The document summarizes key points from an MD Ranger webinar on auditing physician contracts effectively. It discusses the importance of audits to ensure compliance with regulations and align contracts with organizational goals. It provides tips for planning audits such as checking processes, knowing resources, and prioritizing high spend service lines. An example is given where total spend analysis in MD Ranger uncovered higher than typical directorship payments. The document also introduces MD Ranger as a platform providing over 300 physician payment benchmarks and tools to standardize processes, document fair market value, review contracts, and mitigate compliance risks.

1. AUDIT PHYSICIAN
CONTRACTS THE
SMART WAY
October 24, 2019
www.mdranger.com

2. Disclaimer! Pull in legal
• MD Ranger doesn’t give legal advice
• All serious matters regarding potential
Stark or AKS violations (or questions)
should go to your counsel under
privilege
• Fear overpayments based on
comparisons to benchmarks? Talk to
your attorney to consider your options.

3. Your speakers
Lauren Dominik-Slaven
• Lauren specializes in developing and refining
physician contracting processes, policies, and
procedures. Lauren has over nine years of experience
in healthcare working with legal and compliance.
Daniel Perry
• Daniel focuses on supporting MD Ranger users to get
the most out of their subscriptions and advising
healthcare providers on how to optimize use of
benchmarks to support the compliance process.

4. Today’s agenda
Why contract audits are important
Planning and executing your audit
Physician contracting best practices
How MD Ranger can help with audits

5. THE IMPORTANCE OF AUDITS

6. Government regulations
• Numerous state and federal regulations govern
physician payments
• Goal is to reduce and eliminate fraud
• Vague language, legal complexity, and physician
relationships themselves can make adherence
challenging

7. Major compliance regulations
• Stark Law: Limits certain physician
referrals of DHS if a physician or the
physician’s family members have a
financial relationship with that entity,
unless an exception applies
• Anti-Kickback Statute: Prohibits the
exchange or offer to exchange anything
of value to induce the referral of health
care services (any items) from any
person or provider
• False Claims Act: imposes liability on
people/organizations who defraud
government programs

8. Align contracts to organizational goals
• Make sure contracts are aligned with
overall strategic, financial, and
compliance goals
• Are they on the right track?
• Have they been effective: are additional
resources and support needed to achieve
your organization’s goals?
• Is your organization taking compliance
seriously?

9. PLANNING AND EXECUTING AN AUDIT

10. Goals of an internal audit
• Provide overview and oversight of organization-wide
contracting practices
• Uncover problematic or potentially non-compliant
agreements, and bring them to the attention of your
legal and/or compliance team
• Ensure all agreements have necessary
documentation for FMV
• Check for duplicative services

11. Check processes
• Review overall contracting criteria and process
✓ Is time commitment specified in contracts with hourly
payment rates?
✓ Are time records kept, submitted and reviewed?
✓ Are contract renewals timely?
✓ What is the approval process?
✓ Is FMV documented at the time of approval?
• Review major terms of each contract
• Ask key questions of each contract
• Document process, results, and follow up
• Use MD Ranger for all these steps

12. Know your team and resources
• Your audit process depends on your
organization
• Previous audits: figure out what worked,
what didn’t
• Involve staff with contract oversight
responsibility and if you can, integrate
other staff or contractors to assist
• Involve management and board with high
level reports on expenditures and market
rate comparisons

13. If resources are limited…
• No auditing team? No problem!
• You don’t need much infrastructure for a successful
internal audit—all you need is MD Ranger
• MD Ranger’s online platform can support your
internal auditing efforts

14. Auditing call arrangements
• Use dynamic
reporting to review all
call coverage
contracts
• Sort by:
• Quantiles
• Per diems
• Facility
• Service
• Expiration date
• …and more

15. • Total spending report
helps understand
scope of resource
allocation
• View by spending by
facility or
specialty/service line
• Use MD Ranger total
facility benchmarks
to gauge if your
organization is in line
with peers
Prioritize service line audits by spend

16. •Time records?
•Contract comparisons?
•Market rate
documentation?
Review effectiveness
of documentation
process
•Across services and
service line?
•Across facilities?
Compare payments •Approvals?
•Reporting?
Review key
processes and
policies
•Who
•What
•When
Follow up
Orchestrating an audit

17. Executive involvement and support
• A member of the hospital’s executive
team should be accountable for the
audit
• Executive should interpret findings and
make organizational wide
recommendations to mitigate risk
• The individual should have the authority
to execute follow up steps
• Executive should report the audit’s
results to other hospital management
and board to determine if external audit
is warranted
• Executive should determine if additional
policies, procedures or processes are
needed to help void risk in the future

18. Audit timing
• Schedule an appropriate time within your
organization’s budget cycle
• Plan enough time to complete the audit
• Consider when the bulk of your contracts come up for
renewal

19. Recording the auditing process
• Review the entire auditing process and document the
discussion or meeting
• Create a file or document to capture your internal
process. Include:
• Memos written by responsible executive or leader
• Minutes from meetings
• Flags and notes
• List of follow up items in one place, as collected from
above documents, notes, memos, and emails

20. Follow up
• Execution and accountability are
essential for a successful audit, which is
what makes follow up so important
• Track all next steps in one document;
review progress weekly in the month
following the audit and monthly post-
audit
• Good project management is key

21. UNCOVERING POTENTIAL RISKS- EXAMPLE

22. 22
Organization seeks to understand its profile

23. Examined total spend
• This organization underwent an audit of
its total spending on physician
agreements
• They used MD Ranger’s Total Facility
Benchmarks
• They found:
• Higher than typical directorship
payments
• Hourly rates remained in compliance

24. Important discovery:
spend driven by hours
MD Ranger reports provide market rate comparisons for all contracts at-a-glance

25. ABOUT MD RANGER

26. 300+ Physician Benchmarks
• Call coverage rates
• Medical direction payments
• Administrative and leadership
• Hospital-based service stipends
• Diagnostic testing, etc.
• Clinic & hourly rates
• Telemedicine rates
Online Platform
• Benchmark lookups
• Contract proposal tools
• Contract reports by facility and
service
• Total facility costs + benchmarks
Research and Support
• Resources for education and
training
• On-call experts to help
subscribers use benchmarks
and tools
Compliance Documentation
• Contract-specific FMV
documentation reports
• Reports to assist with real-time
monitoring and annual reviews
Meet MD Ranger

27. Standardize
processes and
rates
Document FMV
Access 300+
payment
benchmarks
Review and
monitor
contracts
Have data-
driven physician
negotiations
Mitigate
compliance
risks
The foundation of your contracting process

28. Our database
• More than 250 subscribing facilities
• More than 36,000 physician contracts
across 350+ facilities
• Data covers 32 states
• 25% of reported data are from trauma
centers (Level I and II)
• Includes large systems, independent,
rural, and urban hospitals
• Multiple types of providers:
• Behavioral health
• Dialysis centers
• General acute
• Home health
• Hospice
• Long term acute care/ventilation
• Pediatric
• Rehabilitation
• Skilled nursing
• Telemedicine

29. • Call Coverage (55+)
• Medical direction (90+)
• Hospital-based services and
stipends (20+)
• Administrative (12+)
• Medical Staff Leadership
• Diagnostic/other services
e.g. ROP, autopsy, dialysis
• Clinical hourly professional
services
• Telemedicine
• Residency/teaching/GME
• Uncompensated care
• Meeting attendance, peer review,
IT/EHR and quality initiatives
• 13 pediatric services, with more
emerging each year
Hospital-characteristics drill down
for ADC, bed size, trauma status,
urban/rural, stroke centers,
teaching status, and more
Used in such diverse settings like
academic medical centers,
integrated delivery systems, and
critical access facilities nationwide
Our benchmarks

30. Let’s talk
⁃ Do you struggle with your physician contracting
policy and strategy? Are you performing
regular audits?
⁃ Are you spending too much on FMV opinions?
⁃ Do you think your organization could become
more efficient with access to a streamlined
platform with benchmark lookups and
autogenerated reports?
⁃ Reach out: lslaven@mdranger.com,
dperry@mdranger.com or 650-692-8873