Medicare’s Quality Improvement Program – Information for Physiatry
Starting in 2017, CMS has instituted a Quality Payment Program (QPP) which incorporates prior PQRS/EHR programs.
Under the new QPP program, all Medicare Part B clinicians are responsible to report various categories:
- Quality(old PQRS)
- Advancing Care(old EHR)
- Improvement Activities, and
- Cost(begins 2018)) as follows:
-All physicians must report, whether they are solo practitioners, or employed by another entity.
-Clinician must have more than $30,000 in Medicare allowed charges AND must provide care to more than 100 Medicare patients a year, or they are exempt,
-Clinicians include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists.
-Newly enrolled physicians are exempt during their first year of practice.
Penalties will be assessed as follows:
Failure to properly report in 2017 will cause a 4% penalty in 2019.
Failure to properly report in 2018 will cause a 5% penalty in 2020.
Failure to properly report in 2019 will cause a 7% penalty in 2021.
Failure to properly report in 2020 will cause a 9% penalty in 2022.
Incentives are also available for the above years for successful reporting:
Successful reporting in 2017 may result in an incentive of up to 4% in 2019.
Successful reporting in 2018 may result in an incentive of up to 5% in 2020.
Successful reporting in 2019 may result in an incentive of up to 7% in 2021.
Successful reporting in 2020 may result in an incentive of up to 9% in 2022.
It helps determine the selling price for your practice.
If you are considering selling your practice, you need a third party valuation firm that specializes in valuing businesses to determine the selling price of your practice. Most other professionals such as business brokers, attorneys and CPA’s either don’t have experience with or access to nationwide sold practices transaction data, the methodology used for asset-based, income-based and market-based valuation calculations, or they are not in daily touch with the current lending market. The price and profitability of your practice must be an amount sufficient to support any acquisition debt service, a new owner’s compensation package and periodic additions to the working capital needs of the practice for growth.
Identifies the total fair market value or selling price of your practice
You will receive separate values for the tangible and intangible assets of your practice. Since tangible assets are usually depreciated for tax purposes, the fair market value of all assets to be included in a sale is based upon today’s prices; not original purchase cost like accountants use. The intangible assets represent the “sweat equity” of the practice including goodwill, patient files and referral sources and the efficiency and profitability of your practice. The sum of tangible and intangible assets included in the sale equals the fair market value or selling price of your practice.
Helps you make an educated decision regarding the sale of your practice
You may have a “hunch” about the selling price of your practice based upon speaking with colleagues and other professionals or reading about revenue/profitability multipliers but a “hunch” is not a reliable method for making the decision to sell or not to sell. You need a solid number concerning the amount of money for which your practice will sell in today’s market. Then you can make a fully informed decision to sell or not to sell your practice.
Enables you to price your practice with confidence
Once you know the selling price of your practice, you are in a very strong negotiating position. If you receive offers below your price, you can confidently stand your ground, knowing that the owner’s cash flow will support acquisition debt service and give the potential buyer a solid return on their investment, as compared to other investment opportunities the buyer may be evaluating.
Article contributed by Jeannette Engel, Business Broker at unionbaygroup.com, email@example.com or (206) 783-1717.
WHO OWNS THE PRACTICE?
The answer to this question will guide your practice life with any group. For several years, while managing physician relations for a local hospital, I recruited physicians for the hospital and affiliated medical practices. It game me an opportunity to view physician recruitment from both sides of the contracts negotiated. I think it beneficial to share some of my experiences and personal insights from those times. I once tried to recruit a physician who was moving back to her hometown. In the world of physician recruitment, we might call this “a perfect geographic match.” Ironically, she chose to sign-on with a local group rather than the hospital I was recruiting for because she said she wanted to go into “private practice” which seemed to represent an idealized practice autonomy. I asked her who owned the practice group. She didn’t know.
*Private practice refers to a privately-owned practice, especially one operating under s system of free enterprise or laissez-faire captalism. It describes a physician-owned practice, one that is not owned by an entity such as a hospital, and it is broadly used today to refer to solo and/or partnership practices of varying structures. Unless you hold some level of practice ownership, you are an employee and you need to identify your employers before you sign a contractual agreement.
* Identify the group’s short-term and long-term goals. This will help you decide if your goals match the goals of the group. If you want a busy outpatient practice then you must step in to fill a vacancy in a busy, established practice or your must build it. How will the group help you to do that?
I brought in one physiatrist who interviewed with the hospital CEO and administrators to consider an opportunity to either take over an established hospital-based and staff-supported inpatient/outpatient practice or to become a hospital employee with benefits. Benefits were the dealmaker, but at dinner the CEO offered an unplanned glimpse into the practice environment when he asked the physician her thoughts about his idea to restructure the inpatient unit. It was a very astute physician who later told me that the CEO wasn’t really asking for an opinion;he was simply trying to determine if she would buck him.
* You are primed to be an employee in a system when you can identify and happily live within an organizational structure that neither seeks nor desires your input.
I met with a physician who had just given notice to his group that he was leaving. He was extremely frustrated and had no alternative practice plan in place. Two years earlier he had signed a contract to join that group with the understanding that he would be offered a partnership. Time passed with minimal partnership discussion and he became so disgruntled that he finally made the decision to leave. As I spoke with him, it became clear that the particulars of that partnership had never been provided.
* A well-organized group will provide you with key information even before you ask. A group that is not organized will barely be able to respond to your questions. All groups fall somewhere along that continuum and you will want to gauge the level of the group’s organization since it will play a major role in your practice satisfaction.
Most physicians have a primary desire to practice medicine. Most would choose to forego the cumbersome paperwork and the persistence required to advocate for the patient when arguing with insurers. One physiatrist told me of the time spent in justifying the need for a wheelchair for a quadriplegic patient.
One physiatrist expressed an interest in building a part-time practice performing only EMGs. That physician was obviously well-informed about medical billing and he desired to build a practice with only high-level billable codes. If you entered into practice with this physiatrist on production-based compensation, what type of practice could you expect to build and how much money might you earn monthly?
- Determine the primary needs of the patient population in the practice area.
As an employee, you will receive financial compensation based on a salary guarantee, production, or a combination of both. A salary guarantee is an amount you can bank on, literally, and it may be a great way to start up your practice. However, no group will want to continue to pay you more than you earn. It just isn’t good business. That means it is expected that your gross charges will increase as you build your practice. Your earning potential will typically be tied to the revenue you generate (production-based) for your group and this is an important point to consider as you begin your contract negotiations.
- Production is typically not the best option for a start-up practice for several reasons. It takes an investment of time and money to build a practice and this may be one of the most underestimated aspects of medical practice start-up.
By Kathy Jeffries, MyraPhyx A Physician Resource Group, firstname.lastname@example.org, 573-680-3105
What is the magical way to improve your billing and collection function? Unfortunately, there is none – no hidden secret, no “silver bullet.” However, adherence to several fundamentals will work just as well.
How to maximize upfront billings:
Capture all performed services! For outpatient services, medical offices usually employ a pre-printed superbill which can easily be misplaced. Suggestion: Match each patient on the appointment schedule to a corresponding superbill.
For each patient admitted to a rehab facility, there is usually an initial charge, regular followups, and ultimately a discharge code. Suggestion: Any gap in inpatient billings should be brought to the provider’s attention.
Simple data entry errors can cost the practice thousands of dollars. Suggestion: Have a second person, not the data entry person, check all data entry.
How to maximize collections:
Followup, followup, followup!
Pursue vigorously by telephone or in writing all insurance denials, and non-responses. Many billing personnel find calling insurance companies to be stressful and time-consuming, when in reality they are usually helpful in resolving problem claims. TELEPHONE FOLLOWUP IS A KEY COMPONENT OF THE COLLECTION FUNCTION. Suggestions: When calling the insurance carrier to reprocess the denied claim, get a reference number. When calling about a claim with no response, try to fax the claim.
If a telephone call cannot resolve the denied claim, then a written appeal should be sent. Suggestion: Design a preprinted Appeal Form which can be filled in with the necessary information.
Sometimes, the patient’s insurance information is incorrect. Although it is very easy to simply send a bill to the patient, it is not the most effective way. You have a better chance of collecting money from the insurance company than from the patient. Suggestion: Research thoroughly the insurance problem by calling the patient, and by calling the insurance company. Billing the patient should be the last resort.
As has been demonstrated, billings can be maximized by capturing all services performed.
Bruno Stillo,CPA is the owner of Physiatry Billing Specialists, 800-835-4482, email@example.com
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