How does your organization ensure its financial relationships with physicians are compliant with federal regulations? To help determine whether or not they might have a physician contracting compliance risk, we created a checklist.
This webinar will cover all elements of our checklist, and integrate best practices from other healthcare organizations. Key topics discussed will be:
--Current regulations and penalties
--Contract organization, analysis
--FMV documentation processes
Audit Smart: A Best Practices Webinar for Physician Contracting MD Ranger, Inc.
Organizations routinely audit physician contracts to comply with federal regulations, practice good financial management, and maintain relationships with key physicians.
Our compensation benchmarks and online analytics offer unparalleled insights into physician compensation. MD Ranger empowers executives to be able to analyze, negotiate, and document physician contracts. Executives and their teams can determine appropriate compensation rates, negotiate competitive contracts, comply with federal regulations, and identify opportunities for cost savings with MD Ranger.
You can contact the MD Ranger team with questions or for more info at inquiries@mdranger.com.
Many organizations struggle to find a way to document fair market value in an efficient and cost-effective manner. For hundreds of healthcare organizations, MD Ranger has taken the headache out of FMV documentation.
Both Stark and AKS require that physician contracting rates be negotiated at fair market value. What the regulations lack is clear, tactical advice for determining and documenting FMV. Physician contract compliance can be less of a headache if your organization takes a planned, methodical approach to obtaining and recording payment rates.
Physician contract compliance can be less of a headache if your organization takes a planned, methodical approach to obtaining and recording payments rates.
If your facility could use best practices for determining and documenting FMV for physician contracts, join us for our 30-minute webinar covering:
--The meaning of FMV
--Various methods to determine FMV
--Strategies for efficient documentation
Measuring the Financial Health of Your Physician Contracting ProgramMD Ranger, Inc.
The average hospital spends 3-5% of its total operating budget on physician contracts for emergency coverage, administrative positions, and hospital-based service agreements. These expenditures cannot be ignored
any longer: the financial impact of these relationships can affect the financial outcomes of the entire organization.
Physician contracting compliance is a serious concern for healthcare executives, attorneys, and compliance professionals. Maintaining compliance of physician contracts requires balancing physician relationships and paying fairly.
This webinar will cover best practices hospital leaders can use to refine their organization's compliance processes, including:
-Educating staff
-Determining and documenting FMV
-Identifying and handling potentially risky contracts
This deck will cover key topics including:
• Why audits are important
• Planning and executing your audit
• Physician contracting best practices
• How MD Ranger can help with audits
• ...and more!
Essential Elements of Physician Contracting Compliance ProgramsMD Ranger, Inc.
How does your organization ensure that its financial relationships with physicians are compliant with federal regulations like Stark? To help our subscribers leverage the power of MD Ranger data for documentation and FMV purposes, we have assembled a list of key pointers to help you streamline and improve your physician contracting compliance program.
Audit Smart: A Best Practices Webinar for Physician Contracting MD Ranger, Inc.
Organizations routinely audit physician contracts to comply with federal regulations, practice good financial management, and maintain relationships with key physicians.
Our compensation benchmarks and online analytics offer unparalleled insights into physician compensation. MD Ranger empowers executives to be able to analyze, negotiate, and document physician contracts. Executives and their teams can determine appropriate compensation rates, negotiate competitive contracts, comply with federal regulations, and identify opportunities for cost savings with MD Ranger.
You can contact the MD Ranger team with questions or for more info at inquiries@mdranger.com.
Many organizations struggle to find a way to document fair market value in an efficient and cost-effective manner. For hundreds of healthcare organizations, MD Ranger has taken the headache out of FMV documentation.
Both Stark and AKS require that physician contracting rates be negotiated at fair market value. What the regulations lack is clear, tactical advice for determining and documenting FMV. Physician contract compliance can be less of a headache if your organization takes a planned, methodical approach to obtaining and recording payment rates.
Physician contract compliance can be less of a headache if your organization takes a planned, methodical approach to obtaining and recording payments rates.
If your facility could use best practices for determining and documenting FMV for physician contracts, join us for our 30-minute webinar covering:
--The meaning of FMV
--Various methods to determine FMV
--Strategies for efficient documentation
Measuring the Financial Health of Your Physician Contracting ProgramMD Ranger, Inc.
The average hospital spends 3-5% of its total operating budget on physician contracts for emergency coverage, administrative positions, and hospital-based service agreements. These expenditures cannot be ignored
any longer: the financial impact of these relationships can affect the financial outcomes of the entire organization.
Physician contracting compliance is a serious concern for healthcare executives, attorneys, and compliance professionals. Maintaining compliance of physician contracts requires balancing physician relationships and paying fairly.
This webinar will cover best practices hospital leaders can use to refine their organization's compliance processes, including:
-Educating staff
-Determining and documenting FMV
-Identifying and handling potentially risky contracts
This deck will cover key topics including:
• Why audits are important
• Planning and executing your audit
• Physician contracting best practices
• How MD Ranger can help with audits
• ...and more!
Essential Elements of Physician Contracting Compliance ProgramsMD Ranger, Inc.
How does your organization ensure that its financial relationships with physicians are compliant with federal regulations like Stark? To help our subscribers leverage the power of MD Ranger data for documentation and FMV purposes, we have assembled a list of key pointers to help you streamline and improve your physician contracting compliance program.
Navigating Medical Staff Officer and Physician Leadership Compensation MD Ranger, Inc.
Every hospital has a medical staff that functions as an indispensable partner in quality oversight, credentialing, accreditation, and operations. The medical staff elects officers to represent its physicians. Payment for medical staff officers varies by facility and position and can be a complex area to navigate. With healthcare organizations spending more and more on these types of roles, it is important to think strategically about this area of increasing concern.
In this webinar, we will talk about paying physicians in leadership positions reasonably and fairly. Join MD Ranger for this 30-minute webinar as we discuss:
-The (growing) diversity of physician leadership roles
-When to pay
-How much to pay
-Ways to structure payment
5 Mistakes Hospitals Make with Call Coverage AgreementsMD Ranger, Inc.
This deck covers 5 critical mistakes that hospitals make with call coverage agreements and how to avoid them going forward.
We will cover:
- Effective strategies for setting call rates
- Determining commercial reasonableness
- The most cost-effective ways to pay for call
- Which services are likely to be paid
- ...and more!
Key Findings from MD Ranger’s 2020 Facility Totals BenchmarksMD Ranger, Inc.
Learn how facility totals benchmarks could help your organization answer questions like:
• How many call coverage positions do other trauma centers pay?
• How much do hospitals of similar size pay for medical directorships?
• Are we paying more medical directors than other hospitals?
• ...And more!
Both Stark and AKS require that physician contracting rates be negotiated at fair market value. What the regulations don’t include is explicit, tactical advice for how to determine and document FMV. Physician contract compliance can be less of a headache if your organization takes a planned, methodical approach to obtaining and recording payment rates.
These slides will cover:
-What FMV means
-Various methods to determine FMV
-Strategies for efficient documentation
Practice Valuation & Physician Compensation Planning ConsiderationsPYA, P.C.
PYA Principal Carol Carden and PYA Senior Consultant Katie Culver presented “Practice Valuation and Compensation Planning Considerations" at the TSCPA Southeastern Forensic & Valuation Services Conference.
Defining, Determining, and Documenting FMV for Medical DirectorshipsMD Ranger, Inc.
Both Stark and AKS require that physician contracting rates be negotiated at fair market value. What the regulations don't include is explicit tactical advice for how to determine and document FMV for medical directorships.
Physician contract compliance can be less of a headache if your organization takes a planned, methodical approach to obtaining and recording payment rates.
If your facility could use best practices for determining and documenting FMV for medical directorship contracts, join us for our 30-minute webinar covering:
-What FMV means
-Various methods to determine FMV
-Strategies for efficient documentation
-And more!
What makes successful, compliant physician contracting programs tick? What best practices are progressive organizations using to implement and manage the contracting process? Join MD Ranger for a complimentary, 30-minute webinar to learn how to navigate your way through physician contracts, including:
--Key elements of physician contracting programs
--Best practices for managing physician contracting
--Tools for facilitating communication and enhancing team coordination
High-quality market data is a powerful tool for analyzing physician costs, negotiating competitive contracts, and documenting compliance of hospital-physician agreements. However, market data is not the all-in-one solution for every question or concern regarding physician contracting.
If your organization could use best practices for utilizing market data to evaluate physician contracts, view these slides which cover:
-Situations where market data excels
-When to consult an expert
-Understanding the limitations of market data
Key Strategies for Compensating Physician Administrative PositionsMD Ranger, Inc.
Establishing rates for medical directorships has hidden challenges and risks. Even the most sophisticated market data benchmarks should be thoroughly examined and utilized properly. In addition to analyzing market data correctly, there’s an art to establishing rates policies for your organization. This webinar addresses challenges to determining appropriate rates and shares successful organizational policies.
Using Market Data to Support Your Compliance ProgramMD Ranger, Inc.
Determining whether your physician contracts are compliant is no cakewalk. An inconsistent or poorly managed process for negotiating and benchmarking physician contracts can lead to conflicts and strain your
internal resources.
What You MUST Know About Compensating Physician Emergency CoverageMD Ranger, Inc.
The cost of emergency call coverage has become an increasingly large component of many hospital budgets. Knowing when, how, and how much to pay are crucial to controlling costs and documenting fair market value compliance. This webinar shows how much other hospitals pay for call coverage, the most cost effective ways to pay for call, and which services that are most likely to be compensated.
Uncovering Best Practices from Corporate Integrity AgreementsMD Ranger, Inc.
A CIA is a tool used by the OIG to address violations at healthcare organizations through policies and procedures designed to enforce compliance with regulations. A CIA is usually coupled with a civil settlement between the provider and the government to avoid exclusion from federal health programs.
In this presentation, we will discuss how to use recent CIAs to derive best practices that can benefit your organization.
We will cover:
-Common guidelines found in multiple CIAs
-Best practices from CIAs for specific types of healthcare entities
-Easy ways to improve your physician contracting compliance
-And more!
Perfecting Your Physician Contracting ProgramMD Ranger, Inc.
There are many ways to operationalize a physician contracting team. No program is “one size fits all”. However, many successful physician contracting programs do have a few key things in common.
We will cover:
-Fundamental elements of physician contracting programs
-Best practices to optimize your physician contracting program
-Tools that facilitate success
-And more!
In this presentation, we cover:
- Identifying stacking physician agreements
- Why stacking is risky
- Best practices to prevent stacking
- Case study examples
- ...And More!
Join us to learn:
---1. The key components of physician contracting programs
---2. Steps to take to avoid risky contracting situations
---3. Best practices for creating internal processes
Navigating Medical Staff Officer and Physician Leadership Compensation MD Ranger, Inc.
Every hospital has a medical staff that functions as an indispensable partner in quality oversight, credentialing, accreditation, and operations. The medical staff elects officers to represent its physicians. Payment for medical staff officers varies by facility and position and can be a complex area to navigate. With healthcare organizations spending more and more on these types of roles, it is important to think strategically about this area of increasing concern.
In this webinar, we will talk about paying physicians in leadership positions reasonably and fairly. Join MD Ranger for this 30-minute webinar as we discuss:
-The (growing) diversity of physician leadership roles
-When to pay
-How much to pay
-Ways to structure payment
5 Mistakes Hospitals Make with Call Coverage AgreementsMD Ranger, Inc.
This deck covers 5 critical mistakes that hospitals make with call coverage agreements and how to avoid them going forward.
We will cover:
- Effective strategies for setting call rates
- Determining commercial reasonableness
- The most cost-effective ways to pay for call
- Which services are likely to be paid
- ...and more!
Key Findings from MD Ranger’s 2020 Facility Totals BenchmarksMD Ranger, Inc.
Learn how facility totals benchmarks could help your organization answer questions like:
• How many call coverage positions do other trauma centers pay?
• How much do hospitals of similar size pay for medical directorships?
• Are we paying more medical directors than other hospitals?
• ...And more!
Both Stark and AKS require that physician contracting rates be negotiated at fair market value. What the regulations don’t include is explicit, tactical advice for how to determine and document FMV. Physician contract compliance can be less of a headache if your organization takes a planned, methodical approach to obtaining and recording payment rates.
These slides will cover:
-What FMV means
-Various methods to determine FMV
-Strategies for efficient documentation
Practice Valuation & Physician Compensation Planning ConsiderationsPYA, P.C.
PYA Principal Carol Carden and PYA Senior Consultant Katie Culver presented “Practice Valuation and Compensation Planning Considerations" at the TSCPA Southeastern Forensic & Valuation Services Conference.
Defining, Determining, and Documenting FMV for Medical DirectorshipsMD Ranger, Inc.
Both Stark and AKS require that physician contracting rates be negotiated at fair market value. What the regulations don't include is explicit tactical advice for how to determine and document FMV for medical directorships.
Physician contract compliance can be less of a headache if your organization takes a planned, methodical approach to obtaining and recording payment rates.
If your facility could use best practices for determining and documenting FMV for medical directorship contracts, join us for our 30-minute webinar covering:
-What FMV means
-Various methods to determine FMV
-Strategies for efficient documentation
-And more!
What makes successful, compliant physician contracting programs tick? What best practices are progressive organizations using to implement and manage the contracting process? Join MD Ranger for a complimentary, 30-minute webinar to learn how to navigate your way through physician contracts, including:
--Key elements of physician contracting programs
--Best practices for managing physician contracting
--Tools for facilitating communication and enhancing team coordination
High-quality market data is a powerful tool for analyzing physician costs, negotiating competitive contracts, and documenting compliance of hospital-physician agreements. However, market data is not the all-in-one solution for every question or concern regarding physician contracting.
If your organization could use best practices for utilizing market data to evaluate physician contracts, view these slides which cover:
-Situations where market data excels
-When to consult an expert
-Understanding the limitations of market data
Key Strategies for Compensating Physician Administrative PositionsMD Ranger, Inc.
Establishing rates for medical directorships has hidden challenges and risks. Even the most sophisticated market data benchmarks should be thoroughly examined and utilized properly. In addition to analyzing market data correctly, there’s an art to establishing rates policies for your organization. This webinar addresses challenges to determining appropriate rates and shares successful organizational policies.
Using Market Data to Support Your Compliance ProgramMD Ranger, Inc.
Determining whether your physician contracts are compliant is no cakewalk. An inconsistent or poorly managed process for negotiating and benchmarking physician contracts can lead to conflicts and strain your
internal resources.
What You MUST Know About Compensating Physician Emergency CoverageMD Ranger, Inc.
The cost of emergency call coverage has become an increasingly large component of many hospital budgets. Knowing when, how, and how much to pay are crucial to controlling costs and documenting fair market value compliance. This webinar shows how much other hospitals pay for call coverage, the most cost effective ways to pay for call, and which services that are most likely to be compensated.
Uncovering Best Practices from Corporate Integrity AgreementsMD Ranger, Inc.
A CIA is a tool used by the OIG to address violations at healthcare organizations through policies and procedures designed to enforce compliance with regulations. A CIA is usually coupled with a civil settlement between the provider and the government to avoid exclusion from federal health programs.
In this presentation, we will discuss how to use recent CIAs to derive best practices that can benefit your organization.
We will cover:
-Common guidelines found in multiple CIAs
-Best practices from CIAs for specific types of healthcare entities
-Easy ways to improve your physician contracting compliance
-And more!
Perfecting Your Physician Contracting ProgramMD Ranger, Inc.
There are many ways to operationalize a physician contracting team. No program is “one size fits all”. However, many successful physician contracting programs do have a few key things in common.
We will cover:
-Fundamental elements of physician contracting programs
-Best practices to optimize your physician contracting program
-Tools that facilitate success
-And more!
In this presentation, we cover:
- Identifying stacking physician agreements
- Why stacking is risky
- Best practices to prevent stacking
- Case study examples
- ...And More!
Join us to learn:
---1. The key components of physician contracting programs
---2. Steps to take to avoid risky contracting situations
---3. Best practices for creating internal processes
In this 30-minute webinar we discuss what to do when your physician contract falls outside of traditional FMV Range. Even though many providers adopt a single benchmark quantile as the standard for payments, there are times when a higher rate is justified.
This webinar covers:
- Evaluating if contracts warrant a higher payment rate
- Strategies for efficient documentation of physician contracts
- And more!
Hospital administrators know that the physician contracting process involves many steps in order to get it right and to maintain the best possible relationships with physicians. Wouldn't it be great to have a checklist to standardize the process?
This on-demand webinar covers the basics of Stark Law for those who need a refresher or are new to the compliance arena.
In this webinar we:
- Cover Stark Law basics
- Review penalties for non-compliance
- Discuss strategic and tactical best practices for your physician contracting program
Nervous about the handful of arrangements at your organization that compensate physicians outside traditional FMV ranges?
Even though many healthcare organizations adopt a single benchmark quantile as the standard for payments, there are times when a higher rate is justified. How do you determine what’s fair, and how do you standardize that process?
This deck covers what to do when physician agreements fall outside of traditional FMV Range and how you can protect yourself and your organization against compliance risks, including:
-Evaluating if contracts warrant a higher payment rate
-Crafting policies and procedures for these types of arrangements
-Strategies for efficient, compliant documentation
-And more!
7 Signs Your Organization Could Have Risky ContractsMD Ranger, Inc.
In this webinar, we will talk about how to spot potentially risky situations and contracts at your organization. Join Allison Pullins, Chief Marketing Officer at MD Ranger, Inc, for this 30-minute webinar as she discusses:
-Red flags pointing to a compliance problem
-Strategic physician contracting practices
-Safeguarding against legal and compliance risks
-...and more!
What You Need to Know from HCCA's 2019 Compliance InstituteMD Ranger, Inc.
In this presentation, we cover coming changes to Stark Law, turning your hospital's board of directors into compliance advocates, tracking time for medical directors and more!
Physician Contracting Best Practices for Health SystemsMD Ranger, Inc.
This webinar is geared towards health systems and those working with health systems who want to gain efficiencies within physician contracting and learn how to structure internal guidelines and processes.
During this webinar, you will:
--Learn to create successful strategies for organization-wide policies within health systems
--Explore characteristics of high-quality market data
--Review studies of MD Ranger subscribers
Looking Ahead to Physician Contracting in 2018MD Ranger, Inc.
As 2017 comes to a close, we want to take a step back and look at the actions the OIG and DOJ have taken over the year. These actions are usually a good indicator of what's to come in the next year. How will the focus of the OIG and DOJ impact your physician contracts and strategy in 2018?
10th Anniversary Webinar Series: The Definitive Guide to Medical DirectorshipsMD Ranger, Inc.
Join MD Ranger Chief Strategy Officer Allison Pullins as she summarizes and reviews the findings from The Definitive Guide to Medical Direction.
Learn more about medical direction, including:
- Key findings
- Significant trends in medical direction
- What factors impact payment rates
- ...And more!
Physician Contracting for Exceptional HospitalsMD Ranger, Inc.
Some hospitals have complexities that require careful consideration while determining a physician contracting compliance process. This video will help you identify potential solutions for academic medical centers, children's hospitals, trauma centers, and small hospitals.
Hospital-based contracts are often essential to secure coverage for physician services like anesthesiology, pathology, critical care, and more. These contract terms can be complex, and address elements like call coverage, medical direction, quality initiatives, and conditions of exclusivity. Hospital-based services are among the fastest-growing segments in hospital expenses.
Similar to Physician Contracting Compliance Risk Checklist (20)
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call CoverageMD Ranger, Inc.
MD Ranger Chief Strategy Officer Allison Pullins summarizes and reviews the findings from The Definitive Guide to Emergency Call Coverage.
Learn more about ED call coverage, including:
- Key findings
- Significant trends in ED call coverage
- What factors impact call rates
- ...And more!
Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...MD Ranger, Inc.
Have you structured your hospital-based physician contracts to address all aspects of compliance?
Hospitalist agreements involve unique compliance and financial issues, particularly when global payments and advanced practice providers are involved. Risks include indirect compensation, billing and other compliance issues. This presentation will discuss compliance risks and provide guidance on how to structure compliant contracts and business arrangements.
Physician Contracting at Small and Rural HospitalsMD Ranger, Inc.
In this webinar we discuss discuss the unique physician contracting and compliance considerations facing small and rural hospitals.
We will cover:
- Key considerations for physician contracting at small and rural hospitals
- Spending trends in compensation at these facilities
- Strategies for managing your contracting and compliance program
- And more!
Stop the Financial Bleed: Triaging the Cost of Hospital-Based Physician ServicesMD Ranger, Inc.
This special hour-long webinar from MD Ranger and HealthCare Appraisers advises on how to navigate hospital-based service arrangements at your organization.
Over the last several decades, the number of and cost associated with hospital-based service arrangements have been increasing. These agreements are generally more complex than medical directorships or on-call agreements, and contain unique risks that vary widely between facilities. A thorough understanding of these arrangements is essential to ensure both regulatory compliance and cost containment.
This webinar covers:
- Defining the key components of hospital-based service arrangements
- Reviewing fair market value and commercial reasonableness considerations
- Exploring the key pieces of information and data that drive understanding of these arrangements
- And more!
Key Findings from MD Ranger's 2018 Total Facility Benchmarks ReportMD Ranger, Inc.
Review key findings from our recently published 2018 Total Facility Benchmark Reports, as well as compare them to past years' reports to uncover trends in physician payments.
This presentation covers:
-How much hospitals spend on call coverage and medical directorships
-Facility-wide physician contracting trends
-How healthcare organizations use facility-wide benchmarks to drive better performance
-And more!
Physician Contracting Whack-A-Mole: Playing to WinMD Ranger, Inc.
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
Market data is an efficient way to build a physician contracting compliance program, and is used by hundreds of hospitals across the country. Among the perks of using market data are consistency, accessibility, and flexibility. As long as the database used to calculate payment benchmarks is both large and diverse, benchmarks typically remain stable from year to year. However, even in large databases, there are factors that could change benchmarks from year to year, such as significant increases in the sample size or changes in the market.
By understanding why benchmarks could change from year to year, you can prepare for these changes and address them effectively when they occur. If you are using market surveys or MD Ranger to set physician contract rates and want to learn best practices, this presentation covers:
-Why benchmarks shift
-Addressing changes
-Case studies and real-life examples
Spotting physician overpayments is usually straightforward. Whether it’s compensating above fair market value, or paying for too much or for too many hours in an administrative position, compliance risks are clear and can be easy to identify. However, in some cases, overpayments can be hidden—particularly when there is “stacking” of physician agreements that results in total payments to an individual or group exceeding reasonable levels.
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About this webinar: This talk will introduce what cancer rehabilitation is, where it fits into the cancer trajectory, and who can benefit from it. In addition, the current landscape of cancer rehabilitation in Canada will be discussed and the need for advocacy to increase access to this essential component of cancer care.
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The best massage spa Ajman is Chandrima Spa Ajman, which was founded in 2023 and is exclusively for men 24 hours a day. As of right now, our parent firm has been providing massage services to over 50,000+ clients in Ajman for the past 10 years. It has about 8+ branches. This demonstrates that Chandrima Spa Ajman is among the most reasonably priced spas in Ajman and the ideal place to unwind and rejuvenate. We provide a wide range of Spa massage treatments, including Indian, Pakistani, Kerala, Malayali, and body-to-body massages. Numerous massage techniques are available, including deep tissue, Swedish, Thai, Russian, and hot stone massages. Our massage therapists produce genuinely unique treatments that generate a revitalized sense of inner serenely by fusing modern techniques, the cleanest natural substances, and traditional holistic therapists.
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Physician Contracting Compliance Risk Checklist
1. 1
Measuring the Financial Health of Your
Physician Contracting Program
February 19, 2015
PHYSICIAN CONTRACTING COMPLIANCE
RISK CHECKLIST
ALLISON PULLINS, CMO, MD RANGER
2. Getting value from our discussion
• While listening to the webinar, think about how your
organization addresses(or fails to address) each of the
checkbox items
• After the webinar:
• Determine your top 2-3 areas of risk from our list
• Delegate responsibilities to your team
• Project plan for addressing areas of risk?
• Call MD Ranger!
2
5. 5
MD Ranger includes:
• Benchmarks, available as reports and online queries, with market data for
call, medical direction,administrative services,leadershippositions,
hospital-basedservices,uncompensatedcare,clinics and diagnostic testing
services
• A secure, web-based contract data tool to collect and organize contract
data (uploads via Excel available)
• FMV documentationtools
• Analytics to benchmarkinternal contracts and total expenditures,identify
compliance issues,compare facilities andanalyze expenditures
• Cost and compliance reports
• Resources and researchto support compliance efforts
• Customer support by experts in physiciancompensation,FMV
documentation,andcompliance
6. Your host
6
• Nine years experience in healthcare
consulting and technology; specializing
in physician marketing, recruitment,
engagement, compensation, negotiations
• Helps MD Ranger subscribers leverage
data, analyze internal costs and structure
physician contract compliance programs
9. Executive oversight
• An executive should be in charge of both contractualand
strategic decisions
• They should report to both the CEO and the Board
• Commonly this executive is the Chief Compliance Officer,
the GeneralCounsel, or the CFO
9
10. Contract management
• Organize your contractsby key elements like
• Expiration date
• Dollar value
• Service
• Have an alert system to spark negotiation reviewswell
before the expiration date
• Formalize renewalprocesses
• Manage contractson two levels: contractby contractAND
high-levelstrategic management
10
11. Financial oversight
• Non-employed physician costs average5% of a hospital’s
total operating budget
• Proactive managementof physician contractscan control
costs
• Make sure all agreementsare commercially reasonable
• What’syour definition of FMV? Is it financially feasible
for your organization?
• Benchmark your facility against peers
11
12. Compliance management
• Education
• Because compliance has so many moving parts, it is
important to be deliberate and specific with guidelines,
processes, and training
• FMV determination and documentation processes=key!
12
15. Stark Law
• Prohibits physician referralsof DHS if a physician or the
physician’sfamily membershave a financialrelationship
with the entity, unless an exception applies
• Limited to Medicare and Medicaid programs
• Civil penaltiesup to $15,000 per service; additional
penaltiesup to $100,000 for circumvention. Exclusion
from CMS also possible.
• Strict liability statute, so no intent needed to violate the law
• Physicians are at risk too; make sure to educate them as
well!
15
16. Anti-Kickback Statute
• A criminal statute that forbids the exchangeor offer to
exchange anything of value in an effortto entice or reward
the referralof federalhealth care servicesor business
• Penalties of $25,000 plus up to 5 years in prison per
violation
• Additional civil penaltiesof up to $50,000 per violation
and up to three times the amount of damagessustained by
the government
16
17. False Claims Act
• Imposes liability on people/organizationswho defraud
governmentprograms
• Payments to a hospital for servicesthat violate both Stark
and AKS could be subject to penaltiesbecause they
defraud the government
• Allows whistle-blowersto bring qui tam lawsuits and sue
on behalf of the federalgovernmentfor both Stark and
AKS violations
17
18. Educate your team
• Staff should know about regulationsand penalties
• Hold regular trainings and refreshersessions
• Make sure new employeesreceiving training during
onboarding
18
20. Every paid service must have an agreement
• Must have an agreement, but best practice to have a
contract
• Consider agreementsfor unpaid services, too
• Key elements:
• Signatures form both sides
• Defined duties
• Defined time requirements
• Dates of service
20
21. Are agreements being carried out
properly?
• Track hours
• Track duties
• Watch those expiration dates
21
23. Know the scope
• Small community hospitals tend to have 50-75 physician
contracts
• Large organizationscan have hundreds to thousands
• Best practice to conductbudgeting and financialplanning
• Knowing your contractswill help you uncover potentially
risky arrangements
23
24. Flag your high-risk agreements
• Key service lines
• Politically charged situations
• Typically large hospital-based agreements
• Track coverage arrangements
24
26. Hopefully in a centralized location
• Are your contractsstored in a centralized location?
• Obtain or create a contractmanagementsystem
• Garbage in, garbage out
• Create an automated processfor renegotiations,starting 3-
6 months before the renewaldate
26
27. Don’t know what you don’t know? Get on
it.
• It’s more common than you’d think for a hospital to not
manage contractsproperly
• Make sure you feel 100% confidentthat all contractsare
kept in one location and monitored by staff
27
29. What counts as exceptional?
• Your organization should have a policy defining FMV
standards
• Some organizationscompensateat or below median;others
consider anything below the 75th percentile as FMV
• Exceptionalagreementsmight be:
• Higher hourly rate
• More hours per year (e.g. start up costs
• Rock star physicians
• Undesirable panels
29
30. Create a process
• When you must pay a physician above FMV, create a
consistent review process
• Have a criteria for what counts as an exception
• What is the process for reviewing these exceptions?
• Who needs to sign off on exceptions?
30
31. May we suggest making it difficult?
• The more difficult your exceptionsapprovalprocessis, the
less likely it is that administratorswill pursue higher rates
• Don’t make it impossible, but make it onerous
• Over the course of a few years, you will probably see
lower costs!
31
33. Define FMV
• What is the criteria for FMV and commercial
reasonablenessat your organization?
• What’syour processto determine commercial
reasonableness?
• What tools will you use to establish FMV? Marketdata?
Valuations?
33
34. Document FMV
• How will you consistently document rates?
• What other documents, besides proof of FMV, should you
require?
• How will you track compliance?
• Will you performannual audits?
34
36. Day to day management
• You should designate a point person to handle physician
contracting, even if not full time
• Give this person the tools they need
• Designate an executive the point person directly reports to
for physician contracting
36
37. Tone comes from the top
• Essential to have an executive who is knowledgeable and
responsible for physician contracting
• She should contribute to the compliance programcreation
and be familiar with the day-to-day
• Responsible in the unfortunate eventof an audit
37
39. Auditing
• An annual internalaudit can identify potential patternsof
non-complianceor outliers that have not been properly
documented
• Auditing happenson a regular basis and looks
retrospectively acrossthe organization
39
40. Monitoring
• Monitoring contractsthroughout the year to ensure they
are being paid and performed according to what was
agreed upon
• Monitoring is real-time managementof physician contracts
• Elements should include looping in AP, tracking physician
time
40
42. They provide a look inside the OIG’s
process
• Learn from organizationswho made mistakes
• CIAs can be long, but provide step-by-step requirementsto
be in compliance in their eyes
42
43. 43
ü KNOW THE REGULATIONS
ü HAVE WRITTEN AGREEMENTS
ü KNOW YOUR ORGANIZATION’SCONTRACTS
ü KEEP THEM WELL-ORGANIZED
ü DETERMINE HOW TO HANDLE EXCEPTIONS
ü DEFINE WHAT FMV MEANS
ü DETERMINE HOW FMV WILL BE DOCUMENTED
ü PICK LEADERS AND STAFF INVOLVED
ü AUDIT AND MONITOR YOUR AGREEMENTS
ü REVIEW CIA’S FOR BEST PRACTICES
44. Could we help?
44
Could your organization use tools to help manage
financial oversight of physician contracting?
MD Ranger helps hospitals better understand
physician expenditures and become more strategic
with contracting decisions.
Reach out to us: we can help.
apullins@mdranger.com or 650-692-8873