 DSCRY3 DSCRY5 DSCRY10 DSCRMinimum, Y2 to Y10Year of minimum
    Base case1.00x1.53x1.72x1.78x1.62x1.53xY2
    S1 Reimbursement squeeze0.94x1.25x1.34x1.34x1.04x1.04xY10
    S2 Two physicians leave in Year 31.00x1.53x1.29x1.78x1.62x1.29xY3
    S3 Public-program revenue down 25%0.77x1.27x1.45x1.47x1.25x1.25xY10
    S4 Staff cost up 8% from Year 21.00x1.20x1.37x1.36x1.04x1.04xY10
    S5 Sublease suite empty Years 1 to 30.84x1.37x1.55x1.78x1.62x1.37xY2
    S6 Combined S1, S4 and S50.78x0.75x0.81x0.91x0.46x0.46xY10

    S1 cuts Medicare and Medicare Advantage rates a further 5% in 2029 and holds commercial increases to 1.0% for 2028 to 2030. S2 loses two physicians in Year 3 and replaces them over two years. S3 removes 25% of Medical Assistance and MinnesotaCare revenue from Year 1. S4 raises staff cost 8% from Year 2. S5 leaves the sublease suite empty for three years. None includes a management response.

    The single shocks are survivable. S1 and S4 hold at 1.15x or better from Year 2 through Year 9 before ending near 1.04x, because their damage compounds. S2 is the sharpest sudden hit, cutting Year 3 coverage from 1.72x to 1.29x before replacements ramp. S3 and S5 bite mainly in Year 1, which the reserve covers. The combined case S6 fails in every year. Restoring 1.15x in Year 3 would need $321,997, about $26,833 per physician or 4.9% of modelled physician pay. Physicians in a stressed practice routinely accept cuts of that size, which is why a distribution covenant is worth more to this credit than extra equity.

    Program compliance

    RequirementRuleModelled position
    SizeNAICS 621111 receipts up to $16.0 million [13], or tangible net worth up to $20 million and net income up to $6.5 million [14]$12.6 million base revenue: meets
    Occupancy, new constructionOccupy at least 60%; permanently lease up to 20%; temporarily lease a further 20%, using some within 3 years and all within 10 [8], [1]80% occupied, 20% subleased: meets
    Rentable propertyExcludes stairways, elevators and mechanical areas; includes common areas [1]18,000 of 19,200 sf: meets
    Occupancy at closingThe borrower must be occupying and operating in the required space after closing and funding, unless the loan processing center approves more time in advance; no business may have more than 1 year to meet occupancy [1]At completion: meets
    Subleased spaceInterior finishing of space leased to another business is not an eligible project cost [8]Sponsor-funded allowance: meets
    EPC/OCWritten lease subordinate to SBA's lien, term at least the loan term, rent capped at the loan payment plus holding costs, OC guarantor or co-borrower [8]Condition of closing
    ContributionAt least 15% for limited or special purpose property [8], [1]15.0%: meets
    Bank share and termsAt least 50%; at least 10 years beside a 20-year 504 loan; no early call [8]50%, 10 years: meets
    504 limit$5,000,000 outstanding per borrower and affiliates [8]$3,671,000: meets
    JobsOne per $95,000 guaranteed by SBA [1]39 needed: document retained staff
    Coverage1.15x historical; Year 1 shortfall covered by liquidity [1]1.44x; reserve: meets
    Contingency; feesUp to 10% of construction cost; fee caps [8]6.0%; modelled at caps
    Maturity10-, 20- and 25-year 504 terms [15]25 years
    AppraisalRequired above $500,000 of estimated project property value; USPAP; SBA as client or intended user [1]Condition
    GuarantiesEach 20% owner; at least one owner if none reaches 20% [1]Condition
    Credit elsewhereCredit memorandum states why conventional credit is unavailable [1]Value below cost: supportable
    Credit standardLoans "so sound as to reasonably assure repayment" [8]1.72x stabilized
    VersionSOP 50 10 8.1 for applications issued an SBA loan number from October 1, 2026 [16]Applies

    Risks and mitigants

    RiskEvidenceMitigant
    Physician departureModelled break-even at 8.6 FTEEmployment and buy-sell agreements; key-person insurance
    Reimbursement driftModel assumes a 1.68% Medicare cut in 2027; final rule published November 9, 2026 [9]1.25x annual covenant; distribution limit
    Public-program lossesMedicaid work requirements and six-month redeterminations from 2027 [3]Payer-mix reporting; reserve
    Provider tax1.8% of gross revenues, Medicare exempt [10], [11]Modelled explicitly
    Staff cost12,600 open regional healthcare jobs [2]Tested at +8%
    Cost overrunShell and improvement costs are assumptions until a guaranteed maximum price is signedGuaranteed price, bond, overrun guaranty
    Value below cost84.4% of all-in cost (modelled)15% equity; guaranties
    Medical-only collateralOffice case covers 0.20x of bank loan (modelled)Re-demisable design; dark-value appraisal
    Year 1 shortfall1.00x (modelled)Reserve of $371,378
    Sublease tenantEmpty suite: Year 1 at 0.84x (modelled)Lease or letter of intent before closing
    Bank reset, Year 10Balance $4,012,725 (modelled)Refinance tested at stressed rate

    Model determination

    The modelled project is financeable as structured under SBA 504, with conditions. Historical cash flow, with physicians paid at market and eliminated rent added back, covers post-transaction debt service at 1.44x, above the 1.15x floor. Stabilized coverage is 1.72x and stays above 1.6x through Year 10. The project meets the new-construction occupancy rule and uses the 15% contribution SBA requires for medical facilities treated as special purpose.

    The weaknesses are equally clear. Year 1 is 1.00x, so liquidity must be funded. The building opens below cost, leaving the debenture undersecured. And the margin of safety is counted in physicians.

    A lender reviewing a file like this would likely require:

    1. A reserve of $371,378, six months of real estate debt service, released after two years at or above 1.25x.
    2. An annual global DSCR covenant of 1.25x, with distributions limited when it fails.
    3. Physician employment agreements of at least five years and a funded buy-sell agreement.
    4. Key-person life and disability insurance assigned to the lenders.
    5. Personal guaranties from several physician owners, not only the minimum.
    6. A guaranteed maximum price contract, a payment and performance bond and an overrun guaranty.
    7. A signed sublease or letter of intent, with suite improvements funded outside loan proceeds.
    8. An appraisal with as-complete and dark values, a Phase I environmental assessment, and a survey of local medical office comparables.
    9. A design review confirming the floor plate can be divided into three medical suites.

    With those terms the credit rests where 504 intends: on a durable operating business, with the building as secondary support and the debenture absorbing the collateral gap that keeps conventional lenders out.

    Frequently Asked Questions

    Who repays the loans on an owner-occupied medical office financed with SBA 504?
    The physician group does. The building is usually owned by a related real estate entity that leases it to the practice, but SBA caps that rent at the loan payment plus the costs of holding the property, so the real estate entity has no independent income. Lenders therefore analyze the practice's cash flow after paying physicians market compensation, and treat the building as collateral rather than as the repayment source.
    How much of a new 504-financed building can the practice lease to other tenants?
    For new construction, the borrower may permanently lease up to 20% of rentable space if it occupies at least 60%. A further 20% may be leased temporarily, provided the borrower plans to occupy some of it within three years and all of it within ten. This model study uses an 80% occupied, 20% permanently subleased split, which satisfies the rule without any temporary space.
    Why does this model use 15% equity instead of the usual 10%?
    SBA's SOP 50 10 8.1 lists hospitals, surgery centers, urgent care centers and other health or medical facilities as examples of limited or special purpose property. Such projects require at least 15% borrower cash and cap the debenture at 35%. A CDC must address the question and explain its conclusion either way. The model also shows the 10% alternative, which saves cash but weakens Year 1 coverage.
    What debt service coverage does SBA require for a 504 loan?
    SOP 50 10 8.1 requires historical debt service coverage of at least 1.15, measured as EBITDA over combined post-transaction debt service. If history falls short, the CDC must analyze at least two years of projections. Where projections show repayment in Year 2 but not Year 1, sufficient liquidity must be shown to cover the Year 1 shortfall. Lenders often set a higher ongoing covenant.
    How do Medicare rate changes affect a physician group's ability to repay?
    Medicare sets its rates through the physician fee schedule, and CMS published the CY 2027 final rule on November 9, 2026. This model assumes a 1.68% cut in 2027 and small increases after, and because staff and administrative costs keep rising, slow rate growth squeezes margins every year. A further modelled 5% cut with weak commercial increases holds coverage at 1.15x or better from Year 2 to Year 9 but ends near 1.04x.
    Does Minnesota tax physician revenue?
    Yes. The MinnesotaCare provider tax is 1.8% of a health care provider's gross revenues under Minnesota Statutes section 295.52. Payments for services under the Medicare program, including payments from Medicare Advantage organizations, are exempt under section 295.53. For a group with 65% non-Medicare revenue, the tax costs about 1.2% of total revenue, a line many out-of-state pro formas omit.
    What is a new medical office building worth if the practice fails?
    Much depends on whether another medical user wants it. In this model, re-leasing to medical tenants at a discounted rent recovers enough to cover the first mortgage at about 1.03x but leaves little for the debenture. Re-leasing as general office, at the model's assumed office rent and occupancy, recovers only about a fifth of the first mortgage.
    Is buying or building a clinic cheaper than leasing for a physician group?
    Not at first, under the model's costs and rates. The building's market-rent income covers only about 80% of its real estate debt service in Year 1, so owning costs the physicians more than renting equivalent new space. The gap narrows as rents rise against fixed payments, and the owners build equity through amortization and any appreciation. The case for owning is control and stability.

    Sources

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    2. 2.Minnesota Department of Employment and Economic Development. "County Profile: Hennepin Co." (data updated May 15, 2026). https://mn.gov/deed/assets/hennepin_tcm1045-407441.pdf (accessed 2026-11-11)
    3. 3.U.S. Government Publishing Office, GovInfo. Public Law 119-21 (enacted July 4, 2025), sections 71107, 71112 and 71119. https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm (accessed 2026-11-11)
    4. 4.Hennepin County, Minnesota. Annual Comprehensive Financial Report for the Year Ended December 31, 2025. https://www.hennepincounty.gov/government/about/budget-financial-management/reporting-accountability (accessed 2026-11-11)
    5. 5.Minnesota Office of the Revisor of Statutes. Minnesota Statutes, section 462.357. https://www.revisor.mn.gov/statutes/cite/462.357 (accessed 2026-11-11)
    6. 6.Minnesota Office of the Revisor of Statutes. Minnesota Statutes, section 15.99. https://www.revisor.mn.gov/statutes/cite/15.99 (accessed 2026-11-11)
    7. 7.Minnesota Department of Labor and Industry. "2020 Minnesota State Building Codes." https://www.dli.mn.gov/business/codes-and-laws/2020-minnesota-state-building-codes (accessed 2026-11-11)
    8. 8.U.S. Government Publishing Office, GovInfo. Code of Federal Regulations, Title 13, Part 120, Business Loans (revised as of January 1, 2026). https://www.govinfo.gov/content/pkg/CFR-2026-title13-vol1/xml/CFR-2026-title13-vol1-part120.xml (accessed 2026-11-11)
    9. 9.Centers for Medicare & Medicaid Services. "Medicare and Medicaid Programs; CY 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies," final rule, 91 FR 70992 (November 9, 2026; effective January 1, 2027). https://www.federalregister.gov/documents/2026/11/09/2026-22743/medicare-and-medicaid-programs-cy-2027-payment-policies-under-the-physician-fee-schedule-and-other (accessed 2026-11-11)
    10. 10.Minnesota Office of the Revisor of Statutes. Minnesota Statutes, section 295.52. https://www.revisor.mn.gov/statutes/cite/295.52 (accessed 2026-11-11)
    11. 11.Minnesota Office of the Revisor of Statutes. Minnesota Statutes, section 295.53. https://www.revisor.mn.gov/statutes/cite/295.53 (accessed 2026-11-11)
    12. 12.Board of Governors of the Federal Reserve System. "H.15 Selected Interest Rates (Daily)," release of November 10, 2026. https://www.federalreserve.gov/releases/h15/ (accessed 2026-11-11)
    13. 13.U.S. Government Publishing Office, GovInfo. 13 CFR 121.201, size standards by NAICS industry (revised as of January 1, 2026). https://www.govinfo.gov/content/pkg/CFR-2026-title13-vol1/xml/CFR-2026-title13-vol1-sec121-201.xml (accessed 2026-11-11)
    14. 14.U.S. Government Publishing Office, GovInfo. 13 CFR 121.301, size standards for financial assistance programs (revised as of January 1, 2026). https://www.govinfo.gov/content/pkg/CFR-2026-title13-vol1/xml/CFR-2026-title13-vol1-sec121-301.xml (accessed 2026-11-11)
    15. 15.U.S. Small Business Administration. "504 loans." https://www.sba.gov/loans/504-loans/ (accessed 2026-11-11)
    16. 16.U.S. Small Business Administration. Information Notice 5000-880695, "Issuance of SOP 50 10 8.1" (published August 14, 2026; effective October 1, 2026). https://www.sba.gov/document/sop-50-10-lender-development-company-loan-programs (accessed 2026-11-11)