SlideShare a Scribd company logo
1 of 28
Download to read offline
1
Mitigating Stacking Risks
An MD Ranger on-demand video
Our agenda
• About MD Ranger
• What is “stacking” and why is it risky?
• Best practices for preventing stacking
• Case studies
2
275+ Physician Benchmarks
• Call coverage rates
• Medical direction payments
• Administrative and leadership services
rates
• Hospital-based service stipends
• Diagnostic testing, etc.
• Clinic & hourly rates
Online Platform
• Benchmark lookups
• Contract proposal tools
• Contract reports by facility and service
• Total facility costs + benchmarks
Compliance Documentation
• Contract-specific FMV documentation
reports
• Reports to assist with real-time
monitoring and annual reviews
Research and Support
• Resources for education and training
• On-call experts to help subscribers
use benchmarks and tools
3
The foundation of your contracting process
Standardize
processes
and rates
Document
FMV
Access 275+
payment
benchmarks
Review
contracts and
monitor with
ease
Have smarter,
data-driven
physician
negotiations
Mitigate
compliance
risks
4
5
275+ Benchmarks include:
• Call Coverage (52)
• Medical direction (91)
• Hospital-based services (19)
• Administrative and Medical Staff
Leadership (22)
• Diagnostic/other services e.g.
ROP, autopsy, dialysis
• Hospital-based stipends
• Clinics, professional services
• Telemedicine
• Residency/teaching/GME
• Uncompensated care
• Meeting attendance, peer review,
IT/EHR and quality initiatives
• Pediatric-specific services (13)
• Total hospital spending
• Percent paying
• Number of administrative
positions
Hospital-characteristics drill down
for ADC, bed size, trauma status,
urban/rural, stroke centers, and
more
6
Our database
7
STACKING: WHAT’S THE BIG DEAL?
Overpayments to physicians not always
obvious…
8
• Overpayments in physician agreements can be and are often
easy to spot, such as paying higher than FMV or paying for too
many hours in administrative agreements
• Sometimes reasonable-looking payments that are spread out
across agreements or within one agreement are not reasonable
when looked at in aggregate
OIG Advisory Opinion 07-10
9
In this opinion, the OIG calls problematic compensation
structures:
• “payment for lost opportunity cost that do not reflect bona fide
lost income”
• ”aggregate on-call payments that are disproportionately high
when compared to the physician’s regular practice income”
• “payment…resulting in the physician essentially being paid
twice for the same service”
How stacking happens
10
• A physician or physician group has two or
more agreements with a hospital for
coverage or administrative/medical
direction services
• While agreement may be compliant when
considered independently, when taken
together, payment may be greater than
the 90th percentile or the time
commitment, particularly in the context of
the physician’s clinical practice, requires
more hours per year than full-time
Another likely scenario
An ED call payment rate
is based on “opportunity
cost” of lost private
practice income, but the
physician or group
doesn’t actually suffer
losses
11
12
BEST PRACTICES TO AVOID
STACKING
1) Develop policies and review
procedures
13
Policy should be targeted towards
physicians who hold more than one
position or who perform more than
one service.
If physicians are holding two call
positions at the same time, set
guidelines around how much they
can be paid. If they are effectively an
employed physician, set an
aggregate payment cap from all
sources.
2) Track administrative time carefully
14
Time tracking should be standard
for all physician administrative
positions.
As much you can, automate time
tracking and coordinate effectively
between all parties: physicians,
finance, and administration.
3) Beware of multiple ED call payments
15
Don’t pay a physician to take call for
two services at the same time.
Common service combinations
where stacking most frequently
occurs:
• Orthopedic surgery and hand
surgery
• Plastic surgery and hand surgery
• Non-invasive and invasive
cardiology
• Stroke and non-stroke neurology
• Trauma and general surgery
4) Review and monitor restricted call
payments
16
Ask physicians to certify that
his or her private practice
cannot be rearranged to
avoid lost income.
Another way is to monitor
physicians’ OR utilization to
compare elective volume with
and without on-call coverage.
17
CASE STUDIES
Case study: hospitalist, administrator,
consultant
18
• Dr. Sally Smith is a hospitalist at a
300-bed community hospital,
covering shifts and serving as
medical director of the hospitalist
panel
• Serves as the Vice Chief of Staff
• Has consulting arrangement with
the hospital to assist with EHR
transition
• Rates for each position falls with
the fair market value for that
position
Case study: hospitalist, administrator,
consultant
19
• Dr. Smith is being paid more
than the 90th percentile of
the annual income for a full-
time hospitalist.
• So…if a hospital pays a
physician to be a full-time
hospitalist, and also pays
that individual for three
additional jobs, can the
physician be effective?
Case study: hospitalist, administrator,
consultant
20
• There is a possibility that Dr. Smith could—in an
admirable effort to be efficient and get the heavy workload
done— perform additional administrative duties while she
is on-duty and paid as a hospitalist.
Key takeaway: Dr. Smith’s total compensation must fall
within FMV for the positions she fulfills, and justification
for excess payment must be documented to
demonstrate non-duplicative payments and duties.
Case study: ED call payments
21
• Dr. George Perez is one of the few ENT physicians on the
medical staff who is trained and willing to handle major facial
injuries.
• He staffs two separate panels: ENT and facial injuries.
• Both panels are paid at the 75th percentile of respective fair
market value ranges; he takes simultaneous call for both
specialties.
• These arrangements contradicts the principals in the OIG
advisory opinions and OIG guidelines
Case study: ED call payments
22
• Some organizations pay
physicians in a similar situation
at the high end of the market
range for the best paid position.
• Other organizations will choose
to pay at the median for one
position and at or under the
25th percentile for the second
service.
• Be aware of paying for two jobs
at the same time. Carefully
justify and document whatever
payment is made.
Case study: restricted coverage and
opportunity cost risks
23
• Neurosurgery is particularly
vulnerable to hidden
compliance risks
• Frequently restricted
coverage; private practice
revenue comes from a
relatively small number of
surgical cases
Case study: restricted coverage and
opportunity cost risks
24
• The standard for Levels I and II trauma centers is that
neurosurgeons must be immediately available and
cannot conduct private practice (“restricted call”).
• Compensation benchmarks for trauma center
neurosurgery assume physicians suffer lost private
practice income
Case study: restricted coverage and
opportunity cost risks
25
However, the physician may
not suffer any opportunity
cost.; aggregate
compensation could be
significantly beyond the 90th
percentile of benchmark
annual neurosurgery
compensation.
Case study: employment plus
26
• Dr. Grace Williams is a cardiologist that
works with a medical group that has a
PSA with the local hospital
• The group has negotiated a co-
management agreement and additional
medical directorship payments, including
ad hoc payments for meeting
attendance and peer review participation
• Though her per diem call coverage
payment is the 25th percentile, she and
her colleagues are paid call stipends
Case study: employment plus
27
• Additional payments for services on top of employment
arrangements could result in payments to doctors well
above fair market value
Have more questions about stacking?
Reach out: info@mdranger.com
MD Ranger, Inc. | 1601 Old Bayshore Hwy, Ste. 107 | Burlingame, CA 94010
www.mdranger.com
28

More Related Content

What's hot

Healthcare Reform and Physician Compensation— Presentation Examines What’s in...
Healthcare Reform and Physician Compensation— Presentation Examines What’s in...Healthcare Reform and Physician Compensation— Presentation Examines What’s in...
Healthcare Reform and Physician Compensation— Presentation Examines What’s in...PYA, P.C.
 
Beware of Benchmarks: Use of Survey Data in Determining FMV
Beware of Benchmarks: Use of Survey Data in Determining FMVBeware of Benchmarks: Use of Survey Data in Determining FMV
Beware of Benchmarks: Use of Survey Data in Determining FMVPYA, P.C.
 
Edifecs CJR: don't fumble with your bundle ss
Edifecs CJR: don't fumble with your bundle ssEdifecs CJR: don't fumble with your bundle ss
Edifecs CJR: don't fumble with your bundle ssEdifecs Inc
 
Practice Valuation & Physician Compensation Planning Considerations
Practice Valuation & Physician Compensation Planning ConsiderationsPractice Valuation & Physician Compensation Planning Considerations
Practice Valuation & Physician Compensation Planning ConsiderationsPYA, P.C.
 
Healthcare Risk management overview
Healthcare Risk management overviewHealthcare Risk management overview
Healthcare Risk management overviewAhmad Thanin
 
Webinar Examines Benchmarking Medical Practice Performance
Webinar Examines Benchmarking Medical Practice PerformanceWebinar Examines Benchmarking Medical Practice Performance
Webinar Examines Benchmarking Medical Practice PerformancePYA, P.C.
 
Efr ch3 managedcare_sr2.4
Efr ch3 managedcare_sr2.4Efr ch3 managedcare_sr2.4
Efr ch3 managedcare_sr2.4stanbridge
 
Research Symposium Presentation NwaukaO Final
Research Symposium Presentation NwaukaO FinalResearch Symposium Presentation NwaukaO Final
Research Symposium Presentation NwaukaO FinalOliver Nwauka
 
PSCI Case Study - Population Predictive Risk Analytics from PSCI
PSCI Case Study - Population Predictive Risk Analytics from PSCIPSCI Case Study - Population Predictive Risk Analytics from PSCI
PSCI Case Study - Population Predictive Risk Analytics from PSCIpscisolutions
 
Key Strategies for Compensating Physician Administrative Positions
Key Strategies for Compensating Physician Administrative PositionsKey Strategies for Compensating Physician Administrative Positions
Key Strategies for Compensating Physician Administrative PositionsMD Ranger, Inc.
 
Risk Management Process for Healthcare Organizations
Risk Management Process for Healthcare OrganizationsRisk Management Process for Healthcare Organizations
Risk Management Process for Healthcare OrganizationsCalance
 
Research Report - Insights into Revenue Cycle Management
Research Report - Insights into Revenue Cycle ManagementResearch Report - Insights into Revenue Cycle Management
Research Report - Insights into Revenue Cycle ManagementBESLER
 
Solving preventable-readmissions-white paper
Solving preventable-readmissions-white paperSolving preventable-readmissions-white paper
Solving preventable-readmissions-white paperNathan Brown
 
Clinical Governance[1]
Clinical Governance[1]Clinical Governance[1]
Clinical Governance[1]Simon Lalonde
 
Leading the Journey: Cultivating Success in Healthcare
Leading the Journey: Cultivating Success in HealthcareLeading the Journey: Cultivating Success in Healthcare
Leading the Journey: Cultivating Success in HealthcareHuron Consulting Group
 
Effective risk management in healthcare practice-
Effective risk management in healthcare practice-Effective risk management in healthcare practice-
Effective risk management in healthcare practice-Dr. AbdulQawi Almohamadi
 
CU Errors, clinical governance and patient safety
CU Errors, clinical governance and patient safetyCU Errors, clinical governance and patient safety
CU Errors, clinical governance and patient safetyMedic-ELearning
 

What's hot (20)

Healthcare Reform and Physician Compensation— Presentation Examines What’s in...
Healthcare Reform and Physician Compensation— Presentation Examines What’s in...Healthcare Reform and Physician Compensation— Presentation Examines What’s in...
Healthcare Reform and Physician Compensation— Presentation Examines What’s in...
 
Beware of Benchmarks: Use of Survey Data in Determining FMV
Beware of Benchmarks: Use of Survey Data in Determining FMVBeware of Benchmarks: Use of Survey Data in Determining FMV
Beware of Benchmarks: Use of Survey Data in Determining FMV
 
Operations
OperationsOperations
Operations
 
Risk management
Risk managementRisk management
Risk management
 
Edifecs CJR: don't fumble with your bundle ss
Edifecs CJR: don't fumble with your bundle ssEdifecs CJR: don't fumble with your bundle ss
Edifecs CJR: don't fumble with your bundle ss
 
Practice Valuation & Physician Compensation Planning Considerations
Practice Valuation & Physician Compensation Planning ConsiderationsPractice Valuation & Physician Compensation Planning Considerations
Practice Valuation & Physician Compensation Planning Considerations
 
Healthcare Risk management overview
Healthcare Risk management overviewHealthcare Risk management overview
Healthcare Risk management overview
 
Webinar Examines Benchmarking Medical Practice Performance
Webinar Examines Benchmarking Medical Practice PerformanceWebinar Examines Benchmarking Medical Practice Performance
Webinar Examines Benchmarking Medical Practice Performance
 
Efr ch3 managedcare_sr2.4
Efr ch3 managedcare_sr2.4Efr ch3 managedcare_sr2.4
Efr ch3 managedcare_sr2.4
 
Valuation of Healthcare Facilities (Nov. 17, 2015)
Valuation of Healthcare Facilities (Nov. 17, 2015)Valuation of Healthcare Facilities (Nov. 17, 2015)
Valuation of Healthcare Facilities (Nov. 17, 2015)
 
Research Symposium Presentation NwaukaO Final
Research Symposium Presentation NwaukaO FinalResearch Symposium Presentation NwaukaO Final
Research Symposium Presentation NwaukaO Final
 
PSCI Case Study - Population Predictive Risk Analytics from PSCI
PSCI Case Study - Population Predictive Risk Analytics from PSCIPSCI Case Study - Population Predictive Risk Analytics from PSCI
PSCI Case Study - Population Predictive Risk Analytics from PSCI
 
Key Strategies for Compensating Physician Administrative Positions
Key Strategies for Compensating Physician Administrative PositionsKey Strategies for Compensating Physician Administrative Positions
Key Strategies for Compensating Physician Administrative Positions
 
Risk Management Process for Healthcare Organizations
Risk Management Process for Healthcare OrganizationsRisk Management Process for Healthcare Organizations
Risk Management Process for Healthcare Organizations
 
Research Report - Insights into Revenue Cycle Management
Research Report - Insights into Revenue Cycle ManagementResearch Report - Insights into Revenue Cycle Management
Research Report - Insights into Revenue Cycle Management
 
Solving preventable-readmissions-white paper
Solving preventable-readmissions-white paperSolving preventable-readmissions-white paper
Solving preventable-readmissions-white paper
 
Clinical Governance[1]
Clinical Governance[1]Clinical Governance[1]
Clinical Governance[1]
 
Leading the Journey: Cultivating Success in Healthcare
Leading the Journey: Cultivating Success in HealthcareLeading the Journey: Cultivating Success in Healthcare
Leading the Journey: Cultivating Success in Healthcare
 
Effective risk management in healthcare practice-
Effective risk management in healthcare practice-Effective risk management in healthcare practice-
Effective risk management in healthcare practice-
 
CU Errors, clinical governance and patient safety
CU Errors, clinical governance and patient safetyCU Errors, clinical governance and patient safety
CU Errors, clinical governance and patient safety
 

Similar to Mitigating Stacking Risks

Physician Contracting at Small and Rural Hospitals
Physician Contracting at Small and Rural HospitalsPhysician Contracting at Small and Rural Hospitals
Physician Contracting at Small and Rural HospitalsMD Ranger, Inc.
 
5 Mistakes Hospitals Make with Call Coverage Agreements
5 Mistakes Hospitals Make with Call Coverage Agreements5 Mistakes Hospitals Make with Call Coverage Agreements
5 Mistakes Hospitals Make with Call Coverage AgreementsMD Ranger, Inc.
 
Defining, Determining, and Documenting FMV
Defining, Determining, and Documenting FMV Defining, Determining, and Documenting FMV
Defining, Determining, and Documenting FMV MD Ranger, Inc.
 
Best Practices for Physician Call Coverage Compensation
Best Practices for Physician Call Coverage CompensationBest Practices for Physician Call Coverage Compensation
Best Practices for Physician Call Coverage CompensationMD Ranger, Inc.
 
Physician Contracting for Exceptional Hospitals
Physician Contracting for Exceptional HospitalsPhysician Contracting for Exceptional Hospitals
Physician Contracting for Exceptional HospitalsMD Ranger, Inc.
 
Navigating Hospital-Based Contracts
Navigating Hospital-Based ContractsNavigating Hospital-Based Contracts
Navigating Hospital-Based ContractsMD Ranger, Inc.
 
Physician Contracting Best Practices for Health Systems
Physician Contracting Best Practices for Health SystemsPhysician Contracting Best Practices for Health Systems
Physician Contracting Best Practices for Health SystemsMD Ranger, Inc.
 
10th Anniversary Webinar Series: The Definitive Guide to Medical Directorships
10th Anniversary Webinar Series: The Definitive Guide to Medical Directorships10th Anniversary Webinar Series: The Definitive Guide to Medical Directorships
10th Anniversary Webinar Series: The Definitive Guide to Medical DirectorshipsMD Ranger, Inc.
 
Compliance Pitfalls of Hospital-Based Contracts
Compliance Pitfalls of Hospital-Based ContractsCompliance Pitfalls of Hospital-Based Contracts
Compliance Pitfalls of Hospital-Based ContractsMD Ranger, Inc.
 
Multi-Facility Physician Contracts: Tips for Health Systems
Multi-Facility Physician Contracts: Tips for Health SystemsMulti-Facility Physician Contracts: Tips for Health Systems
Multi-Facility Physician Contracts: Tips for Health SystemsMD Ranger, Inc.
 
Key Findings from Facility Totals Reports 2017
Key Findings from Facility Totals Reports 2017Key Findings from Facility Totals Reports 2017
Key Findings from Facility Totals Reports 2017MD Ranger, Inc.
 
Key Findings from MD Ranger's 2017 Facility Totals Benchmarks
Key Findings from MD Ranger's 2017 Facility Totals BenchmarksKey Findings from MD Ranger's 2017 Facility Totals Benchmarks
Key Findings from MD Ranger's 2017 Facility Totals BenchmarksMD Ranger, Inc.
 
Key Findings from MD Ranger's 2018 Total Facility Benchmarks Report
Key Findings from MD Ranger's 2018 Total Facility Benchmarks ReportKey Findings from MD Ranger's 2018 Total Facility Benchmarks Report
Key Findings from MD Ranger's 2018 Total Facility Benchmarks ReportMD Ranger, Inc.
 
Developing Employment Agreement for Quality, Operational Efficiency and Patie...
Developing Employment Agreement for Quality, Operational Efficiency and Patie...Developing Employment Agreement for Quality, Operational Efficiency and Patie...
Developing Employment Agreement for Quality, Operational Efficiency and Patie...Curtis Bernstein
 
Documenting FMV with MD Ranger
Documenting FMV with MD RangerDocumenting FMV with MD Ranger
Documenting FMV with MD RangerMD Ranger, Inc.
 
Three Keys to a Successful Margin: Charges, Costs, and Labor
Three Keys to a Successful Margin: Charges, Costs, and LaborThree Keys to a Successful Margin: Charges, Costs, and Labor
Three Keys to a Successful Margin: Charges, Costs, and LaborHealth Catalyst
 
Everything You Must Know About Physician Emergency Call Coverage
Everything You Must Know About Physician Emergency Call CoverageEverything You Must Know About Physician Emergency Call Coverage
Everything You Must Know About Physician Emergency Call CoverageMD Ranger, Inc.
 
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call CoverageMD Ranger, Inc.
 
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call CoverageErik Bartlett
 
9 Compliance Tips to Start the Year Right
9 Compliance Tips to Start the Year Right9 Compliance Tips to Start the Year Right
9 Compliance Tips to Start the Year RightMD Ranger, Inc.
 

Similar to Mitigating Stacking Risks (20)

Physician Contracting at Small and Rural Hospitals
Physician Contracting at Small and Rural HospitalsPhysician Contracting at Small and Rural Hospitals
Physician Contracting at Small and Rural Hospitals
 
5 Mistakes Hospitals Make with Call Coverage Agreements
5 Mistakes Hospitals Make with Call Coverage Agreements5 Mistakes Hospitals Make with Call Coverage Agreements
5 Mistakes Hospitals Make with Call Coverage Agreements
 
Defining, Determining, and Documenting FMV
Defining, Determining, and Documenting FMV Defining, Determining, and Documenting FMV
Defining, Determining, and Documenting FMV
 
Best Practices for Physician Call Coverage Compensation
Best Practices for Physician Call Coverage CompensationBest Practices for Physician Call Coverage Compensation
Best Practices for Physician Call Coverage Compensation
 
Physician Contracting for Exceptional Hospitals
Physician Contracting for Exceptional HospitalsPhysician Contracting for Exceptional Hospitals
Physician Contracting for Exceptional Hospitals
 
Navigating Hospital-Based Contracts
Navigating Hospital-Based ContractsNavigating Hospital-Based Contracts
Navigating Hospital-Based Contracts
 
Physician Contracting Best Practices for Health Systems
Physician Contracting Best Practices for Health SystemsPhysician Contracting Best Practices for Health Systems
Physician Contracting Best Practices for Health Systems
 
10th Anniversary Webinar Series: The Definitive Guide to Medical Directorships
10th Anniversary Webinar Series: The Definitive Guide to Medical Directorships10th Anniversary Webinar Series: The Definitive Guide to Medical Directorships
10th Anniversary Webinar Series: The Definitive Guide to Medical Directorships
 
Compliance Pitfalls of Hospital-Based Contracts
Compliance Pitfalls of Hospital-Based ContractsCompliance Pitfalls of Hospital-Based Contracts
Compliance Pitfalls of Hospital-Based Contracts
 
Multi-Facility Physician Contracts: Tips for Health Systems
Multi-Facility Physician Contracts: Tips for Health SystemsMulti-Facility Physician Contracts: Tips for Health Systems
Multi-Facility Physician Contracts: Tips for Health Systems
 
Key Findings from Facility Totals Reports 2017
Key Findings from Facility Totals Reports 2017Key Findings from Facility Totals Reports 2017
Key Findings from Facility Totals Reports 2017
 
Key Findings from MD Ranger's 2017 Facility Totals Benchmarks
Key Findings from MD Ranger's 2017 Facility Totals BenchmarksKey Findings from MD Ranger's 2017 Facility Totals Benchmarks
Key Findings from MD Ranger's 2017 Facility Totals Benchmarks
 
Key Findings from MD Ranger's 2018 Total Facility Benchmarks Report
Key Findings from MD Ranger's 2018 Total Facility Benchmarks ReportKey Findings from MD Ranger's 2018 Total Facility Benchmarks Report
Key Findings from MD Ranger's 2018 Total Facility Benchmarks Report
 
Developing Employment Agreement for Quality, Operational Efficiency and Patie...
Developing Employment Agreement for Quality, Operational Efficiency and Patie...Developing Employment Agreement for Quality, Operational Efficiency and Patie...
Developing Employment Agreement for Quality, Operational Efficiency and Patie...
 
Documenting FMV with MD Ranger
Documenting FMV with MD RangerDocumenting FMV with MD Ranger
Documenting FMV with MD Ranger
 
Three Keys to a Successful Margin: Charges, Costs, and Labor
Three Keys to a Successful Margin: Charges, Costs, and LaborThree Keys to a Successful Margin: Charges, Costs, and Labor
Three Keys to a Successful Margin: Charges, Costs, and Labor
 
Everything You Must Know About Physician Emergency Call Coverage
Everything You Must Know About Physician Emergency Call CoverageEverything You Must Know About Physician Emergency Call Coverage
Everything You Must Know About Physician Emergency Call Coverage
 
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
 
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
10th Anniversary Webinar Series: The Definitive Guide to Emergency Call Coverage
 
9 Compliance Tips to Start the Year Right
9 Compliance Tips to Start the Year Right9 Compliance Tips to Start the Year Right
9 Compliance Tips to Start the Year Right
 

More from MD Ranger, Inc.

Key Findings from MD Ranger’s 2020 Facility Totals Benchmarks
Key Findings from MD Ranger’s 2020 Facility Totals BenchmarksKey Findings from MD Ranger’s 2020 Facility Totals Benchmarks
Key Findings from MD Ranger’s 2020 Facility Totals BenchmarksMD Ranger, Inc.
 
Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...
Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...
Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...MD Ranger, Inc.
 
Audit Physician Contracts the Smart Way
Audit Physician Contracts the Smart WayAudit Physician Contracts the Smart Way
Audit Physician Contracts the Smart WayMD Ranger, Inc.
 
Outside of FMV Range? Now What?
Outside of FMV Range? Now What?Outside of FMV Range? Now What?
Outside of FMV Range? Now What?MD Ranger, Inc.
 
What You Need to Know from HCCA's 2019 Compliance Institute
What You Need to Know from HCCA's 2019 Compliance InstituteWhat You Need to Know from HCCA's 2019 Compliance Institute
What You Need to Know from HCCA's 2019 Compliance InstituteMD Ranger, Inc.
 
Perfecting Your Physician Contracting Program
Perfecting Your Physician Contracting ProgramPerfecting Your Physician Contracting Program
Perfecting Your Physician Contracting ProgramMD Ranger, Inc.
 
Uncovering Best Practices from Corporate Integrity Agreements
Uncovering Best Practices from Corporate Integrity AgreementsUncovering Best Practices from Corporate Integrity Agreements
Uncovering Best Practices from Corporate Integrity AgreementsMD Ranger, Inc.
 
Stop the Financial Bleed: Triaging the Cost of Hospital-Based Physician Services
Stop the Financial Bleed: Triaging the Cost of Hospital-Based Physician ServicesStop the Financial Bleed: Triaging the Cost of Hospital-Based Physician Services
Stop the Financial Bleed: Triaging the Cost of Hospital-Based Physician ServicesMD Ranger, Inc.
 
What to Do When You're Out of FMV Range
What to Do When You're Out of FMV RangeWhat to Do When You're Out of FMV Range
What to Do When You're Out of FMV RangeMD Ranger, Inc.
 
Auditing Physician Contracts with MD Ranger
Auditing Physician Contracts with MD RangerAuditing Physician Contracts with MD Ranger
Auditing Physician Contracts with MD RangerMD Ranger, Inc.
 
Facilitating Internal Physician Contracting Conversations
Facilitating Internal Physician Contracting ConversationsFacilitating Internal Physician Contracting Conversations
Facilitating Internal Physician Contracting ConversationsMD Ranger, Inc.
 
Key Findings from Facility Totals Reports 2017
Key Findings from Facility Totals Reports 2017Key Findings from Facility Totals Reports 2017
Key Findings from Facility Totals Reports 2017MD Ranger, Inc.
 
Defining, Determining, and Documenting FMV for Medical Directorships
Defining, Determining, and Documenting FMV for Medical DirectorshipsDefining, Determining, and Documenting FMV for Medical Directorships
Defining, Determining, and Documenting FMV for Medical DirectorshipsMD Ranger, Inc.
 
Physician Contracting Whack-A-Mole: Playing to Win
Physician Contracting Whack-A-Mole: Playing to WinPhysician Contracting Whack-A-Mole: Playing to Win
Physician Contracting Whack-A-Mole: Playing to WinMD Ranger, Inc.
 
Addressing Changes in Benchmarks
Addressing Changes in BenchmarksAddressing Changes in Benchmarks
Addressing Changes in BenchmarksMD Ranger, Inc.
 
Limitations of Market Data
Limitations of Market DataLimitations of Market Data
Limitations of Market DataMD Ranger, Inc.
 
Defining, Determining, and Documenting FMV
Defining, Determining, and Documenting FMVDefining, Determining, and Documenting FMV
Defining, Determining, and Documenting FMVMD Ranger, Inc.
 
Mitigating Physician Contracting Risk
Mitigating Physician Contracting RiskMitigating Physician Contracting Risk
Mitigating Physician Contracting RiskMD Ranger, Inc.
 
Looking Ahead to Physician Contracting in 2018
Looking Ahead to Physician Contracting in 2018Looking Ahead to Physician Contracting in 2018
Looking Ahead to Physician Contracting in 2018MD Ranger, Inc.
 

More from MD Ranger, Inc. (20)

Key Findings from MD Ranger’s 2020 Facility Totals Benchmarks
Key Findings from MD Ranger’s 2020 Facility Totals BenchmarksKey Findings from MD Ranger’s 2020 Facility Totals Benchmarks
Key Findings from MD Ranger’s 2020 Facility Totals Benchmarks
 
Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...
Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...
Compliance and Legal Risks in Laborist, Surgicalist, and Hospitalist Arrangem...
 
Audit Physician Contracts the Smart Way
Audit Physician Contracts the Smart WayAudit Physician Contracts the Smart Way
Audit Physician Contracts the Smart Way
 
Outside of FMV Range? Now What?
Outside of FMV Range? Now What?Outside of FMV Range? Now What?
Outside of FMV Range? Now What?
 
What You Need to Know from HCCA's 2019 Compliance Institute
What You Need to Know from HCCA's 2019 Compliance InstituteWhat You Need to Know from HCCA's 2019 Compliance Institute
What You Need to Know from HCCA's 2019 Compliance Institute
 
Perfecting Your Physician Contracting Program
Perfecting Your Physician Contracting ProgramPerfecting Your Physician Contracting Program
Perfecting Your Physician Contracting Program
 
Uncovering Best Practices from Corporate Integrity Agreements
Uncovering Best Practices from Corporate Integrity AgreementsUncovering Best Practices from Corporate Integrity Agreements
Uncovering Best Practices from Corporate Integrity Agreements
 
Stark Law Basics
Stark Law BasicsStark Law Basics
Stark Law Basics
 
Stop the Financial Bleed: Triaging the Cost of Hospital-Based Physician Services
Stop the Financial Bleed: Triaging the Cost of Hospital-Based Physician ServicesStop the Financial Bleed: Triaging the Cost of Hospital-Based Physician Services
Stop the Financial Bleed: Triaging the Cost of Hospital-Based Physician Services
 
What to Do When You're Out of FMV Range
What to Do When You're Out of FMV RangeWhat to Do When You're Out of FMV Range
What to Do When You're Out of FMV Range
 
Auditing Physician Contracts with MD Ranger
Auditing Physician Contracts with MD RangerAuditing Physician Contracts with MD Ranger
Auditing Physician Contracts with MD Ranger
 
Facilitating Internal Physician Contracting Conversations
Facilitating Internal Physician Contracting ConversationsFacilitating Internal Physician Contracting Conversations
Facilitating Internal Physician Contracting Conversations
 
Key Findings from Facility Totals Reports 2017
Key Findings from Facility Totals Reports 2017Key Findings from Facility Totals Reports 2017
Key Findings from Facility Totals Reports 2017
 
Defining, Determining, and Documenting FMV for Medical Directorships
Defining, Determining, and Documenting FMV for Medical DirectorshipsDefining, Determining, and Documenting FMV for Medical Directorships
Defining, Determining, and Documenting FMV for Medical Directorships
 
Physician Contracting Whack-A-Mole: Playing to Win
Physician Contracting Whack-A-Mole: Playing to WinPhysician Contracting Whack-A-Mole: Playing to Win
Physician Contracting Whack-A-Mole: Playing to Win
 
Addressing Changes in Benchmarks
Addressing Changes in BenchmarksAddressing Changes in Benchmarks
Addressing Changes in Benchmarks
 
Limitations of Market Data
Limitations of Market DataLimitations of Market Data
Limitations of Market Data
 
Defining, Determining, and Documenting FMV
Defining, Determining, and Documenting FMVDefining, Determining, and Documenting FMV
Defining, Determining, and Documenting FMV
 
Mitigating Physician Contracting Risk
Mitigating Physician Contracting RiskMitigating Physician Contracting Risk
Mitigating Physician Contracting Risk
 
Looking Ahead to Physician Contracting in 2018
Looking Ahead to Physician Contracting in 2018Looking Ahead to Physician Contracting in 2018
Looking Ahead to Physician Contracting in 2018
 

Recently uploaded

FINAL PROJECT IN EMPOWERMENT TECHNOLOGIES 11
FINAL PROJECT IN EMPOWERMENT TECHNOLOGIES  11FINAL PROJECT IN EMPOWERMENT TECHNOLOGIES  11
FINAL PROJECT IN EMPOWERMENT TECHNOLOGIES 11crzljavier
 
Diseases of the Respiratory System (J00-J99),.pptx
Diseases of the Respiratory System (J00-J99),.pptxDiseases of the Respiratory System (J00-J99),.pptx
Diseases of the Respiratory System (J00-J99),.pptxEMADABATHINI PRABHU TEJA
 
Introduction to Evaluation and Skin Benefits
Introduction to Evaluation and Skin BenefitsIntroduction to Evaluation and Skin Benefits
Introduction to Evaluation and Skin Benefitssahilgabhane29
 
Empathy Is a Stress Response - Choose Compassion instead
Empathy Is a Stress Response - Choose Compassion insteadEmpathy Is a Stress Response - Choose Compassion instead
Empathy Is a Stress Response - Choose Compassion insteadAlex Clapson
 
Artificial Intelligence in Healthcare: Challenges, Risks, Benefits
Artificial Intelligence in Healthcare: Challenges, Risks, BenefitsArtificial Intelligence in Healthcare: Challenges, Risks, Benefits
Artificial Intelligence in Healthcare: Challenges, Risks, BenefitsIris Thiele Isip-Tan
 
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdfCompliatric Where Compliance Happens
 
Identifying Signs of Mental Health Presentation (1).pptx
Identifying Signs of Mental Health Presentation (1).pptxIdentifying Signs of Mental Health Presentation (1).pptx
Identifying Signs of Mental Health Presentation (1).pptxsandhulove46637
 
Hematinics and Erythropoietin- Pharmacology of Hematinics
Hematinics and Erythropoietin- Pharmacology of HematinicsHematinics and Erythropoietin- Pharmacology of Hematinics
Hematinics and Erythropoietin- Pharmacology of Hematinicsnetraangadi2
 
Understanding Warts and Moles: Differences, Types, and Common Locations
Understanding Warts and Moles: Differences, Types, and Common LocationsUnderstanding Warts and Moles: Differences, Types, and Common Locations
Understanding Warts and Moles: Differences, Types, and Common LocationsNeha Sharma
 
person with disability and pwd act ppt.pptx
person with disability and pwd act ppt.pptxperson with disability and pwd act ppt.pptx
person with disability and pwd act ppt.pptxMUKESH PADMANABHAN
 
Basics of Giant Cell Tumor of bone (GCTB)
Basics of Giant Cell Tumor of bone (GCTB)Basics of Giant Cell Tumor of bone (GCTB)
Basics of Giant Cell Tumor of bone (GCTB)bishwabandhuniraula
 
Assisted Living Care Residency - PapayaCare
Assisted Living Care Residency - PapayaCareAssisted Living Care Residency - PapayaCare
Assisted Living Care Residency - PapayaCareratilalthakkar704
 
ACCA Version of AI & Healthcare: An Overview for the Curious
ACCA Version of AI & Healthcare: An Overview for the CuriousACCA Version of AI & Healthcare: An Overview for the Curious
ACCA Version of AI & Healthcare: An Overview for the CuriousKR_Barker
 
CECT NECK NECK ANGIOGRAPHY CAROTID ANGIOGRAPHY
CECT NECK NECK ANGIOGRAPHY CAROTID ANGIOGRAPHYCECT NECK NECK ANGIOGRAPHY CAROTID ANGIOGRAPHY
CECT NECK NECK ANGIOGRAPHY CAROTID ANGIOGRAPHYRMC
 
Health literacies in marginalised communities LILAC 24.pptx
Health literacies in marginalised communities LILAC 24.pptxHealth literacies in marginalised communities LILAC 24.pptx
Health literacies in marginalised communities LILAC 24.pptxPamela McKinney
 
Living Well Every Day: Lyons Wellness Practice | Nurtures Your Complete Health
Living Well Every Day: Lyons Wellness Practice | Nurtures Your Complete HealthLiving Well Every Day: Lyons Wellness Practice | Nurtures Your Complete Health
Living Well Every Day: Lyons Wellness Practice | Nurtures Your Complete HealthLyons Health
 

Recently uploaded (20)

FINAL PROJECT IN EMPOWERMENT TECHNOLOGIES 11
FINAL PROJECT IN EMPOWERMENT TECHNOLOGIES  11FINAL PROJECT IN EMPOWERMENT TECHNOLOGIES  11
FINAL PROJECT IN EMPOWERMENT TECHNOLOGIES 11
 
Diseases of the Respiratory System (J00-J99),.pptx
Diseases of the Respiratory System (J00-J99),.pptxDiseases of the Respiratory System (J00-J99),.pptx
Diseases of the Respiratory System (J00-J99),.pptx
 
Introduction to Evaluation and Skin Benefits
Introduction to Evaluation and Skin BenefitsIntroduction to Evaluation and Skin Benefits
Introduction to Evaluation and Skin Benefits
 
Empathy Is a Stress Response - Choose Compassion instead
Empathy Is a Stress Response - Choose Compassion insteadEmpathy Is a Stress Response - Choose Compassion instead
Empathy Is a Stress Response - Choose Compassion instead
 
Painting Rats White Angers Them to No End
Painting Rats White Angers Them to No EndPainting Rats White Angers Them to No End
Painting Rats White Angers Them to No End
 
Artificial Intelligence in Healthcare: Challenges, Risks, Benefits
Artificial Intelligence in Healthcare: Challenges, Risks, BenefitsArtificial Intelligence in Healthcare: Challenges, Risks, Benefits
Artificial Intelligence in Healthcare: Challenges, Risks, Benefits
 
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
2024 Compliatric Webianr Series - Contracts and MOUs from a HRSA Perspective.pdf
 
Identifying Signs of Mental Health Presentation (1).pptx
Identifying Signs of Mental Health Presentation (1).pptxIdentifying Signs of Mental Health Presentation (1).pptx
Identifying Signs of Mental Health Presentation (1).pptx
 
Annual Training
Annual TrainingAnnual Training
Annual Training
 
Hematinics and Erythropoietin- Pharmacology of Hematinics
Hematinics and Erythropoietin- Pharmacology of HematinicsHematinics and Erythropoietin- Pharmacology of Hematinics
Hematinics and Erythropoietin- Pharmacology of Hematinics
 
Understanding Warts and Moles: Differences, Types, and Common Locations
Understanding Warts and Moles: Differences, Types, and Common LocationsUnderstanding Warts and Moles: Differences, Types, and Common Locations
Understanding Warts and Moles: Differences, Types, and Common Locations
 
person with disability and pwd act ppt.pptx
person with disability and pwd act ppt.pptxperson with disability and pwd act ppt.pptx
person with disability and pwd act ppt.pptx
 
Basics of Giant Cell Tumor of bone (GCTB)
Basics of Giant Cell Tumor of bone (GCTB)Basics of Giant Cell Tumor of bone (GCTB)
Basics of Giant Cell Tumor of bone (GCTB)
 
Assisted Living Care Residency - PapayaCare
Assisted Living Care Residency - PapayaCareAssisted Living Care Residency - PapayaCare
Assisted Living Care Residency - PapayaCare
 
ACCA Version of AI & Healthcare: An Overview for the Curious
ACCA Version of AI & Healthcare: An Overview for the CuriousACCA Version of AI & Healthcare: An Overview for the Curious
ACCA Version of AI & Healthcare: An Overview for the Curious
 
CECT NECK NECK ANGIOGRAPHY CAROTID ANGIOGRAPHY
CECT NECK NECK ANGIOGRAPHY CAROTID ANGIOGRAPHYCECT NECK NECK ANGIOGRAPHY CAROTID ANGIOGRAPHY
CECT NECK NECK ANGIOGRAPHY CAROTID ANGIOGRAPHY
 
Health literacies in marginalised communities LILAC 24.pptx
Health literacies in marginalised communities LILAC 24.pptxHealth literacies in marginalised communities LILAC 24.pptx
Health literacies in marginalised communities LILAC 24.pptx
 
SCOPE OF CRITICAL CARE ORGANIZATION
SCOPE OF CRITICAL CARE ORGANIZATIONSCOPE OF CRITICAL CARE ORGANIZATION
SCOPE OF CRITICAL CARE ORGANIZATION
 
Living Well Every Day: Lyons Wellness Practice | Nurtures Your Complete Health
Living Well Every Day: Lyons Wellness Practice | Nurtures Your Complete HealthLiving Well Every Day: Lyons Wellness Practice | Nurtures Your Complete Health
Living Well Every Day: Lyons Wellness Practice | Nurtures Your Complete Health
 
The Power of Active listening - Tool in effective communication.pdf
The Power of Active listening - Tool in effective communication.pdfThe Power of Active listening - Tool in effective communication.pdf
The Power of Active listening - Tool in effective communication.pdf
 

Mitigating Stacking Risks

  • 1. 1 Mitigating Stacking Risks An MD Ranger on-demand video
  • 2. Our agenda • About MD Ranger • What is “stacking” and why is it risky? • Best practices for preventing stacking • Case studies 2
  • 3. 275+ Physician Benchmarks • Call coverage rates • Medical direction payments • Administrative and leadership services rates • Hospital-based service stipends • Diagnostic testing, etc. • Clinic & hourly rates Online Platform • Benchmark lookups • Contract proposal tools • Contract reports by facility and service • Total facility costs + benchmarks Compliance Documentation • Contract-specific FMV documentation reports • Reports to assist with real-time monitoring and annual reviews Research and Support • Resources for education and training • On-call experts to help subscribers use benchmarks and tools 3
  • 4. The foundation of your contracting process Standardize processes and rates Document FMV Access 275+ payment benchmarks Review contracts and monitor with ease Have smarter, data-driven physician negotiations Mitigate compliance risks 4
  • 5. 5 275+ Benchmarks include: • Call Coverage (52) • Medical direction (91) • Hospital-based services (19) • Administrative and Medical Staff Leadership (22) • Diagnostic/other services e.g. ROP, autopsy, dialysis • Hospital-based stipends • Clinics, professional services • Telemedicine • Residency/teaching/GME • Uncompensated care • Meeting attendance, peer review, IT/EHR and quality initiatives • Pediatric-specific services (13) • Total hospital spending • Percent paying • Number of administrative positions Hospital-characteristics drill down for ADC, bed size, trauma status, urban/rural, stroke centers, and more
  • 8. Overpayments to physicians not always obvious… 8 • Overpayments in physician agreements can be and are often easy to spot, such as paying higher than FMV or paying for too many hours in administrative agreements • Sometimes reasonable-looking payments that are spread out across agreements or within one agreement are not reasonable when looked at in aggregate
  • 9. OIG Advisory Opinion 07-10 9 In this opinion, the OIG calls problematic compensation structures: • “payment for lost opportunity cost that do not reflect bona fide lost income” • ”aggregate on-call payments that are disproportionately high when compared to the physician’s regular practice income” • “payment…resulting in the physician essentially being paid twice for the same service”
  • 10. How stacking happens 10 • A physician or physician group has two or more agreements with a hospital for coverage or administrative/medical direction services • While agreement may be compliant when considered independently, when taken together, payment may be greater than the 90th percentile or the time commitment, particularly in the context of the physician’s clinical practice, requires more hours per year than full-time
  • 11. Another likely scenario An ED call payment rate is based on “opportunity cost” of lost private practice income, but the physician or group doesn’t actually suffer losses 11
  • 12. 12 BEST PRACTICES TO AVOID STACKING
  • 13. 1) Develop policies and review procedures 13 Policy should be targeted towards physicians who hold more than one position or who perform more than one service. If physicians are holding two call positions at the same time, set guidelines around how much they can be paid. If they are effectively an employed physician, set an aggregate payment cap from all sources.
  • 14. 2) Track administrative time carefully 14 Time tracking should be standard for all physician administrative positions. As much you can, automate time tracking and coordinate effectively between all parties: physicians, finance, and administration.
  • 15. 3) Beware of multiple ED call payments 15 Don’t pay a physician to take call for two services at the same time. Common service combinations where stacking most frequently occurs: • Orthopedic surgery and hand surgery • Plastic surgery and hand surgery • Non-invasive and invasive cardiology • Stroke and non-stroke neurology • Trauma and general surgery
  • 16. 4) Review and monitor restricted call payments 16 Ask physicians to certify that his or her private practice cannot be rearranged to avoid lost income. Another way is to monitor physicians’ OR utilization to compare elective volume with and without on-call coverage.
  • 18. Case study: hospitalist, administrator, consultant 18 • Dr. Sally Smith is a hospitalist at a 300-bed community hospital, covering shifts and serving as medical director of the hospitalist panel • Serves as the Vice Chief of Staff • Has consulting arrangement with the hospital to assist with EHR transition • Rates for each position falls with the fair market value for that position
  • 19. Case study: hospitalist, administrator, consultant 19 • Dr. Smith is being paid more than the 90th percentile of the annual income for a full- time hospitalist. • So…if a hospital pays a physician to be a full-time hospitalist, and also pays that individual for three additional jobs, can the physician be effective?
  • 20. Case study: hospitalist, administrator, consultant 20 • There is a possibility that Dr. Smith could—in an admirable effort to be efficient and get the heavy workload done— perform additional administrative duties while she is on-duty and paid as a hospitalist. Key takeaway: Dr. Smith’s total compensation must fall within FMV for the positions she fulfills, and justification for excess payment must be documented to demonstrate non-duplicative payments and duties.
  • 21. Case study: ED call payments 21 • Dr. George Perez is one of the few ENT physicians on the medical staff who is trained and willing to handle major facial injuries. • He staffs two separate panels: ENT and facial injuries. • Both panels are paid at the 75th percentile of respective fair market value ranges; he takes simultaneous call for both specialties. • These arrangements contradicts the principals in the OIG advisory opinions and OIG guidelines
  • 22. Case study: ED call payments 22 • Some organizations pay physicians in a similar situation at the high end of the market range for the best paid position. • Other organizations will choose to pay at the median for one position and at or under the 25th percentile for the second service. • Be aware of paying for two jobs at the same time. Carefully justify and document whatever payment is made.
  • 23. Case study: restricted coverage and opportunity cost risks 23 • Neurosurgery is particularly vulnerable to hidden compliance risks • Frequently restricted coverage; private practice revenue comes from a relatively small number of surgical cases
  • 24. Case study: restricted coverage and opportunity cost risks 24 • The standard for Levels I and II trauma centers is that neurosurgeons must be immediately available and cannot conduct private practice (“restricted call”). • Compensation benchmarks for trauma center neurosurgery assume physicians suffer lost private practice income
  • 25. Case study: restricted coverage and opportunity cost risks 25 However, the physician may not suffer any opportunity cost.; aggregate compensation could be significantly beyond the 90th percentile of benchmark annual neurosurgery compensation.
  • 26. Case study: employment plus 26 • Dr. Grace Williams is a cardiologist that works with a medical group that has a PSA with the local hospital • The group has negotiated a co- management agreement and additional medical directorship payments, including ad hoc payments for meeting attendance and peer review participation • Though her per diem call coverage payment is the 25th percentile, she and her colleagues are paid call stipends
  • 27. Case study: employment plus 27 • Additional payments for services on top of employment arrangements could result in payments to doctors well above fair market value
  • 28. Have more questions about stacking? Reach out: info@mdranger.com MD Ranger, Inc. | 1601 Old Bayshore Hwy, Ste. 107 | Burlingame, CA 94010 www.mdranger.com 28

Editor's Notes

  1. Thanks everyone for joining me today for our on-demand video on mitigating risks associated with stacking physician agreements. I’m Allison Pullins from MD Ranger and I’ll be your host today.
  2. Here’s how we’re going to spend our time in this video. First I’ll introduce MD Ranger before we get into the bulk of our content. Then we’ll talk about what stacking is exactly, and why it’s so risky for compliance. Then we’ll discuss some best practices for preventing stacking before it occurs And then we’ll wrap up with some case studies, which illustrate some common examples of when and how stacking occurs at hospital organizations.
  3. MD Ranger is an online platform that integrates over 250 physician compensation benchmarks with a suite of compliance and financial tools. A secure, web-based Contract Data Tool to collect and organize contracts Analytics to benchmark contracts, review expenditures, identify compliance issues, and compare facilities Cost and compliance reports to compare your contracts to MD Ranger benchmarks Resources and research to support compliance efforts And Support from experts in physician compensation, FMV documentation, and compliance
  4. In fact we aim to the the foundation of the physician contracting process MD Ranger helps subscribers standardize their physician contracting process in the way that is best for their organization. Because our benchmarks and online platforms can be integrated into all types of compliance and legal processes, we can be a resource to all types of organizations. . These types of financial arrangements can be very risky to organizations and to physicians—given federal regulations and hightened scrunity by the government. Our subscribers use the MD Ranger platform to mitigate that risk and monitor risky arrangements.
  5. Here is a comprehensive list of the types of different physician agreements we benchmark. We drill down all our benchmarks by meaningful hospital demographics, like hospital size, trauma status, and more.
  6. We began producing benchmarks in 2009 have have grown from a database of 4,000 to 28,000 contracts since. This is a map of our subscribers and where our data comes from. MD Ranger has more than 225 participating healthcare organizations. We work with all types of facilities from large urban trauma centers to small, rural critical access facilities, surgery centers, dialysis centers and everything in between. MD Ranger has strong representation from both rural facilities and small, community hospitals in urban areas, as well as large trauma centers and AMCs. 25% of our facilities are Level 1 or Level 2 trauma MD Ranger benchmarks hospital characteristics, allowing you to match the most appropriate data slice for each valuation
  7. So let’s talk about what stacking is, and why it should be one of your physician contracting compliance concerns..
  8. First of all, there are ways to catch many overpayments in physician agreements, particularly if the contracts are straightforward and benchmarking is available. Risks for overpayments are things like paying above FMV, or paying for too many hours per administrative deal. But, there are overpayments that are a lot harder to catch—particularly when reasonable looking payments are spread across multiple agreements and turn out not to be commercially reasonable when considered in aggregate.
  9. So, what does the OIG tell us about problematic physician compensation structures? This opinion from 2007 talks about three areas to pay particularly close attention to that could result in compliance issues. First is X Etc etc.
  10. So how does stacking commonly happen? Let’s talk about some scenarios. A physician or physician group has two or more agreements with a hospital for coverage or administrative/medical direction services It’s possible that the physician can coordinate his or her time to fulfill both responsibilities within a time frame generally understood as required to fulfill each agreement separately While agreement may be compliant when considered independently, when taken together, payment may be greater than the 90th percentile or the time commitment, particularly in the context of the physician’s clinical practice, requires more hours per year than full-time
  11. Another likely scenario is that a call payment rate assumes an opportunity cost that actually doesn’t exist.
  12. Now let’s discuss some ways to avoid stacking in the first place and some best practices to implement in your physician contracting program.
  13. Develop a policy and review process regarding physicians who hold more than one position or perform more than one service with the hospital or affiliated organizations. If physicians are holding two call positions at the same time, set guidelines around how much they can be paid. If they are effectively an employed physician, set an aggregate payment cap from all sources.
  14. Ask physicians for time documentation that delineates activities for each role. Time tracking should be standard for all physician administrative positions. As much you can, automate time tracking and coordinate effectively between all parties: physicians, finance, and administration.
  15. Don’t pay a physician to take call for two services at the same time. Common service combinations where stacking most frequently occurs: Orthopedic surgery and hand surgery Plastic surgery and hand surgery Non-invasive and invasive cardiology Stroke and non-stroke neurology Trauma and general surgery
  16. Ask the physician to sign a statement to certify that his or her private practice cannot be rearranged to avoid lost income. Another way is to monitor physicians’ OR utilization to compare elective volume with and without on-call coverage.
  17. Now let’s review some case studies which illustrate common scenarios and services where stacking can easily occur.
  18. Dr. Sally Smith is a hospitalist at a 300-bed community hospital, covering shifts and serving as medical director of the hospitalist panel. Additionally, Dr. Smithserves as the Vice Chief of Staff and has a consulting arrangement with the hospital to assist with EHR transition. She is a huge asset to the organization and the rate for each position falls with the fair market value for that position.
  19. Despite Dr. Smiths talents, these responsibilities could be too much for anyone to handle, no matter how competent. If you take all of Dr. Smiths payments and consider them together, she’s being paid more than the 90th percentile of the annual income for a full-time hospitalist. It also raises the question that if a hospital pays a physician to be a full-time hospitalist, and also pays that individual for three additional jobs, can the physician be effective?
  20. Furthermore, there is the issue of accurate time- tracking and reporting. There is a possibility that Dr. Wong could—in an admirable effort to be efficient and get the heavy workload done— perform additional administrative duties while she is on-duty and paid as a hospitalist. The takeaway here is that Dr. Smith’s total compensation must fall within FMV for the positions she fulfills, and justification for excess payment must be documented to demonstrate non-duplicative payments and duties.
  21. Dr. George Perez is one of the few ENT physicians on the medical staff who is trained and willing to handle major facial injuries. He staffs two separate panels at the same Level II trauma center: ENT and facial injuries. Both panels are paid at the 75th percentile of their respective fair market value ranges, and he is allowed to take simultaneous call for both specialties. While this might make sense to Dr. Perez, it contradicts the principals in the OIG advisory opinions and OIG guidelines if he is being paid for taking call twice.
  22. How might the hospital compensate Dr. Perez fairly without overpaying? Some organizations pay physicians in a similar situation at the high end of the market range for the best paid position. Other organizations will choose to pay at the median for one position and at or under the 25th percentile for the second service. No matter what is chosen, be aware of paying for two jobs at the same time. Carefully justify and document whatever payment is made.
  23. Neurosurgery is particularly vulnerable to hidden compliance risks, especially in trauma centers Frequently both a requirement for restricted coverage, plus most non- emergency private practice revenue comes from a relatively small number of surgical cases that don’t have inflexible scheduling demands
  24. The standard for Levels I and II trauma centers is that neurosurgeons must be immediately available and cannot conduct private practice when on-call (“restricted call”). Thus, compensation benchmarks for trauma center neurosurgery assume physicians suffer lost private practice income given the restriction of the physician’s activities while on call. This assumption is based on the understanding that the neurosurgeon’s practice is busy and nearly all the physician’s time could be utilized for the private practice.
  25. However, if a physician’s practice has slack capacity and the private practice cases can be juggled (or traded with a partner), the physician may not suffer any opportunity cost. Aggregate compensation could be significantly beyond the 90th percentile of benchmark annual neurosurgery compensation.
  26. Dr. Grace Williams is a cardiologist that works with a medical group that has a professional services agreement with the local hospital. In addition to the PSA, Dr. Williams and her colleagues have negotiated both a co- management agreement and additional medical directorship payments, including ad hoc payments for meeting attendance and peer review participation. Though her per diem call coverage payment is quite small and falls in the 25th percentile range, she and her colleagues are paid call stipends.
  27. Immediately raises some red flags. Additional payments on top of PSA’s could result in payments to physicians above and beyond FMV
  28. Thanks for joining us, good luck in the new year.