Roadmap for Physician Contracting: Setting Up for Success in 2017
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Transcript of Roadmap for Physician Contracting: Setting Up for Success in 2017
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ROADMAP FOR PHYSICIAN CONTRACTING:
SETTING UP FOR SUCCESS IN 2017
DECEMBER 2016
Today’s topics
• Who we are
• Guidance from OIG
• Our crystal ball: physician contracting in 2017
• Best practices to kick off the year
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MD Ranger: the foundation of your
compliance process
Standardize processes and rates
Document FMV
Access 250+ payment
benchmarks
Review contracts and monitor with
ease
Have smarter, data-driven physician
negotiations
Mitigate compliance
risks
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Our benchmarks
• Call Coverage (55+)
• Medical direction (85+)
• Hospital-based services (15+)
• Administrative
• Medical Staff Leadership
• Diagnostic/other services e.g.
ROP, autopsy, dialysis
• Hospital-based stipends
• Clinics, professional services
• Telemedicine
• Residency/teaching/GME
• Uncompensated care
• Meeting attendance, peer review,
IT/EHR and quality initiatives
• 13 Pediatric services, with more
emerging each year
Hospital-characteristics drill down
for ADC, bed size, trauma status,
urban/rural, stroke centers, and
more.
Used in academic medical centers,
integrated delivery systems, and
hospital organizations.
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Our subscribers
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LESSONS FROM THE OIG
Yates Memo
• Published September
2015
• Discusses the personal
accountability of
physicians and
healthcare executives in
fraud
• Example: Tuomey CEO
Jay Cox fined $1 million
this year for violations
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Settlements abound
• ACA turns up the heat
• DOJ funnels more resources
into investigating fraud
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Tenet Healthcare Corporation: $513 million
• Two Georgia hospitals charged with paying kickbacks
in exchange for referrals
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Lexington Medical Center: $17 million
Dr. Venkateswara Kuchipudi: $786,000
• Violated Stark by improper financial arrangements with
28 physicians
• Involvement in complex Medicare fraud scheme
landed this physician jail time, too
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PHYSICIAN CONTRACTING 2017
Medical directorships are both risky
and expensive
• Many organizations auditing medical directorship
payments and looking for ways to streamline
spending
• These administrative payments attract scrutiny
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Call coverage demands from
physicians could increase
• Some organizations don’t pay for call; others spend
millions annually
• With incomes uncertain, physicians may ask for
additional payments for financial security
• If coverage becomes an issue, providing ED
coverage services could become even less appealing
to doctors
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Healthcare organizations face larger
fines
• The Bipartisan Budget Act of 2015 mandated that
federal agencies make inflation adjustments to the
amounts of civil monetary penalties.
• This year’s increases are substantial: False Claims
Act penalties have not been adjusted in 20 years. • The fines for False Claims Act violations are now $10,781 at the
minimum and $21,563 at the maximum.
• Stark Law fines increased from $15,000 to $23,863 per violation
• Anti-Kickback Statute fines increased from $50,000 to $73,588.
• Penalties are expected to increase based on inflation
each year.13
False Claims Act in the spotlight
• Since the passing of ACA, the False Claims Act has
become more prominent in healthcare
• The FCA could apply to any fraudulent government
payment (like Stark and Anti-Kickback violations)
• Experts seem to think that the False Claims Act will
continue to be a liability for organizations.
Remember: FCA penalties substantially increase the
potential repayment amount.
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BEST PRACTICES FOR KICKING OFF
2017
Outline your organization’s process
• Give your process the organization it needs with a
foundational document:
• Include the purpose of your physician contracting
process and the intended outcomes.
• Outline step by step how contracts will be processed
as well as team roles and responsibilities.
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Get buy-in and consensus
• Get buy-in from key executives, committees, and
board members
• Ensure that leadership understands importance of
physician contracting compliance process and agrees
upon processes and guidelines
• Communicate compliance measures and safeguards
to hospital employees and medical staff
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Store all your contracts in a centralized
location
• Contract management systems are key to all
physician contracting programs
• Find the right vendor to meet your needs
• Demand utilization
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Develop a process to determine FMV
consistently
• Certifying that physician agreements are FMV should
be the cornerstone of effective physician contracting
programs
• Discuss what is best for your organization with your
team
• Once determined, codify your process in a
foundational document
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Create (or update) guidelines for
handling exceptional agreements
• Not every agreement should be negotiated above the
75th or 90th percentile; however, organizations always
have one or a few exceptions
• Be prepared and create an exceptions process in
advance to process these requests
• If you are smart about it, you can structure guidelines
in a way that discourage exceptions—always a good
thing
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Educate your staff on regulations and
enforcement actions
• Join associations or attend
conferences
• Keep up with the OIG online
• Consider yearly trainings
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Make a plan to audit physician
contracts
• Annual audits are always a
good idea
• Consider smaller audits
each quarter
• Whatever your schedule,
use technology to make
your job easier
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Thank you!
MD Ranger, Inc. | 1601 Old Bayshore Hwy, Ste. 107 | Burlingame, CA 94010
www.mdranger.com
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