During these tough economic times, don't underestimate the difficulty of internal process improvement and cost reduction, says this piece from Sg2. The long-term success or failure of your internal process improvement can, to a large extent, be predicted based on how internal teams are structured, deployed and positioned in the organization, according to the article.
Surgeon Beth DuPree's dream of a specialized hospital for breast-cancer patients has closed. She says the Comprehensive Breast Care Institute at DSI of Bucks County, PA, was a victim of the economy and naive business planning. But for her, the closing of the freestanding, for-profit hospital in Bensalem, PA, is both cautionary tale and learning experience.
Every physician office needs a compliance plan—a written document that outlines proper policies and procedures for coding, billing, and managing other regulations that apply to physician practices. Ideally, your compliance plan will keep you out of hot water with the Office of Inspector General (OIG) and health plan or government auditors.
But should you be accused of noncompliance, simply having a written plan protects a practice from penalties and other damages that can be levied against it in the event of incidents without intent. Not developing and implementing a compliance plan essentially removes those protections.
Although most facilities have such a plan, some are slow to adjust their policies based on changes within the practice. Others simply fail to follow procedures defined within their plan. It's crucial to keep compliance a priority, however, to avoid government penalties and withheld reimbursement.
"The OIG Work Plan is the government crystal ball," says Curtis J. Udell, CPAR, CPC, senior advisor at Health Care Advisors, Inc., in Annandale, VA.
The Work Plan outlines seven general guidelines for compliance plan development and implementation:
1. Conduct internal monitoring and auditing.
2. Establish policies and procedures that include an examination of risk areas specific to your practice, such as those relating to coding and billing; reasonable and necessary services; documentation; and improper inducements, kickbacks, and self-referrals.
3. Designate a compliance officer or contact to monitor compliance efforts and enforce practice standards.
4. Conduct compliance training, particularly in regard to coding and billing.
5. Respond to and investigate detected violations, disclose any such incidents to the appropriate government agencies, and develop corrective action initiatives.
6. Keep the lines of communication open via discussions at staff meetings or community bulletin boards. Janet Burch, administrator at Pikes Peak Nephrology Associates, PC, a nine-provider practice in Colorado Springs, CO, says to delegate some of the development and implementation work to staff members, making the process a team effort. "It allows everyone to take more ownership in the practice," Burch says.
7. Publicize guidelines and enforce disciplinary standards.
These seven elements are just a starting point for practices' compliance efforts, says Udell. "It must be an active part of practice operations," he says, noting that regular reviews, revisions, and updates are crucial for any plan.
This article was adapted from one that originally appeared in the February 2009 issue ofThe Doctor's Office, a HealthLeaders Media publication.
Fee for service has to go, that much we know. Among its many flaws as a reimbursement system, perhaps its greatest is that it offers few financial incentives for preventative medicine and primary care, which will become increasingly important to meeting the growing demand for healthcare services in coming years.
So the multi-billion dollar question now is: What replaces fee for service? We've seen wish lists from CMS and other industry players for more emphasis on pay for performance and similar types of value-based purchasing, but absent from the discussion has been consensus on an overarching payment structure to replace the current one.
One of the leading candidates has been a bundled payment system that reimburses physicians and hospitals for episodes of care, such as months of cancer treatment, that under the current system involve many separate billable procedures. Medicare is piloting a program in which bundled payments are split between physicians and hospitals, and some private insurers are experimenting with it as well.
When it comes to large scale reform, this payment system lost a strong advocate this week when Tom Daschle withdrew from consideration as nominee for Health and Human Services Secretary, but be careful about reading too much into that. Senator Max Baucus (D-MT), who may play a large role in shaping healthcare reform as chairman of the Senate Finance Committee, also favors bundled payments, as do other influential policy makers, according to the Wall Street Journal.
I can certainly see the appeal. It is in many ways a "middle road" that seeks to avoid the pitfalls of fee for service without venturing into capitation, which pays a fixed rate per patient and has been criticized for creating incentives for providers to cut costs and withhold treatments for patients.
But healthcare policy makers didn't see many of those unintended consequences coming when capitation was touted as a physician reimbursement solution, just as many of the flaws in the fee-for-service model weren't always apparent. So before moving forward with a bundled system, policy makers should carefully examine the incentives it will create and do their best to foresee possible unintended consequences.
Take hospital and physician relationships, for instance. In some cases, when bundled payments are made for hospital-based episodes of care, the hospital is in charge of doling out the money to physicians. And if you can't see the potential problems that will cause, you haven't been paying attention to the healthcare industry.
Physicians are worried that they will have to constantly negotiate with hospitals to receive a fair share of the payment—that may be less of a problem as more hospitals employ doctors outright, but it could hurt relations with those in private practice. And because many of these episodes of care involve multidisciplinary teams, physicians are already competing with one another to make a case for why their specialty deserves a larger piece of the pie.
Proponents of bundled payments are trying to avoid many of these hurdles by adding caveats and conditions for payment. But the more complicated any payment system becomes, the more likely it is that payments will influence provider behavior in ways that haven't even been considered.
If policy makers aren't careful, their worthwhile attempts to fix the flaws in the fee-for-service system may just create a whole new set of problems.
Elyas Bakhtiari is a managing editor with HealthLeaders Media. He can be reached at ebakhtiari@healthleadersmedia.com.
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A new study suggests that 21.2% of medical students suffer from depression, compared with the 10% rate commonly reported for the general population. The study, a survey of 2,000 students that was reported in Academic Medicine, also said that black medical students are particularly prone to suicidal thoughts, with 13% reporting "suicidal ideation," versus 5.7% of the general population.
The House gave final approval to a bill extending health insurance to millions of low-income children, and President Obama signed it later in the day. Obama hopes it is the first in what will be many steps to guarantee coverage for all Americans. Since August 2007, the House has voted at least seven times for legislation to expand the State Children's Health Insurance Program, but prior efforts were thwarted by the Bush White House.