Medical office buildings

    Medical Office Building Feasibility Study: Demand, Tenants and Financing

    By Sarrah Allen, MAI, Principal · Updated

    A medical office building feasibility study tells a lender whether one specific building, with one specific set of physician owners and tenants, can pay its debt at the coverage the capital source requires, meet the program's occupancy and health care lease rules, and keep its value if the main practice leaves. The rent comes from medical practices, so the study tests the practices as closely as it tests the property.

    Three facts shape almost every medical office loan file:

    • Patients are getting older. The U.S. population age 65 and older grew 16.2% from April 2020 to July 2025, to 64,617,088, while the population under 65 grew 0.5% [1].
    • Payer risk sits with the tenant. Medicare fee for service paid 20.4% of the receipts of physician offices in 2022 [2], and 50.9% of Medicare beneficiaries were in Medicare Advantage and other health plans in 2025 [3].
    • Occupancy decides SBA eligibility. An owner-occupant financed with SBA 7(a) or 504 must use at least 51% of an existing building or 60% of a new one [4][5].

    This page sets out what the study must prove and how each financing program reads the file. Three model studies, illustrative analyses built on public data, apply the method: an owner-occupied medical office building under SBA 504, a dental practice acquisition under SBA 7(a) and a rural health clinic under a USDA Community Facilities loan. For questions about the practice itself rather than the building, see medical and dental practice feasibility studies.

    Every study ends in one of three conclusions: feasible as proposed; feasible with stated conditions, such as a smaller building, a signed lease for the third-party space or a larger equity contribution; or not feasible as proposed, with the changes that would make it work.

    What is a medical office building feasibility study?

    It is an independent analysis, written for the lender's file, of whether a proposed or existing medical office building can support its financing. It covers the market for the practices' services, the tenants and their leases, the building and its cost, the financing structure, and the cash flow that pays the debt.

    The tenants show up in federal statistics under several codes: offices of physicians (NAICS 621111), offices of dentists (621210), freestanding ambulatory surgical and emergency centers (621493) and other outpatient care centers (621498) [6]. The building owner, when it is not the practice, is a lessor of nonresidential buildings (531120) [6]. Three building types cover most loan requests:

    1. Owner-occupied practice building. A physician or dental group buys or builds its own space, often leasing the rest to other practices.
    2. Multi-tenant medical office building. An investor or developer leases suites to physician groups, health systems and outpatient operators.
    3. Specialty facility. A surgery center, imaging center or clinic whose design follows a regulated use.

    A hospital itself needs a different study; this page covers buildings leased to practices and outpatient operators. A feasibility study is not an appraisal: an appraisal estimates value at a date, while a study tests whether the project works and what would have to change. SBA may require a feasibility study on any business loan [4], and its procedures name the triggers: market saturation by industry type and location, a highly specialized project property, and a project size disproportionate to the community it will serve [5]. Its 504 procedures also say independent reports, feasibility studies among them, "may be beneficial in mitigating any weaknesses identified in the credit analysis" [5]. USDA requires one, prepared by an independent qualified consultant, for guaranteed loans above $1,000,000 to a new entity or new activity [7]. For what separates a study a lender can rely on from one it cannot, see what makes a feasibility study bankable.

    What does a lender need the study to prove?

    A lender needs proof that the occupant's cash flow repays the loan under the program's rules, and that the leases, the occupancy and the building do not break those rules. SBA's regulation states the standard: "Loans must be so sound as to reasonably assure repayment" [4].

    Exhibit 1. What the lender asks and what the study shows

    Lender questionWhat the study showsRule or test
    Is the occupant eligible and small?Practice type, receipts and affiliatesSize standard of $16.0 million in receipts for offices of physicians [6]
    Does the owner use enough of the building?Rentable square feet by user51% of an existing building; 60% of new construction [4]
    Can cash flow carry the debt?Practice EBITDA, building costs and debt service, with and without tenant rent1.15 in 7(a) and 504; tenant rent counts only in the global analysis [5]
    Is the rent lawful?Each lease tested against fair market valueStark office space exception; anti-kickback space rental safe harbor [8][9]
    Is the equity enough?Sources and uses504: 10%, 15% or 20% [4]; health facilities on SBA's special purpose list [5]
    What if the main practice leaves?Re-leasing case and alternative useLimited or special purpose property review [5]

    Source: 13 CFR Parts 120 and 121; SBA SOP 50 10 8.1; 42 CFR 411.357 and 1001.952, as cited in each row.

    How large is the outpatient and physician office sector?

    It is large and fragmented. County Business Patterns counted 701,862 employer establishments in ambulatory health care services in 2023, and offices of physicians were the largest group [10].

    Exhibit 2. Ambulatory health care establishments, 2023

    Industry (NAICS)EstablishmentsMid-March employeesAnnual payroll ($ thousands)
    Offices of physicians (6211)218,0662,771,935290,855,928
    Offices of physicians, except mental health specialists (621111)204,6172,706,297285,925,593
    Offices of dentists (6212)135,6651,028,88962,471,602
    Offices of other health practitioners (6213)204,6151,212,86158,497,123
    Outpatient care centers (6214)61,9581,345,946100,178,529
    Freestanding ambulatory surgical and emergency centers (621493)10,042196,17812,495,695
    All other outpatient care centers (621498)21,074492,05138,028,223
    Medical and diagnostic laboratories (6215)23,603332,06024,701,770

    Source: U.S. Census Bureau, County Business Patterns 2023, U.S. file (cbp23us), all legal forms [10].

    The 2022 Economic Census adds revenue. Offices of physicians reported receipts of $640.4 billion from 213,772 establishments run by 149,963 firms, about 1.43 establishments per firm [11]. Freestanding ambulatory surgical and emergency centers reported $44.1 billion from 10,119 establishments, about $4.4 million each, against about $3.0 million per physician office (calculated from [11]). Outpatient care centers reported $222.5 billion from 57,177 establishments [11].

    Census counts establishments, not square feet. No federal series publishes medical office inventory, vacancy or rent, so the study surveys the local buildings itself: rentable area, tenants, asking and achieved rents, lease terms and space under construction.

    Where does demand for medical office space come from?

    Demand comes from patients, and the patient base is aging faster than it is growing. From April 2020 to July 2025 the U.S. added 10,268,744 residents, and 8,988,997 of them, 87.5%, were age 65 or older [1].

    Exhibit 3. U.S. resident population by age, 2020 and 2025

    Age groupApril 1, 2020 baseJuly 1, 2025ChangePercent change
    All ages331,516,113341,784,85710,268,7443.1%
    Under 65275,888,022277,167,7691,279,7470.5%
    65 and older55,628,09164,617,0888,988,99716.2%
    75 and older22,626,64927,928,9375,302,28823.4%
    85 and older6,325,4547,041,036715,58211.3%

    Source: U.S. Census Bureau, Vintage 2025 Population Estimates, NC-EST2025-AGESEX-RES [1]. Age groups summed, changes calculated by FSC.

    The share of residents age 65 and older rose from 16.8% to 18.9% [1]. Census projections carry the trend forward, with the fastest growth in the oldest groups. The study turns those counts into demand with visit rates by age taken from the practices' own patient records.

    Exhibit 4. Projected U.S. population age 65 and older, 2025 to 2050

    Year65 and older75 and older85 and older65 and older, share of residents
    202563,326,60327,384,7667,047,04318.7%
    203071,183,49833,194,7088,559,63920.6%
    203575,828,41138,919,79111,178,88721.6%
    204078,293,90043,152,84913,675,78222.0%
    205082,130,28245,131,95317,374,95722.8%

    Source: U.S. Census Bureau, 2023 National Population Projections, middle series, np2023_d1_mid [12]. Age groups summed and shares calculated by FSC. The projections were released in 2023, so their 2025 values differ from the Vintage 2025 estimates in Exhibit 3.

    From 2025 to 2035 the projections add 19.7% to the population age 65 and older, 42.1% to the population 75 and older and 58.6% to the population 85 and older [12]. A building financed on a 25-year term will spend most of its loan life in that market.

    Demand is local, and establishment counts are not capacity

    National growth does not fill a particular building. The study measures the service area: residents by age, the practices and outpatient centers already there, the hospitals that anchor referrals, and the drive time patients accept for each specialty.

    Exhibit 5. Ten states with the most residents age 65 and older

    StateResidents 65 and older, 2025Share of residentsResidents 75 and older, 2025Offices of physicians, 2023Residents 65 and older per office
    California6,901,16817.5%3,031,38529,615233
    Florida5,346,78822.8%2,484,67519,994267
    Texas4,711,38114.9%1,938,61521,500219
    New York3,860,55119.3%1,707,42912,412311
    Pennsylvania2,799,79021.4%1,220,8387,854356
    Ohio2,398,12920.2%1,019,6135,551432
    Illinois2,379,14518.7%1,023,8336,775351
    North Carolina2,119,43818.9%910,7535,102415
    Michigan2,076,46720.5%870,5816,412324
    Georgia1,884,14016.7%789,4647,199262

    Source: U.S. Census Bureau, Vintage 2025 Population Estimates, SC-EST2025-ALLDATA6 [13], and County Business Patterns 2023, state file, NAICS 621111 [14]. Residents per office calculated by FSC; the two counts are from different years.

    The last column is a screen, not a measure of shortage. Minnesota had 745 residents age 65 and older per office of physicians and North Dakota 862, against 219 in Texas [13][14]. A state where care runs through large clinic systems can show fewer, larger establishments. The study therefore counts providers and square feet in the service area rather than relying on establishment ratios.

    How much new medical office space is being built?

    Less than in 2023. Private spending on medical buildings, the Census category that covers clinics, medical offices, medical labs and doctor and dentist offices [46], was $23.2 billion in 2025, 8.0% below the $25.2 billion of 2023 [44].

    Exhibit 6. Value of private construction put in place ($ millions)

    Type of construction2022202320242025
    Health care46,32853,43055,51459,334
    Hospital22,13324,34027,12730,373
    Medical building19,79725,19023,83323,185
    Special care4,3973,9014,5545,775
    Office82,37287,82391,658104,270

    Source: U.S. Census Bureau, Value of Construction Put in Place, annual private construction 2022 to 2025 [44]; category definitions [46].

    The monthly series shows the slowdown continuing. At a seasonally adjusted annual rate, medical building spending was $21.6 billion in September 2026 (preliminary), against $22.9 billion in September 2025 and $22.8 billion in September 2024 [45]. Hospital spending rose from $27.3 billion to $31.2 billion over the same two years [45], so more of the health care construction dollar is going to hospitals.

    National spending is context only. The supply survey counts local medical buildings, space under construction, permits and site plan approvals, health system capital plans and certificate-of-need filings.

    Why is payer mix an operating-company risk?

    Because the practices pay the rent from patient revenue, and insurers and government programs paid 71.2% of physician office receipts in 2022 [2]. The building's debt service is fixed; the practice's revenue moves with payment rules, payer contracts and patient volume. The Economic Census shows how different tenant types are paid.

    Exhibit 7. Where outpatient revenue came from, 2022 (share of receipts)

    Source of revenueOffices of physiciansOffices of dentistsOutpatient care centers
    Medicare fee for service (Parts A, B and D, excluding Part C)20.4%1.5%11.2%
    Medicaid fee for service5.8%4.8%12.6%
    Other federal, state or local government programs2.6%1.3%5.6%
    Private health insurance42.3%44.0%27.1%
    Patient out of pocket8.7%39.6%5.5%
    Other health care providers (patient and non-patient care)9.4%4.5%7.6%
    All other sources10.8%4.3%25.4%

    Source: U.S. Census Bureau, 2022 Economic Census, EC2262TYPEPAYER [2]. Shares of total receipts calculated by FSC; "all other" combines workers' compensation, property and casualty insurance and other patient and non-patient revenue. Reported lines cover 94.9% of outpatient care center receipts.

    Two points follow. First, government programs paid 28.9% of physician office receipts through fee-for-service lines alone [2], and the Census Medicare line excludes Part C, so Medicare Advantage revenue sits in other lines. Second, dental tenants carry a different risk: 39.6% of their receipts came from patients' own pockets and 1.5% from Medicare fee for service [2]. A building leased to both needs a credit view of each.

    Exhibit 8. Medicare beneficiaries by type of coverage

    PeriodTotal beneficiariesOriginal MedicareMedicare Advantage and other health plansAdvantage and other share
    201555,495,61838,024,67117,470,94831.5%
    201961,513,83638,576,33922,937,49837.3%
    202265,100,54635,270,91429,829,63245.8%
    202467,995,11633,913,84734,081,26950.1%
    202569,476,45634,133,86835,342,58850.9%
    July 202670,736,62434,558,87436,177,75051.1%

    Source: Centers for Medicare & Medicaid Services, Medicare Monthly Enrollment, national rows (annual rows for 2015 to 2025; July 2026 monthly row) [3]. Shares calculated by FSC.

    Medicare enrollment grew 25.2% from 2015 to 2025, and the Advantage and other plan share passed half in 2024 [3]. More of a practice's older patients are now paid under plan contracts it negotiates, and fewer under the federal fee schedule. The study reads the practice's payer contracts, not only its payer percentages.

    Where the federal fee schedule applies, its updates have been small. The statute sets the annual update to the conversion factor, and Congress has added temporary increases in some years.

    Exhibit 9. Medicare physician fee schedule: statutory updates, 2016 to 2027

    YearConversion factor update in statuteTemporary payment increase
    2016 to 20180.5% a yearNone
    20190.25%None
    2020 to 20250.0%3.75% (2021), 3.0% (2022), 2.5% (2023), 1.25% then 2.93% (2024)
    20260.75% for qualifying APM participants; 0.25% for others2.5% for 2026 only
    20270.75% for qualifying APM participants; 0.25% for othersNone; the 2026 increase ends before January 1, 2027

    Source: 42 U.S.C. 1395w-4(d) and (t), United States Code 2024 edition [15]; Public Law 119-21, section 71202, approved July 4, 2025 [16].

    The study takes the payment rates from the CY 2027 final rule, published on November 9, 2026 and effective January 1, 2027 [17], prices the practice's own procedure mix under it, and runs a downside case with lower fee schedule revenue. Rural health clinics are paid differently: an all-inclusive rate per visit, subject to a limit of $165 in 2026, $178 in 2027 and $190 in 2028 for clinics under the general limit [18].

    How do physician groups and health systems differ as tenants?

    A physician group's credit is the practice's cash flow and the physicians who produce it; a health system's credit is a much larger balance sheet. Most physician tenants are small businesses. In 2023, 52.7% of physician offices had fewer than five employees and 86.1% had fewer than 20 [10].

    Exhibit 10. Offices of physicians by number of employees, 2023

    Employees per establishmentEstablishmentsShare of 204,617
    Fewer than 5107,85852.7%
    5 to 938,18718.7%
    10 to 1930,03014.7%
    20 to 4920,0429.8%
    50 to 995,1672.5%
    100 to 2492,3861.2%
    250 or more9470.5%

    Source: U.S. Census Bureau, County Business Patterns 2023, cbp23us, NAICS 621111 [10]. Shares calculated by FSC; the 250 or more class combines three published classes (606, 212 and 129).

    The average office had 13.2 employees [10]. A small practice can be a strong tenant, but its credit rests on a few physicians, so the study reviews each tenant the same way:

    1. The entity and its owners. Who signs the lease, who guarantees it, and whether the physicians are owners or employees.
    2. Production and payers. Revenue by physician and by payer for three years, and contracts up for renewal.
    3. Succession. The ages of the physicians who produce most of the revenue, and any recruitment plan.
    4. The lease. Term, renewal options, termination and relocation rights, assignment, expense recoveries and the rent schedule.
    5. Affiliation. Whether a health system employs or contracts with the group, which can strengthen credit and also raise the fair market value questions below.

    A health system or a large outpatient operator can carry a long lease on its own balance sheet. Under SBA, though, it cannot be the occupying borrower unless it is a small business: the size standard is $16.0 million for physician offices, $19.0 million for freestanding surgical and emergency centers and $47.0 million for general hospitals [6]. In an SBA-financed building a large tenant fits inside the share the borrower may lease to third parties.

    What changes when a hospital department is the tenant?

    The credit behind the lease improves, but the tenant's revenue at the site depends on Medicare's provider-based and site-neutral rules [36][37].

    The campus is the area next to the main buildings plus areas within 250 yards of them [36]. An off-campus department must be 100 percent owned by the main provider, share its governing body and, with narrow exceptions, sit within a 35-mile radius of the campus [36]. It must be held out to the public as part of the hospital [36].

    Since January 1, 2017, departments on the campus and off-campus departments that billed under the hospital outpatient system before November 2, 2015 are excepted; other off-campus services are generally paid under the physician fee schedule [37]. A department keeps excepted status only if it has not impermissibly relocated or changed ownership [37]. So an excepted department has a reason to stay, and a landlord who asks it to move may be asking it to give up revenue.

    Exhibit 11. Hospital-affiliated and independent medical tenants compared

    QuestionHospital department or health system tenantIndependent physician or dental practice
    Who stands behind the rent?The system's balance sheet, if it signsThe practice and its owners' guarantees
    How does Medicare pay for services at the site?Excepted departments under the hospital outpatient system; other off-campus departments generally under the physician fee schedule [37]Physician fee schedule, with the updates in Exhibit 9 [15]
    Location rulesOn campus, or off campus generally within 35 miles [36]None from Medicare
    Ownership and controlOff-campus department 100 percent owned by the main provider, same governing body [36]The owners' choice
    Can it relocate?A move can cost an excepted department its status [37]Yes, subject to the lease
    SBA occupancyThird-party tenant inside the 49% or 20% limit; general hospital size standard of $47.0 million [4][6]Can be the occupying borrower if small [4][6]
    Lease rulesStark and anti-kickback tests when the parties can refer to each other [8][9]The same, when landlord or co-tenants can refer [8][9]

    Source: 42 CFR 413.65 and 419.48 [36][37]; 13 CFR 120 and 121.201 [4][6]; 42 CFR 411.357 and 1001.952 [8][9]; 42 U.S.C. 1395w-4 [15].

    For any hospital tenant the study asks for written confirmation of whether its department is excepted, when it began billing, and whether a relocation or change of ownership would change that.

    What do Stark and the anti-kickback statute require of a medical office lease?

    They require rent set in advance at fair market value, for a term of at least one year, not tied to referrals. The physician self-referral law (Stark) has an exception for office space rentals [19][8], and the anti-kickback statute has a matching safe harbor for space rental [9]. Any lease between parties in a position to refer patients to each other should meet both.

    Exhibit 12. Lease tests under Stark and the anti-kickback safe harbor

    RequirementStark office space exceptionAnti-kickback space rental safe harbor
    Written leaseIn writing, signed, premises specifiedIn writing, signed, covers all premises leased between the parties
    TermAt least 1 yearNot less than one year
    RentSet in advance and consistent with fair market valueAggregate rent set in advance and consistent with fair market value
    ReferralsNot determined by the volume or value of referrals or other businessNot determined by the volume or value of referrals or business generated
    FormulasNo percentage of revenue; no per-unit charges for patients referred by the lessorPart-time leases must state the exact schedule, length and rent
    SpaceReasonable and necessary; used exclusively by the lessee; common areas pro rataNot more than reasonably necessary for a commercially reasonable purpose
    Business purposeCommercially reasonable even if no referrals were madeCommercially reasonable business purpose
    Fair market valueGeneral commercial rent, without the value of proximity to a referral sourceGeneral commercial value, not adjusted for proximity to referral sources
    After expiryHoldover allowed on the same terms if the expired lease qualifiedParagraph (b) has no holdover provision

    Source: 42 CFR 411.357(a) and 411.351 [8][20]; 42 CFR 1001.952(b) [9]; 42 U.S.C. 1395nn(e)(1)(A) [19].

    The stakes are high for both parties. The statute makes a knowing kickback a felony with fines of up to $100,000 and prison of up to 10 years [21]. The Stark statute sets civil money penalties of up to $15,000 for each service billed in violation and up to $100,000 for each circumvention scheme [19].

    For the lender, the rules matter in three ways.

    1. Rent above fair market value overstates the building. If a hospital pays physician landlords more than general commercial rent, the excess is not durable income, and it can disappear when the lease is reviewed. The study's rent conclusion follows the regulatory definition: value "for general commercial purposes," without adjustment for proximity to a referral source [20].
    2. Percentage and per-click rent is not allowed. A rent tied to the tenant's revenue or to services for patients the landlord refers fails the Stark exception [8], so the study models fixed rent only.
    3. Short or informal leases are a credit problem. A tenant on a handshake or a month-to-month arrangement fails the one-year test in both rules [8][9], and the study treats that space as vacant until a written lease is signed.

    The study is not a legal opinion. It flags every lease where landlord and tenant can refer to each other and tells the lender which ones need health care counsel's sign-off.

    Worked examples: how the rent rules change the numbers

    Each row uses illustrative facts, not market rents, to show what the study counts as durable rent.

    Exhibit 13. Rent rule examples (illustrative model)

    ArrangementIllustrative factsRuleWhat the study counts
    Hospital leases from a physician-owned building above market4,000 sq ft at $34 a sq ft a year; survey range for general commercial use $26 to $29Fair market value is value for general commercial purposes, not adjusted for proximity to referral sources [20][9]$29 at most; the $5 excess, $20,000 a year, is treated as at risk
    Imaging tenant offers percentage rent8% of collections from services in the suiteNo rent formula based on a percentage of revenue from services performed in the space [8]Fixed rent at fair market value only
    Scanner leased per use$150 a scan for patients the lessor refersNo per-unit charges that reflect services to patients the lessor refers [8]Fixed rent set in advance
    Visiting specialist leases a suite part-timeTwo days a weekThe lease must state exactly the schedule of intervals, their precise length and the exact rent [9]Rent counted only under that written schedule, as short-term income
    Hospital tenant lets visiting physicians use its suite by the half dayRooms and staff for evaluation and management visitsTimeshare exception: hospital or physician organization only, predominantly evaluation and management, no advanced imaging, no possessory leasehold [8]The hospital's own lease counts; the timeshare does not
    Lease expires and the tenant staysSame terms, month to monthStark allows a holdover on the same terms if the expired lease qualified; the space rental safe harbor has no holdover provision [8][9]Vacant after expiry until renewed in writing

    Source: 42 CFR 411.351 and 411.357 [20][8]; 42 CFR 1001.952 [9]. Facts and dollar amounts are FSC assumptions.

    Above-range hospital rent lowers confidence in the lease rather than raising the building's value. The Stark fair market value exception also covers office space leases [8], with the same fixed-rent tests.

    How does SBA count owner occupancy in a medical office building?

    By rentable square feet, under the same test in 7(a) and 504. In an existing building the borrower must occupy at least 51% and may lease up to 49%. In new construction it must occupy at least 60%, may permanently lease up to 20%, and may temporarily lease another 20%, using some of it within 3 years and all of it within 10 [4][5].

    Exhibit 14. SBA occupancy rules for 7(a) and 504

    RuleExisting buildingNew construction
    Minimum occupied by the borrower or Operating Companies51%60%
    Permanent leases to third partiesUp to 49%Up to 20%
    Temporary leasesNot applicableAn additional 20%, with some reoccupied within 3 years and all within 10
    Rentable PropertyExcludes stairways, elevators and mechanical areas; includes common areasSame
    Common areasThe lender may count them toward the occupant's shareSame
    Time to meet occupancyNo more than 1 year after closingSame
    Improving tenant spaceNot with loan proceeds; 504 interior finishing of leased space is ineligibleSame
    Tenant rent from the project propertyGlobal cash flow analysis only; excluded from the repayment testSame

    Source: 13 CFR 120.131 and 120.871 [4]; SBA SOP 50 10 8.1, occupancy and leasing requirements and the 7(a) and 504 repayment analysis [5].

    How medical tenants count

    The occupancy test counts only the borrower, or the Operating Companies in a passive company structure. Every other practice is a third-party tenant inside the 49% or 20%, however closely it works with the owners. That decides how a multi-practice building is structured:

    • Several practices can count together. SBA permits multiple separately owned Operating Companies in one structure, with only one Eligible Passive Company [5], and the regulation applies the occupancy rule to "the Operating Company, or Operating Companies together" [4].
    • Counting has a price. Each Operating Company must be a guarantor or co-borrower, and each owner of 20% or more of the passive company or any Operating Company must guarantee the loan [4].
    • Each must be small. The passive company and each Operating Company must meet a size standard; affiliated companies are combined [4][5]. The standards are $16.0 million for physician offices, $9.0 million for dentists and $25.5 million for other outpatient care centers [6].

    The eligible passive company structure

    Most physician-owned buildings are held by a real estate company owned by the physicians and leased to their practice. SBA allows this Eligible Passive Company structure as an exception to its bar on financing passive investments, and "each condition is interpreted strictly" [5]:

    1. The passive company leases 100% of the building to the Operating Companies, which must occupy 51% of an existing building or 60% of new construction and may sublease the rest within the same limits [4][5].
    2. The lease is written, subordinate to the lender's lien, and runs, with renewal options only the Operating Company can exercise, at least as long as the loan [4][5].
    3. The passive company assigns the rents to the lender [4][5].
    4. The rent "cannot exceed the amount necessary to make the loan payment to the lender," plus the passive company's direct holding costs such as maintenance, insurance and property taxes [4][5].
    5. The lender must find that the Operating Company's cash flow covers the loan payment and the holding costs [5].

    The rent cap and the fair market value rules can pull in different directions. When the passive company's owners and a tenant can refer patients to each other, the lease has to satisfy both, so the study shows the SBA cap and the fair market value range side by side.

    The calculator below runs these tests. One rule surprises many owners. In 504, rent from tenants in the project property "may be included in the global cash flow analysis" but "must not be included in the repayment ability analysis," and 7(a) leaves it out of projected coverage [5]. The calculator's third case shows the effect: coverage of 1.38 with tenant rent and 1.05 without it, a failure at 1.15, and practice EBITDA of $310,046 before occupancy costs needed to pass. Those are model results from illustrative inputs, not market facts.

    Owner-occupancy, rent and coverage check

    Every default is an illustrative assumption you control, not market data. The occupancy tests and the repayment rule follow SBA SOP 50 10 8.1 and 13 CFR 120.131 as cited on this page.

    Practice occupies at least 51%Pass
    Leased space at most 49%Pass
    Practice share / leased share61.7% / 38.3%
    Practice space needed to pass / largest permanent lease5,220 sq ft / 5,880 sq ft
    Monthly payment / annual debt service$21,716.01 / $260,592.11
    Tenant rent after vacancy / building expenses$113,620.00 / $132,000.00
    Repayment coverage (tenant rent excluded)1.26x, passes 1.15x
    Global coverage (tenant rent included)1.69x
    EBITDA needed at the target / headroom$431,680.92 / $28,319.08
    Most a passive company may charge in rent$392,592.11 ($32.72 per sq ft)
    Net occupancy cost / per practice sq ft$278,972.11 / $42.92
    Share of carrying cost tenants pay if the practice leaves28.9%

    Illustrative model. Inputs are assumptions you control, not market data. A feasibility study replaces them with the building's measured plans, signed or proposed leases and the practice's own financial statements.

    Worked example: an owner-occupied building under SBA 504 (model)

    This example runs the tests in order on one hypothetical project. Every input is an FSC assumption, not a market figure; the rules are cited. A physician group plans a new two-story building of 14,000 rentable square feet, with an elevator, keeps 7,600 square feet for its own suites, and leases the rest to other practices.

    Exhibit 15. Worked example: occupancy, sources and coverage (model)

    StepModel input or resultRule applied
    Practice suites plus common areas7,600 plus 1,000 = 8,600 sq ft, or 61.4%At least 60%; common areas may count [4][5]
    Permanent leases2,800 sq ft, 20.0%Up to 20% [4]
    Temporary leases2,600 sq ft, 18.6%Another 20%, some taken back within 3 years and all within 10 [4][5]
    Project cost$7,500,000: land $900,000; construction $5,600,000; soft costs $500,000; contingency $280,000; interest during construction $220,000Contingency up to 10% of construction cost is eligible [4]; improvements to leased space are not [5]
    SourcesBank $3,750,000 (50%); debenture $2,625,000 (35%); borrower $1,125,000 (15%)15% if the CDC classes the building as special purpose [5]
    Annual debt service$537,953: bank at 7.25%, debenture at 6.50%, 25 yearsAssumed rates; 10-year Treasury 4.88% and prime 7.00% on November 9, 2026 [29]
    Building operating costs$161,000, or $11.50 per sq ftAssumption
    Practice EBITDA before occupancy costs$840,000, with current rent added backRent payments are an adjustment the CDC must justify [5]
    Repayment coverage, tenant rent excluded($840,000 less $161,000) / $537,953 = 1.26At least 1.15 [5]
    Global coverage, tenant rent included1.52, with $136,080 of rent ($28 a sq ft, 10% vacancy)Global analysis only [5]
    Passive company rent cap$698,953, or $49.93 per rentable sq ftLoan payment plus holding costs [4][5]
    If the practice leavesTenant rent covers 19.5% of debt service and building costsLimited or special purpose review [5]

    Source: FSC model; rules from 13 CFR 120 [4] and SBA SOP 50 10 8.1 [5]; rates from the Federal Reserve H.15 release [29].

    Exhibit 16. Worked example under stress (model)

    CaseRepayment coverageGlobal coverageResult at 1.15
    Base case1.261.52Passes, with $60,354 of EBITDA headroom
    Practice EBITDA 10% lower ($756,000)1.111.36Fails by $23,646 of EBITDA
    Both interest rates 1 point higher1.161.39Passes, with $3,278 of headroom
    Building operating costs 15% higher1.221.47Passes
    All third-party space vacant1.261.26Passes; tenant rent was never in the test
    10% contribution and 40% debenture1.191.43Passes; $375,000 less equity, $30,384 more debt service a year

    Source: FSC model results from the assumptions in Exhibit 15.

    In an SBA building the practice carries the debt. Losing every tenant leaves the repayment ratio where it was; a 10% fall in the practice's earnings fails it. So the study spends most of its effort on the practice's production, payers and succession.

    How much space does each specialty need?

    No federal source used here sets the size of a private practice suite, so the study builds each suite from the tenant's own schedule: providers, clinic sessions, rooms per provider and support space. The ratios in the second column are FSC planning assumptions, used until the tenant's architect confirms a program. The rules and data in the last column are sourced.

    Exhibit 17. Space programs and build-out drivers by tenant type

    Tenant typePlanning assumption (FSC)Build-out driversSourced rule or data
    Primary care2 to 3 exam rooms per providerExam room sinks, lab draw areaRural health clinics must run basic lab tests on site [42]
    Orthopedics3 to 4 exam rooms per surgeon, plus x-rayShielded x-ray, cast room, therapy area35.6% of certified surgery centers offer orthopedic surgery [31]
    Cardiology2 exam rooms per provider plus testing roomsStress and echo rooms, dedicated circuitsEquipment leases between referral sources need fixed rent [8]
    Imaging centerOne room per modality plus control roomsShielding, structure, coolingFixed-base testing facilities may not share or sublease their location [38]
    Surgery centerOperating rooms plus pre-op and recovery positionsMedical gas, ventilation, sterile processing, emergency powerMedian of 2 operating rooms [31]; separate recovery room and waiting area [25]
    Dental3 to 4 operatories per dentistVacuum and air lines, amalgam separators, x-raySeparators with at least 95% removal efficiency [41]
    DialysisTreatment stations in staff viewWater treatment, plumbing at each stationPatients in view of staff; video surveillance does not meet the rule [43]

    Source: FSC planning assumptions (second column); 42 CFR 491, 411.357, 410.33, 416.44, 494.60 and 40 CFR 441; CMS Provider of Services File, as cited.

    For scale, the 2018 Commercial Buildings Energy Consumption Survey found 129,000 outpatient health care buildings averaging 13,700 square feet [47], and CMS listed 7,522 active dialysis facilities in the third quarter of 2026 [54]. Surgery and dialysis suites load plumbing, power and structure far more than exam rooms, so the study prices the tenant mix before the shell.

    What tenant improvements and building specifications does the study test?

    The study tests whether the building fits the services the tenants will deliver, and whether the budget prices that fit. No federal source publishes medical office construction or tenant improvement cost, so every cost line is a labeled assumption until it is replaced by a contractor's bid. Service mix is the starting point.

    Exhibit 18. Patient care revenue by type of service, 2022

    Type of patient careOffices of physiciansFreestanding surgical and emergency centersOutpatient care centers
    Visits and consultations53.4%27.8%50.5%
    Surgical interventions13.0%52.0%13.4%
    Non-surgical interventions14.3%9.5%19.4%
    Anesthesia services4.9%2.5%0.7%
    Laboratory services3.1%2.4%1.9%
    Diagnostic imaging6.7%2.9%1.7%
    Other patient care, including space and equipment4.6%2.9%12.4%

    Source: U.S. Census Bureau, 2022 Economic Census, EC2262PATIENT, share of patient care revenue [22]. Laboratory and imaging combine the published lines for services paid by patients, insurers or government and services paid by other providers (summed by FSC).

    A building for visit-based practices is mostly exam rooms, offices and waiting areas. Freestanding surgical and emergency centers earned 52.0% of patient care revenue from surgery [22], and a surgery center is built around operating rooms, recovery and sterile processing under the rules in Exhibit 19. SBA lists surgery centers among its examples of limited or special purpose property [5], so the tenant mix drives both the budget and the collateral case.

    Exhibit 19. Federal rules that shape a medical office building

    RuleRequirementWho it reaches
    ADA elevator exemption for alterationsThe exemption for buildings under three stories or under 3,000 square feet per story does not apply to the professional office of a health care providerPublic accommodations altering a facility [23]
    Accessible medical diagnostic equipmentAt least 10% of each type of equipment, and at least one unit, must be accessible; 20% where care focuses on mobilityRecipients of HHS federal financial assistance, including physicians' offices [24]
    Accessible exam table and scaleAt least one of each within 2 years after July 8, 2024Same [24]
    Surgery center fire safetyLife Safety Code provisions for ambulatory health care occupancies, regardless of patient count; fire watch or evacuation when sprinklers are off more than 10 hoursMedicare-certified surgery centers [25]
    Surgery center building systems and layout2012 Health Care Facilities Code (NFPA 99); a separate recovery room and waiting areaSame [25]
    Rural health clinic locationIn a rural area designated as a shortage areaRural health clinics [26]
    Flood insuranceRequired on financed buildings and equipment in a special flood hazard areaSBA borrowers [4]
    Construction contingencyUp to 10% of construction cost is an eligible 504 project costSBA 504 projects [4]

    Source: 28 CFR 36.404; 45 CFR 84.92; 42 CFR 416.44; 42 CFR 491.5; 13 CFR 120.160 and 120.882, as cited in each row.

    The study then checks the specifications that decide whether the space works for these tenants and the next ones, as labeled assumptions until the architect and contractor confirm them:

    • Structure: column spacing and floor-to-floor height that allow exam room modules and later reconfiguration; slab capacity and shielding for imaging.
    • Plumbing and mechanical: sinks in exam rooms, exhaust and pressure control for procedure and sterile areas, and zoned heating and cooling.
    • Power and life safety: emergency power for procedure areas and drug refrigeration; sprinklers and alarms matched to the occupancy class.
    • Access and parking: an elevator for multi-story medical space (the ADA alterations exemption does not reach health care offices [23]), drop-off canopies, parking set by local zoning and patient volumes, and access tested against the state transportation department's traffic counts.
    • Tenant improvement split: what the landlord builds in the shell and what each tenant funds. SBA loan proceeds may not improve space subleased to a third party [5], so an SBA borrower funds third-party improvements from other sources.

    Bids should be current.

    Which operating assumptions move coverage most?

    Five assumptions move a multi-tenant building's coverage most: the rent basis, vacancy and credit loss, the cost of refitting suites when leases roll, reserves for building systems, and utilities. Utilities are the one with a federal benchmark used here.

    • Rent basis. A lease in which tenants reimburse operating costs yields more net income at the same quoted rent than a gross lease, so the study models each lease as written.
    • Vacancy and credit loss. Lease-up comes from the local survey, by month, with the month coverage first reaches the lender's ratio.
    • Refitting at rollover. Medical suites are built around plumbing and room layouts, so re-leasing reserves are priced from bids, not a general office allowance.
    • Building systems. Reserves for heating and cooling, emergency power and elevators follow the property condition report.
    • Utilities. Outpatient buildings use more energy than offices.

    Exhibit 20. Energy use and cost by building type, 2018

    Building typeBuildings (thousands)Floorspace (million sq ft)Mean size (thousand sq ft)Energy per sq ft (thousand Btu)Energy cost per sq ft
    All commercial buildings5,91896,42316.370.4$1.46
    Office97016,66217.265.6$1.63
    Health care, all1374,01829.3144.5$2.70
    Outpatient health care1291,76013.782.0$2.09
    Inpatient health care92,259264.8193.3$3.18

    Source: U.S. Energy Information Administration, 2018 Commercial Buildings Energy Consumption Survey, Tables C3 and C4 [47][48]. Costs are 2018 dollars for the sum of major fuels.

    Outpatient buildings used 25.0% more energy per square foot than offices and paid 28.2% more for it (calculated from [48]), so the study escalates utilities separately and reads the leases to see who pays.

    What rules govern a surgery center in a medical office building?

    Medicare's conditions for coverage. A certified ambulatory surgery center (ASC) must be a distinct entity that operates exclusively to provide surgical services to patients who do not need hospitalization, with an expected stay of no more than 24 hours [35]. In a medical office building that means its own suite, its own governance and its own certification, even when the surgeons own the building.

    Exhibit 21. Medicare conditions that shape a surgery center suite

    ConditionRequirementEffect on the building and the lease
    Definition (416.2)Distinct entity, exclusively surgical, stay of no more than 24 hours [35]A separate suite, not shared with clinic use
    Agreement (416.26)State survey, or deemed status through accreditation or licensure [35]Rent start should allow for the survey date
    Governing body (416.41)An effective procedure for immediate transfer to a local hospital [35]The study confirms the hospital relationship in the service area
    Surgical services (416.42)Pre-surgery examination for procedure and anesthesia risk [35]Pre-operative space and anesthesia work areas
    Environment (416.44)Life Safety Code ambulatory health care provisions regardless of patient count; NFPA 99; a separate recovery room and waiting area [25]Construction type, sprinklers, medical gas and layout
    Laboratory and radiology (416.49)Laboratory work under part 493; radiology only when integral to the procedures offered [35]Limits imaging use of the suite
    Medical staff (416.45)Privileges granted and periodically reappraised [35]Credit depends on surgeons who hold privileges

    Source: 42 CFR Part 416, revised as of October 1, 2025 [35][25].

    CMS's provider file for the third quarter of 2026 lists 6,665 active certified ASCs [31][32]. Of those reporting ownership, 95.3% were proprietary; 6.3% of those with an urban or rural code were rural [31]. Most are small: of 6,223 reporting operating rooms, 19.0% had one, 33.5% had two and 30.9% had three or four, a median of two [31]. One record lists 5,112 operating rooms, an entry error, so the study uses medians.

    Exhibit 22. Surgical specialties offered at certified ASCs, third quarter 2026

    SpecialtyASCs offering itShare of 6,227 reporting
    Orthopedic2,21735.6%
    Pain2,21635.6%
    Ophthalmologic2,06433.1%
    Endoscopy1,95831.4%
    Plastic and reconstructive1,67927.0%
    Podiatric1,64326.4%
    Ear, nose and throat1,38522.2%
    Obstetrics and gynecology1,06817.2%
    Dental4767.6%

    Source: CMS, Provider of Services File, iQIES, quarter ending September 30, 2026, active ASCs [31][32]. A center can offer several specialties; 52.6% reported exactly one. Shares calculated by FSC.

    Across the 50 states and DC there was one certified ASC for every 9,746 residents age 65 and older, from one per 3,185 in Maryland to one per 20,003 in New York (calculated from [31][13]). A low ratio can mean a crowded market or a long habit of freestanding surgery, so the study reads it with local surgeons' case volumes.

    Which certificate-of-need and imaging rules can stop a project?

    In some states a surgery center or scanner needs a state certificate of need, so the study confirms the rule before it models revenue. The table covers five states whose official sources state it.

    Exhibit 23. Certificate-of-need rules in five states

    StateSurgery centersImaging and equipmentCertified ASCs, 2026
    KentuckyAn ASC needs a certificate and a license [49]Major medical equipment needs a certificate [49]42 [31]
    GeorgiaReviewed in batching cycles; April 2026 took only exception applications, next need assessment around September 30, 2026 [50]Not covered by the notice414 [31]
    North CarolinaNew operating and GI endoscopy rooms are reviewed; a qualified urban facility in a county over 125,000 is outside the facility definition [51]From November 21, 2026, MRI review only in counties of 125,000 or fewer; major equipment over $2,000,000 [51]155 [31]
    VirginiaA center or office space developed for outpatient surgery is covered; added operating rooms are a project [52]CT, MRI and PET services and equipment are projects [52]82 [31]
    IowaApplicants include ambulatory surgery centers [53]Equipment costing more than $1.5 million [53]34 [31]

    Source: KRS 216B.061 [49]; Georgia Department of Community Health notice of April 1, 2026 [50]; N.C.G.S. 131E-176 [51]; Code of Virginia 32.1-102.1:3 [52]; Iowa HHS certificate of need program page [53]; CMS Provider of Services File [31].

    A certificate-of-need law does not always mean few centers: Georgia had 414, the fourth most of any state [31]. It changes timing and risk. Kentucky prohibits obligating a capital expenditure above the statutory minimum without a certificate [49], so the study shows the approval path and a denial case, and treats surgery or imaging revenue as unproven until approval.

    Federal rules for imaging tenants

    Imaging is either part of a physician practice or a separately enrolled independent diagnostic testing facility (IDTF), and the rules differ.

    Exhibit 24. Federal rules that shape an imaging tenant

    RuleRequirementWhy the landlord cares
    IDTF statusIndependent of a physician's office or hospital [38]Decides who enrolls and signs the lease
    Supervising physicianGeneral supervision of no more than three IDTF sites [38]The staffing plan must cover each site
    Fixed-base locationMay not share, lease or sublease its practice location to another enrolled provider, or share initial testing equipment [38]No shared imaging suites or subleases
    In-office ancillary servicesSame building (one street address), with an office open at least 35 hours a week and a physician practicing at least 30, or another test [39][20]Practice-owned imaging sits where the practice works
    Equipment rentalWritten, at least 1 year, fixed fair market rent, no per-use charges for the lessor's referrals [8]Counts only when fixed

    Source: 42 CFR 410.33, 411.355, 411.351 and 411.357 [38][39][20][8].

    For tests that need direct supervision, the physician must be present in the office suite and immediately available [40], so those rooms sit near physician offices.

    What does a dental tenant change?

    Payers, plumbing and practice size. Dental offices are smaller than physician offices: in 2023 they averaged 7.6 employees against 13.2, and 73.1% had fewer than 10 employees [10].

    Exhibit 25. Offices of dentists and physicians by number of employees, 2023

    EmployeesOffices of dentistsShareOffices of physiciansShare
    Fewer than 551,14237.7%107,85852.7%
    5 to 948,07635.4%38,18718.7%
    10 to 1929,79022.0%30,03014.7%
    20 to 496,1134.5%20,0429.8%
    50 or more5440.4%8,5004.2%

    Source: U.S. Census Bureau, County Business Patterns 2023, cbp23us, NAICS 621210 and 621111 [10]. Shares calculated by FSC; 50 or more combines published classes.

    1. Payers. Patients paid 39.6% of dental receipts from their own pockets in 2022 and private insurance 44.0% [2], so the study tests fees against local household income rather than Medicare rules.
    2. Plumbing. A dental office that places or removes amalgam and discharges to a sewer must capture amalgam with separators, or equivalent devices, rated at 95% removal efficiency or better, file a one-time compliance report (within 90 days of first discharge for a new office) and keep inspection records for three years [41]. Offices that practice only certain specialties, such as orthodontics or periodontics, are outside the rule [41].
    3. Acquisition rules. A 7(a) practice purchase is a change of ownership: coverage of 1.25 for an initial acquisition, an independent business valuation unless the price is $350,000 or less with no close buyer and seller relationship, and a quality of earnings report at $3 million or more [5]. The size standard for dentists is $9.0 million in receipts [6]. The dental practice acquisition model study works through that structure.

    What must a rural health clinic prove?

    Location, staffing and payment. A rural health clinic must sit in a non-urbanized area designated as a shortage area, must have a nurse practitioner, physician assistant or certified nurse-midwife available at least 50 percent of the time it operates, and is paid an all-inclusive rate per visit subject to a limit [42][26][18].

    Exhibit 26. Rural health clinic rules that shape the building and the loan

    RuleRequirementWhat the study tests
    LocationA rural area, meaning not a Census urbanized area, designated as a shortage area [42][26]The site's status before land is bought
    StaffingA nurse practitioner, physician assistant or nurse-midwife available at least 50 percent of operating hours; at least one PA or NP employed by the clinic [42]Rooms and offices for those providers; the recruitment plan
    LaboratoryBasic tests on site, including urine, blood glucose and pregnancy tests [42]A lab area in the program
    PaymentAll-inclusive rate per visit; limit of $165 in 2026, $178 in 2027 and $190 in 2028 under the general limit [18]Visits per provider and payer mix
    USDA pathBusiness and Industry fits for-profit owners outside cities over 50,000; Community Facilities serves public bodies, nonprofits and tribes [7][27]Owner type picks the program

    Source: 42 CFR Part 491 and 491.5 [42][26]; 42 CFR 405.2462 [18]; 7 CFR 5001 and 1942.17 [7][27].

    A hospital-owned clinic is read on its own terms, since the provider-based definition of a hospital department excludes an RHC [36]. Of the 5,626 rural health clinics enrolled in Medicare in the September 29, 2026 file, 3,581 (63.7%) were registered with the IRS as nonprofits and 2,034 (36.2%) as proprietary [33][34].

    The split varies by state. In Tennessee 284 of 328 clinics were proprietary, owners who would look to Business and Industry guarantees; in Iowa 197 of 217 were nonprofit, the borrowers Community Facilities serves [33][7][27]. The rural health clinic model study applies these rules.

    What happens to the collateral if the main practice leaves?

    The building is then worth what another medical user, or a general office user, would pay for it after the cost of refitting. SBA's procedures list "Hospitals, surgery centers, urgent care centers, and other health or medical facilities" among examples of limited or special purpose property [5], defined as "a limited-market property with a unique physical design, special construction materials, or a layout that restricts its utility" to its original use [5]. The CDC must address the question in its credit memorandum and explain its conclusion [5].

    The classification has direct financial effects:

    • More equity in 504. A limited or special purpose project requires a borrower contribution of at least 15%, with the debenture at no more than 35%; a new business in such a property contributes at least 20% [5].
    • A specialist appraiser. When the collateral is special purpose property, the appraiser must be experienced in the particular industry [5].
    • Longer terms on some acquisitions. A 7(a) loan for a change of ownership is generally amortized over no more than 10 years [5], but where an owner-occupied special purpose property is integral to the business, the maturity can reach 25 years if 85% or more of project costs are real estate [5].

    The study's re-leasing case answers four questions. How long would the owner's space take to re-lease to another practice, and at what rent and improvement cost? Could it convert to general office, and what would conversion cost, including elevator and accessibility work in alterations [23]? Do the remaining tenants' leases survive the owner's departure? And who in the market leases space of this type and size? In the calculator's first case, the third-party tenants' rent covers 28.9% of debt service and building costs if the owner practice leaves; that is a model result, and it is why the guarantees and the practice's succession plan matter as much as the real estate.

    Which financing paths fit a medical office building?

    Five paths cover most loans: SBA 504, SBA 7(a), USDA Business and Industry guarantees, USDA Community Facilities loans for public and nonprofit clinics, and conventional loans from banks or insurance companies. The right one depends on who occupies the building, where it is, and how much of it the owner uses.

    Exhibit 27. Financing paths compared

    FeatureSBA 504SBA 7(a)USDA Business and IndustryUSDA Community FacilitiesConventional and insurance company
    BorrowerSmall occupant, or passive company leasing to it [4][5]SameBusiness in a rural area [7]Public body, nonprofit or federally recognized tribe [7]Lender policy
    Size limitSBA portion $5,000,000 per borrower; $5,500,000 for small manufacturers and certain energy projects [4]$5,000,000 loan; $3,750,000 guaranty [4]$25 million per borrower [7]$100 million of guaranteed loans per borrower [7]Lender policy
    Occupancy51% existing; 60% new [4]Same [4]Not an occupancy ruleSpace leased for ineligible uses under 25% of floor area [7]Lender policy
    Equity10%; 15% for special purpose or a new business; 20% for both [4][5]10% for a start-up [5]10% existing; 20% new; 25% if guaranteed before construction is complete [7]Credit elsewhere test [27][7]Lender policy
    Coverage1.15 on historical EBITDA; tenant rent excluded from the repayment test [5]1.15 and 1:1 global; 1.25 for an initial acquisition; tenant rent excluded from projections [5]Lender's analysisRevenue sufficient for operation, maintenance, reserve and debt (direct loans) [27]Lender policy
    Term10, 20 or 25 years [28]Up to 25 years [4]Useful life, up to 40 years [7]Useful life, up to 40 years (direct loans) [27]Lender policy
    LocationNoneNoneOutside cities over 50,000 and their urbanized areas [7]Direct loans: not in a city or town over 20,000 [27]None
    Feasibility studySBA may require [4]SBA may require [4]Required above $1,000,000 for a new entity [7]Agency review of economic feasibility [27]Lender policy

    Source: 13 CFR Part 120 (revised as of January 1, 2026); SBA SOP 50 10 8.1; SBA 504 loans page; 7 CFR Part 5001 (revised as of January 1, 2026); 7 CFR 1942.17 (revised as of January 1, 2025).

    SBA 504

    The 504 loan fits an owner-occupant buying or building its own space. A third-party lender provides 50% or more of the financing, a Certified Development Company provides up to 40% through a debenture, and the borrower contributes at least 10% [5]. Because health and medical facilities appear on SBA's special purpose list, a medical project the CDC classes as special purpose contributes at least 15%, and the debenture falls to 35% [5]. SBA's page cites a $5.5 million maximum [28]; under the regulation that figure applies to small manufacturers and certain energy projects, and $5,000,000 applies otherwise [4]. The debenture rate is "pegged to an increment above the current market rate for 10-year U.S. Treasury issues" [28]; the 10-year yield was 4.88% on November 9, 2026 [29].

    Coverage must be at least 1.15 on historical cash flow, measured as EBITDA over the combined debt service after the loan, and repayment ability rests on the operating company's cash flow [5]. Rent payments are among the adjustments the CDC must justify [5], which is how a practice leaving leased space shows the rent it will stop paying. Rent from other tenants in the building stays out of the repayment test [5]. If history falls short, the CDC analyzes at least 2 years of projections, and if repayment works in Year 2 but not Year 1, the borrower must show liquidity for the Year 1 shortfall [5]. The Minnesota medical office model study works through a 504 structure in full.

    SBA 7(a)

    The 7(a) loan is more flexible: SBA lists uses from acquiring, refinancing or improving real estate and buildings to working capital [30]. The maximum loan is $5,000,000 and SBA's guaranty to one borrower is capped at $3,750,000 [4]; real estate terms run up to 25 years [4]. Coverage must be at least 1.15, with global coverage of 1:1, and projected coverage "may not include anticipated cash flow from rental income from the Project Property" [5]. In a multi-tenant building financed with 7(a), the owner practice has to carry the debt largely on its own cash flow.

    7(a) also covers a physician or dentist buying a practice together with its building. The general change of ownership rule limits amortization to 10 years, with the special purpose exception described above. Appendix 15 of the SOP sets coverage at 1.25 for an initial acquisition and 1.15 for a business expansion, and lenders may add back rent payments "when the owner-occupied commercial real estate is part of the transaction" [5]. The dental practice acquisition model study shows that structure. The prime rate, one of two acceptable base rates for variable 7(a) loans [5], was 7.00% on November 9, 2026 [29].

    USDA Business and Industry and Community Facilities for rural clinics

    USDA has two paths, set by who owns the clinic. A for-profit practice in a rural area can use a Business and Industry guarantee. "Rural" excludes any city or town of more than 50,000 inhabitants and the urbanized area next to it, and "applications cannot be approved subject to meeting rural area requirements" [7], so location is confirmed first. Guaranteed loans to one borrower are limited to $25 million, equity runs from 10% to 25%, terms follow the useful life of the assets up to 40 years, and a feasibility study is required above $1,000,000 for a new entity or activity [7].

    A public body, nonprofit or tribe can use Community Facilities, because "Health care facilities and services" are essential community facilities [7]. Direct loans are not made to a city or town of more than 20,000 inhabitants, run up to 40 years, require the applicant to show it cannot get credit elsewhere at reasonable rates and terms, and must be supported by revenues sufficient for operation, maintenance, a reserve and debt payment [27]. A nonprofit medical building can lease less than 25% of its floor space for ineligible uses; the rule's own example is "a pharmacy in a medical facility" [7]. Clinics seeking Rural Health Clinic status must also be located in a rural area designated as a shortage area [26]. The rural health clinic model study applies these rules.

    Conventional and insurance company loans

    Without a federal guarantee, each lender sets its own coverage, loan-to-value and lease requirements, and investor-owned multi-tenant buildings are financed this way. The evidence those lenders need is the same: a rent roll at fair market value, the credit of each tenant, lease terms against the loan term, and a re-leasing case.

    What will each lender ask?

    Each capital source starts from a different question, set by its own rules.

    Exhibit 28. Lender questions by program

    ProgramFirst questionsRule behind them
    SBA 504Is the building special purpose? Does history cover 1.15 without tenant rent? Is the appraisal an as-completed value?15% contribution; coverage; appraisal above $500,000 of property value, upon completion for new construction [5]
    SBA 7(a)Is this a change of ownership needing a business valuation and, at $3 million or more, a quality of earnings report? Is the appraiser state-certified for a property over $1,000,000?Appendix 15; appraisal standards [5]
    SBA, both programsWhat do the environmental questionnaire and records search show?Loans over $250,000 start with both; reports dated within one year of the loan number [5]
    USDA Business and IndustryIs the site rural? Are as-is and prospective values appraised? What do credit reports on 20% owners show?7 CFR 5001 [7]
    USDA Community FacilitiesIs the borrower public, nonprofit or tribal? Can it get credit elsewhere? Do revenues cover operation, maintenance, a reserve and debt?7 CFR 1942.17 [27]
    Conventional bank or insurance companyRent roll at fair market value, tenant credit, lease terms, re-leasing caseLender policy

    Source: SBA SOP 50 10 8.1 and Appendix 15 [5]; 7 CFR 5001 [7]; 7 CFR 1942.17 [27].

    USDA also tells lenders to weigh the "alternative uses" of collateral [7], the same question as SBA's special purpose review.

    What must a medical office feasibility study contain?

    1. The conclusion first, with any conditions or required changes spelled out.
    2. The project defined: rentable square feet, users, suites, specialties, services and phasing.
    3. Program fit: the occupancy test in rentable square feet, the passive company structure if used, size standards and the special purpose question.
    4. The service area by specialty and drive time, with residents by age today and projected.
    5. Supply: competing medical buildings and outpatient centers, with rentable area, tenants, rents, terms and space under construction.
    6. Demand by specialty, tied to the practices' own patient data and referral sources.
    7. Tenant credit for each practice: owners, production by physician, payer mix and contracts, and succession.
    8. A lease review: term against loan term, renewal and termination rights, expense recoveries and assignment.
    9. A fair market value rent conclusion for each lease between parties who can refer to each other, on general commercial terms.
    10. A building review: shell, tenant improvements by suite, accessibility, life safety for regulated uses and parking.
    11. The regulatory path for regulated tenants: ASC certification, certificate of need, IDTF enrollment, a hospital tenant's provider-based status and RHC certification.
    12. A development or acquisition budget with sources and uses, contingency, interest during construction and working capital, every line cited to a bid, a quote or a labeled assumption.
    13. Practice cash flow before occupancy costs, building operating costs and debt service, with coverage on the program's basis, with and without tenant rent.
    14. Downside cases: a fee schedule cut, the loss of the largest third-party tenant, a physician departure and a construction delay.
    15. A collateral and re-leasing case for the owner's space and for conversion to general office.
    16. Every source and assumption listed, with model outputs labeled as such.

    What does the study cost and how long does it take?

    The fee and delivery date are confirmed when the scope is set; the feasibility study cost page explains how fees are structured. Four things decide how long a medical office study takes:

    1. Whether the practice's financial statements, tax returns and payer and production reports arrive complete.
    2. Whether signed leases or letters of intent exist for the third-party space.
    3. Whether a regulatory question comes first: a certificate of need, ASC certification, IDTF enrollment or a hospital tenant's provider-based status.
    4. Whether plans and a contractor's budget exist, or the study must start from a space program.

    After closing, the model is a baseline: the lender can compare actual practice earnings, tenant rent and building costs with the study's cases each year.

    How the study runs

    1. Scoping: confirm the capital source, program, loan size, occupancy plan and the tests that apply.
    2. Document intake: practice financial statements and tax returns, payer and production reports, leases, plans, budget and any purchase contract, plus certificate-of-need filings, certification or enrollment status and provider-based status for regulated tenants.
    3. Field and market research: site inspection, building and rent survey, service area demographics and referral sources.
    4. Model: occupancy test, practice cash flow, building operating budget, debt service, base and downside cases.
    5. Review: the draft is checked against the lender's questions and revised only for new facts.
    6. Final report: signed by Sarrah Allen, MAI, with written answers to the lender's follow-up questions. More about who prepares the study is on the about page.

    Download the evidence behind this page's exhibits (CSV, 545 data points with sources)

    Frequently Asked Questions

    Does SBA require a feasibility study for a medical office building?
    Not on every loan. SBA may require one [4], and its procedures name triggers such as a highly specialized project property and market saturation [5]. Its 504 procedures add that independent reports, feasibility studies among them, can help offset weaknesses in the credit analysis [5].
    How much of the building must the practice occupy for an SBA loan?
    At least 51% of the rentable square feet of an existing building, or 60% of new construction, with up to 49% or 20% leased permanently to others [4][5]. Common areas may count toward the practice's share [5].
    Can several physician practices share one SBA-financed building?
    Yes. Separately owned practices can join as Operating Companies with one passive company, and together they must meet the occupancy rule [5][4]. Each must guarantee or co-borrow, and each 20% owner guarantees [4].
    Can a hospital or health system lease space in an SBA-financed building?
    Yes, as a third-party tenant inside the 49% or 20% limit [4]. It cannot be the occupying borrower unless it is small; the general hospital size standard is $47.0 million [6].
    How do Stark and the anti-kickback statute affect the rent?
    Leases between parties who can refer to each other need rent set in advance at fair market value, for at least one year, not tied to referrals [8][9]. Fair market value excludes the value of proximity to a referral source [20].
    Is a medical office building special purpose property for SBA 504?
    It can be. SBA's example list includes "other health or medical facilities," and the CDC decides and explains its conclusion [5]. If it is special purpose, the borrower contributes at least 15% [5].
    Can rent from other tenants count toward SBA coverage?
    Only in the global cash flow analysis. In 504 it must not be included in the repayment ability analysis, and 7(a) leaves it out of projected coverage [5]. In the calculator's third case, coverage falls from 1.38 to 1.05 without tenant rent (a model result).
    How does Medicare Advantage growth affect a medical office loan?
    It moves practice revenue from the federal fee schedule to negotiated plan contracts. Advantage and other plans covered 50.9% of Medicare beneficiaries in 2025 [3], so the study reads the practice's contracts as well as its payer mix.
    What has happened to Medicare physician payment updates?
    The statutory update was 0.0% a year from 2020 to 2025, with temporary increases in some years [15]. From 2026 it is 0.75% for qualifying APM participants and 0.25% for others, plus a 2.5% increase for 2026 only [15][16].
    Which USDA program fits a rural clinic?
    A for-profit practice uses Business and Industry, outside cities over 50,000 [7]. A public body, nonprofit or tribe uses Community Facilities; direct loans exclude cities and towns over 20,000 [27].
    Does USDA require a feasibility study?
    For Business and Industry guarantees above $1,000,000 to a new entity or activity, yes, by an independent qualified consultant acceptable to the Agency [7]. Below that, the Agency may require one when the lender's analysis cannot show feasibility [7].
    Does a two-story medical office building need an elevator?
    In alterations, the ADA elevator exemption for buildings under three stories or under 3,000 square feet per story does not apply to the professional office of a health care provider [23]. The study prices an elevator for any multi-story medical plan.
    How many Medicare-certified surgery centers are there?
    CMS's provider file for the third quarter of 2026 lists 6,665 active certified ASCs [31]. Of those reporting operating rooms, the median center had two [31].
    Does a surgery center in a medical office building need its own suite?
    Yes. A certified ASC must be a distinct entity operating exclusively for surgical services, with a separate recovery room and waiting area [35][25].
    Which states require a certificate of need for a surgery center or an MRI?
    It varies and changes often. Kentucky requires one for any new ASC, Virginia covers outpatient surgery and MRI centers, and North Carolina limits MRI review to counties of 125,000 or fewer from November 21, 2026 [49][52][51].
    Can an imaging center sublease space in the building?
    Not if it is a fixed-base IDTF: it may not share its practice location or lease or sublease it to another Medicare-enrolled provider [38]. The study treats imaging subleases as a compliance question.
    What is site-neutral payment, and why does a landlord care?
    Off-campus hospital departments that were not billing before November 2, 2015 are generally paid under the physician fee schedule [37]. An excepted department can lose its status if it relocates, which gives it a reason to stay [37].
    How far from the hospital can a hospital outpatient department be?
    The campus extends 250 yards from the main buildings; an off-campus department generally must be within a 35-mile radius, with narrow exceptions [36].
    Can a hospital let physicians use its suite part-time?
    Yes, under the Stark timeshare exception, for rooms used mainly for evaluation and management visits, with no advanced imaging and no possessory leasehold [8]. The study does not count that use as a lease.
    Does a dental office need special plumbing?
    Yes, if it places or removes amalgam: it must capture amalgam with separators, or equivalent devices, rated at 95% removal efficiency or better, and keep inspection records for three years [41].
    What staffing rule shapes a rural health clinic's space plan?
    A nurse practitioner, physician assistant or certified nurse-midwife must be available at least 50 percent of the time the clinic operates [42], so the plan includes rooms for those providers.
    How much more energy does an outpatient building use than an office?
    In 2018 outpatient health care buildings used 82.0 thousand Btu per square foot against 65.6 for offices, and paid $2.09 per square foot against $1.63 [48].
    Is new medical office construction rising or falling?
    Falling. Private medical building construction was $23.2 billion in 2025, 8.0% below 2023, and the September 2026 annual rate was $21.6 billion [44][45].
    What appraisal does SBA require on a medical building?
    In 504, an appraisal when the project property is worth more than $500,000, by a state-certified appraiser above $1,000,000, valued at completion for new construction [5]. The 7(a) rules set the same $1,000,000 certification line [5].
    Does buying a dental or medical practice require a business valuation?
    In 7(a), yes, unless the purchase price is $350,000 or less with no close buyer and seller relationship; at $3 million or more the lender also needs a quality of earnings report [5].

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