Entering into contractual agreements with non-hospital employed physicians and other ancillary providers is becoming a high priority for hospitals as they seek to increase patient numbers and keep up with competition. As a result, hospitals are dealing with increased regulatory scrutiny and facing settlements being brought forward by whistleblowers. This furthers the need to evaluate practices for identifying and monitoring physician arrangements. Hospitals should be implementing compliance procedures to monitor such arrangements on an on-going basis including:
- Understand the relationships within your organization – review the contracts for services within your organization, in an entrepreneurial environment, physician practices may also have ownership stakes in other ancillary service companies
- Transparency – conduct fair market value analysis and exclusion checking, maintain a checklist of requirements, reviews and approvals for each contract
- Documentation – maintain signed contracts and the supporting documentation in a centralized database
- Training and education – educate board members, contracting staff and others involved in the contracting process (i.e., network development, counsel, etc.) on the risks associated with physician arrangements
Remember, many physician arrangements whistleblower cases stem from situations where someone doesn’t feel they are receiving the same benefits as someone else. Thus, the importance of having a consistent process in place to evaluate and monitor these relationships can increase your organization’s ability to respond to complaints internally, address external inquiries and help you more efficiently do business.
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