When our subscribers ask about physician contract compliance best practices, we caution them to be sure that the annual payment, the hourly rate, and the hours of service are compliant, and that contract performance and payments are tracked. Negotiating compliant terms and filing documentation isn’t enough. An effective compliance program also requires ongoing documentation that the work being performed is appropriate for the payments being made. Physician contract compliance is not complete after fair market value is documented.
New settlements for Stark, Anti-Kickback, or False Claims violations are being reported with growing frequency. Many of the parties had compliance policies in place that were not being followed. Violations that led to settlements, include:
- Automatically paying a physician the same amount each month without verification of work completed
- Continuing to pay a physician after the contract end date
- Not verifying physician time logs for accuracy
- Not confirming that reported activities are compensable
- Incomplete or missing time logs
These violations often result from the lack of automation or insufficient internal processes. Keeping time records is an essential, but often irritating task for physicians and administrators that has long been begging for a solution.
One solution to the challenge is a mobile app to replace paper time logs. One example of such an app is DocTime Log®, which allows physicians to report administrative duties via their cell phone or tablet while software automates and streamlines the reporting and payment process for approvers of the time logs. While MD Ranger’s Physician Contract Benchmark Reports help hospitals determine and document FMV, DocTime Log® matches reported time and activities to the contract terms, thereby simplifying the documentation and payment process.
Another tool that facilitates compliance is an easy-to-use contract management system that provides notification of end dates. MD Ranger provides a tool that includes effective dates and benchmarks each contract against current MD Ranger rates. Used in conjunction, these types of tools should increase your organization’s compliance and improve the workflow of your compliance team.
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