Welcome to the final installment in MD Ranger’s blog series on risk management! We hope that this series has been an interesting and informative resource for you and your organization. We’ve spent a lot of time talking about the potential consequences of Stark, Anti-Kickback, and False Claims Act violations.
Compliance matters. A dynamic compliance program can both minimize risk and allow for innovation. Involving compliance officers in the early stages of major decisions reduces risk and saves time. Top healthcare organizations have begun to include compliance officers in their C-Suite.
No one wants to be blindsided by compliance violations. Under the False Claims Act, the government could be auditing your organization without your knowledge. The biggest threat to a healthcare organization is ignorance. Think about your organization’s compliance program.
Are the administrators and compliance officers in charge of your physician contracts aware of the penalties for these violations?
Ask yourself the following questions:
1. Does your organization have contracts for all paid services and positions?
It is essential that you document all financial arrangements with physicians. Work with your administrators and C-Suite to ensure that all contracted positions have signed agreements including payment rate, defined services, and time requirements. Paying a physician for service without a contract in place is illegal.
2. Do you track or automate your contract expiration dates?
The law requires that physician contracts be set in advance. Identify all expired contracts and prioritize them for renewal. If your organization doesn’t have a contract management system, consider either building or purchasing one.
3. Do you know how many physician contracts your organization currently has?
MD Ranger has found that community hospitals have an average of 50-60 physician contracts. Larger organizations and health systems have numbers skyrocketing into the thousands. Understanding the scope of market positions of your contracts and payment rates will help you identify high-risk contracts before they become a problem.
4. Do you know which of your contracts are high-risk?
Contract review is not rocket science. Annual review of your contracts against published benchmarks is a simple way to identify potential areas of concern. If your organization has risky or high-profile contracts, they may require extra documentation. Familiarize yourself with payment rate benchmarks and how they apply to your facility or system.
5. Does your organization have a system for handling exceptions to market data?
When your organization compensates a physician above or below fair market value, do you have a process for documenting exceptions? There are no explicit prohibitions to paying physicians above a certain threshold, but you need to justify your actions.
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