How to Talk to Physicians about Compensation as it Relates to Compliance
This is admittedly a tricky topic. Physicians can become suspicious when hospitals talk about FMV and think it’s an excuse for hospitals to pay them less. This often is because of lack of education. If this is the case at your organization, you must work hard to mythbust.
We recommend being straightforward about the definition of FMV and give real-world examples of what that means. Talk about ways to determine FMV: market data, valuation methods, and your organization’s preferred method. Give case examples. Try writing up some FAQ’s relating to FMV, Stark Law, and the Anti-Kickback Statute for doctors.
When it comes to discussing methods to determine specific doctor’s compensation, organizations take one of two positions. Some choose to share their methodology, data, and research with physicians on how they are determining their compensation. Others choose not to reveal sources. There are legitimate reasons for each position. We recommend that whatever approach your organization chooses, be consistent. Always explain your reason(s) why.