Coding Changes Have Implications Beyond Just Billing.
Every time the Center for Medicare and Medicaid Services (CMS) updates ICD 10 billing codes, the implications for healthcare providers can be far ranging. Think of it as the check engine light on your car. It needs attention. Immediate attention.
The coding and billing departments at health care institutions across the country are undoubtedly hard at work updating their software and billing systems with the new codes. But if they’re smart (and have a car in the garage), that new coding work should trigger a reminder to health care providers about the importance of updating the valuations for employed and contracted physicians.
A change in code, which causes a change in reimbursement, can affect physician compensation when paid on a wRVU basis. Physician payments by health care providers must be at fair market value (FMV) to avoid Stark Law, anti-kickback violations and False Claims Act issues.
While most health care providers obtain a FMV opinion when acquiring physician practices or entering into PSAs with physicians, best practices should also include periodic (annual) updates to ensure that these physician arrangements remain at fair market value throughout the life of the relationship.
An initial FMV opinion obtained when a health care provider enters into a relationship with a physician is not sufficient to protect the relationship from scrutiny after the transaction is effective.
The CMS, OIG and DOJ can, and will, review periodic fair market valuations to determine whether a physician is being paid above-market rates regardless of when the relationship began. Fair market value can change and be affected by new coding, changes in reimbursement rates, changes in the physician’s work duties and requirements and changes to market rates for similar physicians.
Annual reviews should be conducted by outside independent evaluators so that providers can demonstrate a good faith effort to maintain compliance with various health care laws and validate transaction values (a practice that should continue throughout the life of the relationship).
Don’t ignore the check engine light. Get your physician relationships reviewed now!
akiro can provide health care providers with ongoing fair market value services to ensure updated compliance with regulatory and legal requirements. If you have any questions about post-transaction valuations or the services provided by akiro, please contact David Audibert at firstname.lastname@example.org.