Healthcare organizations often struggle with developing processes and best practices for both the creation and the execution of physician agreements. By knowing the risks, you can squash problems before they pop up as potential violations with serious consequences.
This slide deck covers best practices healthcare leaders can use to refine their organization’s financial and compliance processes, including:
-Educating staff
-Determining and documenting FMV
-Identifying and handling potentially risky contracts
-Examples of and solutions to risky situations
2. Agenda
1. Introduction
2. Why physician contracting feels like Whack a Mole
3. Playing to Win: Best Practices for Physician Contracts
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3. Introducing MD Ranger
§ The foundation of your physician contracting
program in an integrated, online platform
§ Access 300+ proprietary compensation
benchmarks
§ Call coverage
§ Medical Direction
§ Hospital-based services
§ Diagnostics
§ Clinical professional services
§ Facility total benchmarks, percent paying, and more
§ Standardize FMV documentation
§ Audit spending
§ Monitor compliance
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4. 4
§ Active financial management of physician
agreements
§ DocTime Log®: a mobile application for physicians
to submit time and web-based SaaS that
automates workflow
§ Documentation for compliance audits and
reporting to CMS
§ Approvals of all submitted time with notes
attached for audit trail
§ Payments for very complex physician agreements
using software to track all payment rules
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Introducing Ludi
6. Compliance involves many steps
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§ Use Templates
§ Annual review of all agreements
§ Compliance audits
§ Financial review
COMMERCIAL
REASONABL-
ENESS
CONTRACT
MGMT
DUTIES
FAIR
MARKET
VALUE
TERMS
7. High volume of arrangements can be chaotic
§ If you don’t have
policies and
procedures, it’s easy
to be distracted by
issues and challenges
that arise
§ If you don’t have a
good way to work
renewals, they can
sneak up on you 7
8. FMV breached because agreement isn’t followed
§ Operationally FMV is not maintained when a
monthly or annual maximum is exceeded
§ Contract is not adjudicated financially on a
consistent basis, or ever
§ Layering of agreements leads to duplication of
duties and time paid
§ Calculations are incorrect
§ Math is incorrect in the contract or so complex it is
too difficult to follow
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9. Most tracking currently takes place on paper and goes through a multitude of steps for
approval and payment
What the physician writes may not be a duty
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Room for error
Measuring spend
Frustrating for
physicians
Compliance risks
10. Manual processes can lead to technical violations,
i.e. paper time logs
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Physician
Logs Time
Physician
Receives
Payment
12. Standardize your process and create policies
1. Test for commercial
reasonableness
2. Find benchmarks with
appropriate sample sizes
3. Determine if scope of services is
a good match
4. Find best payments within the
market ranges (your
organization should have a
policy about this; if not, create
one)
5. Negotiate payment with the
physician or group
6. Document FMV! 12
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13. Assess commercial reasonableness
§ When payment is requested, never grant without analysis
§ If it is commercially unreasonable to pay a physician for a service in the first
place, you have bigger problems than merely a high payment
§ Benchmarks can help you establish commercial reasonableness
MD Ranger’s ”Commercial Reasonableness Toolkit” is available for
download today
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14. Use market data with care
q Consider sample size and participant
characteristics of the survey
q Who reports the data?
q Where are the providers?
q How are Antitrust Safety Zone
Guidelines interpreted?
q Is the data collected consistently and
comprehensively, and is it routinely
audited by experts?
q Are the most helpful, relevant
statistics reported?
q What is the distribution of rates within
the data?
q Am I comparing ”apples to apples”?
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Market data can be a powerful way to determine physician
payment rates, but there are pitfalls to avoid.
15. Determine payment within FMV range
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• 75th percentile and under generally considered within “fair
market value range”
• It’s normal for an organization to have a small handful of
agreements that exceed the 75th percentile, or even a few
above the 90th percentiles
• These contracts must be carefully vetted and reasons for higher
payments should be justified
• Paying above fair market value thresholds should be a rare
occurrence, not standard!
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17. Collect time logs for all non patient care activities
for employed or independent
18. 10 Unique Duties Per
Facility
(10 x 60 = 600)
Standardize and streamline duties
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§ Ensure that the service line adheres to each hospital’s policies and procedures,
applicable laws and regulations, accrediting body requirement and other regulatory
compliance, and make recommendations to hospital personnel.
§ The Director shall ensure compliance with regulatory agencies governing the
medical staff, including the Joint Commission and state and federal agencies with
the assistance of hospital personnel in the service.
§ The Medical Director, in collaboration with the unit leadership, nursing director and
hospital leadership, facilitates compliance with: department policies; TJC standards;
federal rules and regulations; corporate integrity agreements
§ Time consuming to check time log against
specific duties each month – operational
challenge
Reduce Variation
19. Approvers should be trained and have clear
accountability
Access to physician’s historical and current logs
Access to actual contract
20. Mind the math not only with setup but with every
payment
Current time log details Year-to-date view
21. Infrastructure needs to operationalize
financial management of agreements
Physicians are
accountable
Clear expectations
Manage what you
measure
Dashboards and data
Payments are within
scope and more timely
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22. Assess overall spend
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Compare yourself to similar
organizations
MD Ranger calculates facility totals benchmarks by summing
estimated values for all physician agreements. Taking each hospital
total as a single data point, a distribution of facility total spending is
formed and the percentile values are reported.
Discover if you’re paying too
many medical directors
Determine if you’re spending
too much on call coverage,
directorships
Analyze aggregate spending
on physician contracts