It’s an exciting time at MD Ranger headquarters in Burlingame, California. Over the past four months, we have collected thousands of contracts from our 200+ subscribers across the US. In preparation for publishing our annual benchmark report (coming soon!), we’ve been auditing our data and working around the clock to ensure our data is reported accurately.
One of the reasons why we’ve been able to produce high quality data year after year is our rigorous data auditing process. We like to be transparent, so I wanted to take the opportunity to tell you how we whip our data into shape.
First, we review all data that comes in from subscribers as soon as it comes. This allows us to look at the hospitals’ contracts holistically, and in relation to all other contracts at the hospital. This makes it easy to catch if there’s a strange number of contracts (say, three medical directors of radiation oncology on one campus), or if there’s a strange per diem (say, $5,000 for family practice coverage that probably is $500 instead). We run updates on our database internally, to check and see if our data is changing (and if so, by how much).
As we get closer to production time, we start auditing our data by service. What this means is that we take an entire service, say general surgery call coverage, and we look at each contract within the service for errors. We pay special attention to outliers (especially high or low contracts), as well as statistics that have changed from last year’s published data. As our database grows larger and more diverse, the more stable it becomes.
MD Ranger prepared a quick list of compliance tips for hospital and health system executives dealing with physician contracts for administrative, leadership, on-call, and hospital-based services. These tips will help shape a new physician contracting compliance program or refine an existing program. Apply these tips to create a successful compliance program to help prevent Stark violations.
Establish a rigorous contract management process and assign staff to oversee day to day management of your physician contracts. Contract management may be straightforward in terms of processes and best practices, but the trick is ensuring proper execution and consistent application of procedures. Every compliance program should be incorporating the following contract management elements:
- Have a contract for all physician arrangements (even non-monetary ones)
- Organize your contracts by date, party, and expense
- Alert your team to expiring contracts well in advance of expiration
- Establish a renewal process that includes:
- Reviewing or updating a contract
- Checking the rate against relevant benchmarks
- Negotiation strategy
- Necessary approvals
- Strategic contract management
It is also important to identify and prevent the development of silos that mask overall payments to individual physicians or groups for similar services. Contract management teams should work across the organization as a true cross-functional team so that there is a comprehensive appreciation of contracting costs.
MD Ranger attended “The Future of Health Care Leadership Summit” in San Francisco this morning. This annual event is produced by the San Francisco Business Times, and is always a big hit among the business and health care community in the Bay Area.
Today’s panelists were:
Mark Laret, CEO, UCSF Medical Center
Paul Markovich, CEO, Blue Shield of California
Dr. Tom Lee, CEO, One Medical Group
David Joyner, COO, Hill Physicians Medical Group
Wade Overgaard, Senior Vice President, Health Plan Operations, California, Kaiser Permanente
The discussion revolved around topics of health care affordability and sustainability, and how technology could help us achieve both. Because the implementation of the Affordable Care Act is in such early stages, it is still difficult to predict effects of this major transformation. Interestingly, no provider was comfortable reporting seeing an influx of patients with expanded coverage, nor did they comment on any changes to payer mixes or any other effects of the exchanges. They were still in “wait and see” mode.
The specific types of technologies mentioned to decrease the costs of healthcare have to do directly with the consumer. Telemedicine was heralded as important contributor to lowering healthcare costs and accessibility challenges. Handheld mobile devices could be the key to further innovation for consumer education, marketing, and and even treatment. Why hasn’t healthcare already embraced these technologies that have been critical for innovation in other industries? According to panelists, reimbursement must keep up with the changing pace of technology and health care. The argument was that provider will adopt a technology if there isn’t a way to get paid for it.
The panelists imagined seeing both cost savings and patient satisfaction increase when care is coordinated across the continuum, with an emphasis on customizing the message. While the panelists urged communicating to consumers in a personalized fashion, no solutions discussed on how exactly to do this.
Monday, I attended the session “What’s FMV Got to Do with It?: The Role of Fair Market Value in Physician Employment Arrangements”. While MD Ranger doesn’t benchmark employed or salaried physician data, it is very closely related to the contracted physician arrangement. Because of the recent developments in the Halifax case, this session revolved much around this example.
Much of the debate over the Halifax case, according to this session, stems from whether the physician arrangements in question were employment arrangements or not. Employment and contracted physician arrangements are held to different standards under Stark and AKB. It is important to note that when you have a bona fide employee, you can pay them for referrals but, a contracted physician is subject to the referral regulations and penalties from violations under Stark law and AKB.
How do you document employment of physicians or the FMV for contracted physician arrangements in your organization?