using market data to support your compliance program

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1 Using Market Data to Support Your Compliance Program November 21, 2013 Allison Pullins, Director

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1

Using Market Data to

Support Your Compliance

Program

November 21, 2013

Allison Pullins,

Director

2

Discussion Agenda:

• Introduce MD Ranger

• How to identify quality market data and use it

appropriately for physician contract compliance

• Outline benefits of using benchmarks for payment

rates in your compliance program

• Successful strategies and tips from MD Ranger

partner organizations

MD Ranger: your physician market

data and compliance resource

• Provides market data benchmarks for broad range of

administrative services

• Helps to negotiate competitive contracts

• Documents compliance and uncovers potential risks

• Identifies opportunities for cost reduction

• Provides tools to compare a hospital’s internal data to

benchmarks, tools for budgeting

• Generates contract-specific reports for compliance

documentation

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4

MD Ranger Subscribers

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Our Methodology

MD Ranger’s unique subscription service turns verified hospital

data into industry benchmarks. Subscribers submit data via online

survey, working with our implementation team to ensure data

accuracy.

Our unique approach to capturing all contract data from an

organization allows us to not only determine what to pay, but also

when to pay.

Who I am

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• Director at MD Ranger, Inc

• Background in physician

marketing, recruitment,

engagement, compensation,

negotiations

• Helps MD Ranger subscribers

leverage the data, analyze

internal costs, and document

compliance

How to Identify

Quality Market Data

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Attributes of High-Quality Data

• Sample size

• Participant characteristics

• Consistent, comprehensive collection method

• Thorough and transparent auditing processes

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What Does Market Data Reveal?

• What similar hospitals pay

• How rates are distributed

• Hours per month

• Annual payments

• Hourly rates

• Number of positions per service

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Using Benchmarks for

Physician Contracting

Compliance Programs

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Putting Data to Good Use

• Make only apples to apples comparisons

• Consider sample size

• Focus on similar organizations

• Consistently apply market data, especially within a

certain specialty or service

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Setting Internal Guidelines

• Write your policy with input from key stakeholders,

compliance professionals, and attorneys

• Put an executive in charge

• Communication is key!

• Be consistent and descriptive in your policy

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Example Compliance Policy Guidelines

• All physician call coverage contracts must be at or

below the 50th percentile

• Extenuating circumstances may go up to the 60th

percentile

• Exception: call coverage for general surgery and

orthopedic surgery may be at the 75th percentile

• If you must pay above 75th percentile, a written

exception request must go to CEO/CCO/etc

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Benefits of Using Market Data

for Your Compliance Program

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Standardization

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• Everyone across your organization adheres to the

same standard

• Consistency ensures fairness and transparency

• Protects the organization and physicians

Wide Applicability Across Physician

Contracts

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• Diverse data sets allow you to drill deep into

specialties, sub-specialties, etc.

• Facilities with special demographics can use the

most appropriate data cut

• Helpful data on DSH, Medicare status,

uncompensated care components, and incentives

can help inform contract negotiations

Consistently Measure Performance

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• Establishing targets for physician contracting costs

can be measured through using market data

consistently

• Aggregated spend on call coverage and physician

administrative positions can help measure your

financial performance

Strategies, Tips from MD

Ranger Subscribers

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Make Medical Directorships as Simple

as Possible

• Consider setting an organization-wide hourly rate

• Ensure that administrative positions that could be

held by physicians of any specialty are standardized

• Know and track hours spent by physicians doing

administrative, non-clinical duties

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Make Sure Medical Directorships Don’t

Carry Hidden Risks

• Is the role a typical directorship role, or are there

“above and beyond” duties like starting a clinical

program or service line from scratch?

• Beware of hidden compliance risks in number of

hours per month or number of positions per service

• Take a second look at low or average rates

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Discourage “Exceptions” by Making

Dispute Process Rigorous

• Be reasonable when creating a policy, yet

understand your upper limits

• Encourage accountability through using executive

involvement in process

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Health Systems: Empower Facilities to

Make Decisions within reason

• Publish and communicate reasonable guidelines

• Give facility decision-makers access to data;

empower them to make their own decisions within the

guidelines of your policy

• Anything within the policy goes (so be comfortable

with your policy!)

• Outline a fair process to dispute

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Always Put the Organization First

• Does our physician contracting rate policy help

achieve overall goals?

• Does your compliance program protect the

organization?

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Questions?

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We want to hear from you!

www.mdranger.com

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Allison Pullins

Director

[email protected]

650-692-8873