A vast majority of current physician employment contracts, both with larger systems and in individual practice, have some sort of productivity component for compensation, dependent upon the production of: WRVUs (Work Relative Value Unit) Collections Net Profits Even if there are no negotiated “resource” provisions, most contracts also have what was always thought to be just generic obligations of the employer to provide appropriate resources–which they are not necessarily doing if the “offices are closed”,…

The Centers for Medicare and Medicaid Services (CMS.gov) issued a Telemedicine Tool Kit.  Use this link to access the Tool Kit.…

I. Introduction. The COVID-19 pandemic presents all physicians, but especially private practice physicians, with numerous clinical, liability and business challenges. We have chosen the following categories to organize and present recommended guidance and linked resources for your information: 1. Clinical Guidance 2. Malpractice Liability 3. Reimbursement 4. Employer/Workers Compensation 5. Telehealth II. Clinical Guidance. Many authoritative sources are providing clinical recommendations, so we thought it would be more useful to curate some of the leading…

While we are waiting for final disposition of the AKS Safe Harbors and Stark Exceptions proposed in October of 2019, since the comment period expired December 31, 2019 and final rules have not been issued, I thought we should reflect on the comments made and proposed regulations regarding physician compensation. Physicians have become accustomed to hospitals trying to hold down compensation with arguments that it’s illegal to pay physicians more than the revenue they generate,…

You can now tell that telemedicine is a mature industry, because it has achieved enough critical mass that the fraud has started and the OIG is beginning to prosecute.  There is a lag time between when the cash flow and profit achieves sufficient critical mass to attract the criminals, the OIG identifies the problems, and the prosecution actually begins. I am attaching a link to an OIG news release dated February 5, 2020 indicating the…