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23 posts from June 2009

June 17, 2009

Stark and allocation of ancillary income

Stark dictates that ancillary income cannot be allocated based on referrals to the ancillary service.  As long as the ancillary income distribution formula is set in advance, is not based on referrals, and is of reasonable duration, it should pass muster.  As an example, your group could agree in advance that all physicians, including those who are not partners will share ancillary income (you could even say that 90% will be split by owners and 10% will be split by non-owners). 


A distribution formula that in essence produced the same result as distribution based on referrals would probably not pass a smell test.


Many physician group practices have gone the distribution by ownership route because it is easy and has already passed scrutiny by the feds, making it essentially a safe harbor.  It also tends to be more readily accepted by the physicians in the group as being fair since the equipment used is generally an equal asset of all owners.


If you haven’t looked at it in a while, make sure your group compensation formulary is in compliance with Stark. If you are looking for a good resource (it requires an annual fee), take a look at MGMA’s www.starkcompliance.com website.

June 16, 2009

Learn to budget wisely when creating a medical office

If you're just starting to build a medical office, craft your best estimate of what will happen in the upcoming year as straightforwardly as possible. As you compare each month's actual results to your projections, you'll learn as much about the process as you will about your finances.

Don't worry about so-called stretch goals in your initial foray. While they might motivate doctors to strive for growth objectives, you can kill any enthusiasm for the entire budgeting process if you set targets too high. No one enjoys spending the whole year "behind the budget."

If you're an old pro at business planning, you'll have good reasons to set challenging goals and look at longer time spans. After several consecutive years of strong, double-digit practice growth, you might expect a natural slowdown. Planning for continued growth keeps the pressure to produce on physicians and employees-particularly if they're included in a performance-bonus pool.

Rather than inflating budget goals, include your best estimates in your budget and use the higher stretch goals as benchmarks for a bonus plan. This way, you'll keep your estimates true and still set ambitious goals.

p.s. Pay a visit to my microblog - www.twitter.com/rtacpa.com


June 15, 2009

A simple way to keep track of drug inventory

If you don’t already have one, here is a real simple way to keep track (and control) of drugs kept in the office:


1.     Medicine vials and invoice arrive.  (Example – 10 vials)

2.     The vials are numbered 1 thru 10 and entered into a log book.

3.     As the injection is given the patient name, etc. is completed on the log book.

4.     Injection & vial # entered into chart.

5.     A routine check is done at the end of the month to insure all injections were billed.

6.     Remaining vials in refrigerator - Match open line items on log.

June 12, 2009

Documenting E/M services

I ran across this documentation chart the other day; appears to be a pretty good one. Use it not only as a documentation tool, but an educational tool as well. Be prepared in case of an audit.


June 11, 2009

How to handle penalties against non-compliant partners

You cannot effectively impose penalties against non-compliant partners without clear provisions for punitive action. Our experts, thus, urge providing for sanctions, and specifically for monetary penalties, within your group documents.

Ask your attorney if your present contracts permit assessing penalties for non-compliant behavior. If they do, undertake partner-level adoption of a specific penalty system. Among other reasons, just doing so (and following it whenever necessary) helps prove the group's intent to carry out an effective Medicare compliance program, possibly mitigating any fines in case of audit.

These days, effective groups' documents should specifically address performance expectations and permit penalizing for failure to meet them. You are better served to improve your legal structure before a problem arises than to find yourself hamstrung when you need to act.

June 10, 2009

Notices of privacy practices

Reproduced from [name of publication] © 2008 HCPro, Inc., 200 Hoods Lane, Marblehead, MA 01945. 781/639-1872. www.hcpro.com. Used with permission.

Do notices of privacy practices (NPP) apply to business associates of a covered entity, such as a billing agency for physician practice? A covered entity (e.g., a physician practice) issues an NPP to tell patients what information it collects about them, how it will use that information, and what patients’ rights are with respect to their information. The NPP does not provide any specific protection for the physician practice, and it does not apply to business associates, such as a billing agency. However, the covered entity (physician practice) must have a business associate agreement with the billing agency to protect the information the billing agency can access.

June 09, 2009

Eliminate timecards

Time Clock Software and Labor Tracking Systems are the solution to the Attendance monitoring problems in every company, including physician practices. Count Me In has a product that is one of the cleanest and most efficient ways to track employee's timecards. Check out their Fingerprint Time Clock System and eliminate those time cards (which often lead to employee abuse as we all know!).

June 08, 2009

Employed or Independent - What direction is in store for you?

The trend of hospitals acquiring physician practices is back. Approached physicians are thinking should I stay put or should I sell out. My friend and colleague Mike DeVries (Mike@vmde.com) has written an excellent blog post on the subject…..check it out:


 p.s. Don’t forget to follow me on Twitter: www.twitter.com/rtacpa

June 05, 2009

Create a patient form that's in tune with the times

Add a field on patient forms that asks, "How would you like to be addressed by our staff?" More than simply demonstrating political correctness, that single action shows that you care about your patients' feelings.

Some studies estimate that at least 40% of your patients seek "alternative" healthcare or self-medicate with "natural" dietary supplements. Make sure your form asks about medications, other physicians (specifically including other practitioners), and over-the-counter products.

Remember, too, that today's patients are more "connected" than ever. Include space on your form for cellphone numbers, fax numbers, pagers, and e-mail addresses. Some practices take an identification photo of patients at registration to help physicians and staff associate faces with names. Consider using a digital camera or a scanner to include the picture in computerized charts, too.

June 03, 2009

Looking for on-call scheduling software?

Take a look at these three companies: