Incorporating Anesthesia Services into your Facility

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Hugh Atkins
8 years ago
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1 Incorporating Anesthesia Services into your Facility

2 Credentials Marc E. Koch, MD, MBA President & Chief Executive Officer Doctor of Medicine (State University of NY at Stony Brook) Board Certified Anesthesiologist (Yale School of Medicine) Certified - American Board of Pain Medicine MBA Finance (Fordham University) President and CEO of Somnia Inc. 12 Yrs of Consulting (Anesthesia, Pain, Facility Development)

NY at Stony Brook) Board Certified Anesthesiologist (Yale School of Medicine) Certified -

3 Disclosure: 1 Somnia provides anesthesia services for: Inpatient Facilities Ambulatory Surgery Centers Office Based Surgical Facilities Consulting Services

4 Disclosure: 2 All slides and discussion are for discussion purposes only. Advice is provided by a retained consultant and attorney not me The exchange of something of value between the provider and recipient of medical referrals can have serious criminal and civil penalties.

me The exchange of something of value between the provider and

5 Model # 1: Straight Fee-for-Service Management Company Services Clinical Services Residual Cash Flow Anesthesia Entity Owned by Anesthesia Docs Anesthesia Reimbursement GI Doctors Patients Anesthesia Docs

Flow Anesthesia Entity Owned by Anesthesia Docs

6 Anatomy of a Fee-for-Service Anesthesia group provides services Anesthesia group submits claims and collects Anesthesia group pays its bills (clinical and administrative) Recruitment Scheduling Billing & Revenue Collection Logistics Support (if applicable) Credentialing and Privileging Vacation Coverage Residual cash flow comes to the doctors

administrative) Recruitment Scheduling Billing & Revenue Collection Logistics Support

7 Model #2: Administrative Service Agreement Management Company Services Clinical Services GI ASC ASA Payment Anesthesia Entity Owned by Anesthesia Docs Anesthesia Reimbursement GI Doctors Patients Residual Cash Flow Anesthesia Docs

Anesthesia Entity Owned by Anesthesia Docs Anesthesia

8 Anatomy of an ASA Agreement Anesthesia group provides anesthesia services to the facility RAA shall pay an Administrative Service Arrangement fee to the facility Compulsory requirements include the ASA fees be for services that are: necessary and indicated priced at fair market value can not be volume based beware of overlap with CMS Facility Payments (false claim)

requirements include the ASA fees be for services that are: necessary and indicated priced

9 Model #3: Joint Venture Model Anesthesia Entity Owned by Anesthesia Doc s Residual Cash Flow GI Physicians/ ASC Management Company Services Management Fees Management Services Newly created anesthesia PC 50/50 Clinical Services to Patients Revenue Patients

Management Company Services Management Fees Management Services

10 Anatomy of a Joint Venture Anesthesia services provided All anesthesia bills are paid Profits apportioned according to PC ownership True JV results in 50/50 arrangement but Serious Compliance Issues: 60/40 rule- 60% of referrals must be from sources that do not own the anesthesia professional corporation

50/50 arrangement but Serious Compliance Issues: 60/40 rule- 60% of

11 Model #4 Management Model (GI Docs Own) Management Company Services Clinical Services Residual Cash Flow Anesthesia Entity Owned by GI Docs Anesthesia Reimbursement GI Doctors Patients GI Docs

12 Anatomy of a Management Contract GI Partners create an Anesthesia Entity at their sole expense Management service company manages Anesthesia Entity Anesthesia Entity pays Somnia a management fee GI Docs receives all residual income once all bills are paid

company manages Anesthesia Entity Anesthesia Entity pays Somnia

13 Model #5 Captive Contract Somnia Management Services Clinical Services Anesthesia Entity Owned by Anesthesia Docs Anesthesia Reimbursement GI Doctors Patients GI Docs Pay Anesthesia Entity a Flat Fee +/- Bonus Anesthesia Reimbursement Assigned to GI Docs GI Docs

Reimbursement GI Doctors Patients GI Docs Pay Anesthesia Entity a

14 Anatomy of a Captive Contract Anesthesia Entity provides anesthesia services to GI facility GI facility pays Anesthesia Entity a flat fee Anesthesia Entity assigns payments to the GI Docs GI Docs keeps any residual income left over

Anesthesia Entity a flat fee Anesthesia Entity assigns

15 Anesthesia Relationships: Compliance Anti-kickback compliance issues on both State/Federal levels Billing compliance issues Imperative that any agreement be reviewed and endorsed by counsel.

16 Elements of a Successful Anesthesia Department Management Services include, but are not limited to: Staffing assessment Recruitment Interviewing Contracting Credentialing and privilege confirmation Benefits coordination

Staffing assessment Recruitment Interviewing

17 Elements Continued Arranging for vacation coverage Arranging for QA, peer review, etc Contracting with payors Revenue Management Accounting reports Completion and submission of tax forms Total Quality Management Program

payors Revenue Management Accounting reports

18 Getting Started Speak to knowledgeable consultant Speak with health care counsel! Choose an engagement model Execute contracts

19 Disclosure: 2 (again) All slides and discussion are for discussion purposes only. Advice is provided by a retained consultant and attorney not me The exchange of something of value between the provider and recipient of medical referrals can have serious criminal and civil penalties.

Advice is provided by a retained consultant and attorney not me The

20 Contact Information Marc E. Koch, MD, MBA President and CEO Somnia Incorporated Phone ext 3511 Fax

Courtesy of Mark F. Weiss www.advisorylawgroup.com

Courtesy of Mark F. Weiss www.advisorylawgroup.com Page 1 of 7 Published in Anesthesiology News August 2012 Inspector General Weighs In on Fee Sharing BY: MARK F. WEISS, J.D. In a much-awaited pronouncement, the U.S. Department of Health and Human Services