As experts and thought leaders in the healthcare arena, Coker Group associates frequently write articles to help our readers better understand and navigate through the industry’s foremost issues. Below are a few of our recent articles, several of which appeared in the industry’s top publications.

Comparing risks: Physician employment and clinical integration
By Ellis “Mac” Knight, MD, MBA, Compliance Today

The November 2018 issue of HCCA’s Compliance Today published an article written by Coker Senior Vice President/CMO, Ellis “Mac” Knight, MD, MBA. The article addresses the following key takeaways.

  • Employment of physicians and other providers by hospitals and clinical integration between hospitals and providers are two standard models of aligning hospitals, health systems, and providers.
  • Clinical integration is becoming a more popular model for alignment, given that it places much less financial stress on the balance sheet of the hospital or health system than does provider employment.
  • Employment of providers entails particular risks related to the Stark Law, the Anti-Kickback Statute (AKS), and HIPAA.
  • Clinical integration’s compliance risks predominantly revolve around antitrust rules and regulations; however, Stark, AKS, HIPAA, and medical malpractice risks are also inherent in this model.
  • Neither employment nor clinical integration is free of compliance risks, and hospital or healthcare systems will have to scrutinize the risks and benefits of each before deciding which model they prefer to use to align and engage effectively with their providers.

Read the full article here.

Physician compensation in a confusing and disordered reimbursement environment (volume to value)
By Justin Chamblee, CPA, Journal of Management in Healthcare

The healthcare industry is changing from a reimbursement perspective, in that reimbursement is still predominantly fee-for-service but includes value-based elements. This dual system is widely affecting providers by pushing more of the payment and cost risk onto them (versus insurers). In short, the current reimbursement environment is confusing and disordered. This evolving paradigm calls for a new approach to how physicians’ compensation is pursued, ensuring that a model structure is in place that aligns incentives and/or risk with the respective physicians relative to the reimbursement environment. Furthermore, it must be sufficiently flexible to adapt to the current frenzied nature that precedes this unfamiliar approach. This paper examines current and pending changes and their effect on the healthcare market. It discusses the various risks associated with different payment arrangements and reviews how the passage of the Medicare Access and CHIP Reauthorization Act of 2015 affects reimbursement. It then drills down into the corresponding compensation considerations that should be evaluated in light of the value-based reimbursement structures and strategies. The final focus is on navigating these changes to the healthcare environment.

Read full article here.

Telemedicine Reimbursement and Regulations 
By Max Reiboldt, CPA, Healthcare Business Management Association

Telemedicine is the delivery of healthcare through communications technology between providers and patients with a focus on improving access to care. The technological developments in telemedicine allow for the expansion of the scope of services and the provision of cost-effective care to patients. Telemedicine enables healthcare facilities the ability to reduce hospital admissions, readmissions, and emergency room volume by treating patients with chronic conditions who may otherwise be unable to seek treatment or manage their conditions effectively. Patients with minor ailments or those needing follow-up visits can also use telemedicine when an in-person visit is unnecessary. Additionally, telemedicine facilitates better patient care by connecting patients to specialists they often otherwise are unable or not as readily able to access. This lack of access especially applies to rural and other shortage areas.

Read full article here.

Addressing compliance issues in reimbursement and licensing for telemedicine 
By Max Reiboldt, CPA, Compliance Today

The December 2017 issue of HCCA’s Compliance Today published an article written by Coker President/CEO, Max Reiboldt, CPA. The article addresses the following key takeaways.

  • Telemedicine allows for expanded access and improved quality of care.
  • Eligible locations, providers, and live-video telemedicine are required for Medicare reimbursement.
  • No two states are alike in Medicaid telemedicine requirements.
  • The top commercial payers all offer some coverage for telemedicine.
  • There are avenues to expedite telemedicine licensing and credentialing.

Read the full article here.

Clinical documentation: 10 means for compliance and convenience
By Ellis “Mac” Knight, MD, MBA, Compliance Today

The October 2017 issue of HCCA’s Compliance Today published an article written by Coker Senior Vice President, Ellis “Mac” Knight, MD. The article addresses the following key takeaways.

  • Avoid poor clinical documentation practices that commonly result from limited time for direct patient care and documentation.
  • Mitigate the deleterious effect documentation in the electronic medical record can have on face-to-face patient care delivery.
  • Ensure compliant documentation of care is accomplished in the most efficient and effective manner possible.
  • Prepare for value-based reimbursements, where both clinical documentation and abstraction of performance data from the medical record will be required for billing purposes.
  • Step back to re-tool provider clinical documentation processes and procedures.

Read the full article here.

Credit card on file program
By Debbie Kiehl, FACMPE, CRCR, Compliance Today

The September 2017 issue of HCCA’s Compliance Today published an article written by Coker Senior Manager, Debbie Kiehl. The article addresses the following key takeaways.

  • Due to increasing out-of-pocket expenses for patients, healthcare entities are exploring a “credit card on file” option to make patient payments more timely and efficient.
  • Credit card on file programs should use a certified PCI-DSS vendor to ensure the healthcare entity meets the credit card data security standard.
  • Develop policies and procedures for practice staff to follow, including a financial policy for the patients to review, and require patients to provide signed authorization for payments.
  • Penalties for non-compliance and/or a breach are maintained by the industry PCI Standards Council (can range from $2,000-$100,000 per month).
  • Penalties are levied on banks and credit card institutions and can be filtered down to the healthcare practice if credit card data is compromised.

Read the full article here.

Rolling the dice: Gambling with improper documentation and billing practices
By Deborah Hill, MBA, CMPE, CPC, CHC, Compliance Today

The July 2017 issue of HCCA’s Compliance Today published an article written by Coker Senior Manager, Deborah Hill. The article addresses the following key takeaways.

  • Some internal processes may enhance revenue but increase risk.
  • Various documentation elements can expose your practice to compliance risk.
  • The documentation process imposes imposes limits on use of support staff.
  • Coding outliers in your organization can be identified.
  • Baseline and regular random reviews are critical to maintaining compliance.

Read the full article here.

Surviving Value-Based Healthcare with Revenue Integrity
By Annette Sullivan, RHIA, Compliance Today

The June 2017 issue of HCCA’s Compliance Today published an article written by Coker Senior Manager, Annette Sullivan. The article addresses the following key takeaways.

  • The impact of revenue integrity on value-based healthcare is often overlooked.
  • Revenue integrity must be a formal, centralized process that is constant and inclusive of all departments and individuals that affect the revenue cycle.
  • The integrity of your data in 2017 will determine the payments you receive and the penalties you incur in 2019.
  • Track and trend issues, determine the root causes, and implement solutions to improve efficiencies.
  • Develop an audit plan to reduce day in AR and mitigate risks of claims denials.

Read the full article here.

Data-Driven Solutions, Set in Motion
Outpatient Outcomes – 2017 Issue 6, Interviewed Phil Meyer, Consultant with Coker Group

Outpatient Outcomes 2017 issue 6 was published in May 2017. This issue included an article on Data-Driven Solutions in which Coker Consultant, Phil Meyer, was interviewed regarding initiatives at South Shore Ambulatory Surgery Center where he is functioning as the chief operating officer.

Read the full article here. Used with permission by Medline and Phil Meyer.

Transaction Strategies and Long-Term Value Creation: Do Deals Automatically Result in Success for Health Care Organizations?
By Mark Reiboldt, Senior Vice President, published in AHLA’s 2017 Health Care Transactions Resource Guide

AHLA published their 2017 Health Care Transactions Resource Guide in April 2017 for distribution at the Health Care Transactions Conference. This resource guide included an article written by Mark Reiboldt, Senior Vice President of Coker Group. This article discuss the importance of long-term value creation in today’s health care environment. It goes on to review transaction strategies and evaluate trends from deals that have taken place in the current market landscape.

Read the full article here.

Clinical Integration: What Hospital Board Members Need to Know
By Ellis “Mac” Knight, MD, MBA, Governance Institute E-Briefing

The Governance Institute’s March 2017 E-Briefing – Volume 14, No. 2 published an article written by Coker’s Senior Vice President/CMO, Dr. Ellis “Mac” Knight. Clinical integration is a key ingredient as providers attempt to re-tool care processes and procedures to operate successfully in a reimbursement environment moving towards value-based payments. This article looks at organizing providers around value-based care delivery and the key components of a clinically integrated network.

Read the full article here.

The uncertainty of the implied certification theory
By Daniel Kiehl, JD, LLM, Compliance Today

The March 2017 issue of HCCA’s Compliance Today published an article written by Coker Associate Consultant, Daniel Kiehl. The article addresses the following:

  • The False Claims Act prohibits submitting false or fraudulent claims to the government.
  • The Supreme Court in Escobar did not define what it determines to be a material misrepresentation.
  • The appellate court circuits were split in regards to the scope of the implied certification theory.
  • Escobar does not consider whether the misrepresentation involves a condition of payment.
  • The False Claims Act provides for triple damages for violations.

Read the full article here.

Aligning Physician Compensation in a Value-based World
By Keith L. Martin, Physician Practice

On October 28, 2016, Physician Practice spoke with Justin Chamblee, CPA, Senior Vice President and Jon Morris, JD, MBA, Manager at Coker Group about compensation changes and how practices can move forward “with minimal impact to physicians and daily operations.” Below is the beginning of this discussion. For the full article click here.

Employed Physician Network Turnaround
By Jeff Gorke, MBA

Coker Group’s article, Employed Physician Network Turnaround: A Roadmap to Financial Success, was recently featured in AHLA’s 2015 Healthcare Transactions Resource Guide and appeared as the resource guide’s headlined article in AHLA’s newsletter. Take a look at the article for valuable, tested advice on how to successfully integrate an EPN into a health system’s organizational structure.

Repositioning from IPA to CIN
By Max Reiboldt, CPA and Ellis “Mac” Knight, MD, MBA
(Featured in May 2015 by Becker’s Hospital Review)

As the healthcare industry moves slowly but inexorably toward a more value-based reimbursement environment, many independent physician associations (IPAs) are looking at becoming clinically integrated networks (CINs). The difference between these two entities is not a matter of mere semantics. Instead, the distinction gets to the core of which model better allows physicians and other healthcare providers to enter into value-based contracts with confidence and perhaps become full-fledged population health managers.

The transition, however, is not easy nor is it without risks. This article will hopefully clarify much of the confusing nomenclature used in this area and provide the reader with a valuable roadmap to guide them through this often very complicated transformation process.

Physician Compensation in an age of Decreasing Reimbursement: A New Perspective on the Median
By Justin Chamblee, MAcc, CPA
(Featured in a 2014 issue of HFMA’s hfm publication)

The current trends of hospitals heavy (and oftentimes sole) use of benchmark data in establishing physician compensation is inadvertently increasing physician compensation, presenting a situation that is likely to undergo mounting scrutiny in an environment under pressure to lower costs. The merits and consequences of using benchmark data, focusing on median compensation per wRVU ratio, to build a compensation model and its long-term feasibility are examined in this paper. Also presented are modifications that can be made when developing wRVU-based compensation models that will address the issues of using benchmark data to derive compensation that aligns with productivity levels and general market trends.

Hot, Emerging HCIT Tool and Trends
The Pace Quickens
By Jeffery Daigrepont, EFPN
(Featured in the January, 2014 Edition of AMGA Group Practice Journal)

Health systems and clinics of every size are preparing for an accelerated pace for healthcare information technology (HCIT) adoption and implementation, which will increase influence in every part of the clinical, financial, and operational workflow. This article addresses the five emerging tools/trends where acceleration will be most profound and necessary for future viability and participation in quality care initiatives.

Three Rights Equal Value
A Success Formula
By Ellis “Mac” Knight, MD, MBA, Jeffery Daigrepont, EFPM, and Nilam Patel, MPH

Three critical requirements in developing an IG framework include establishing a team, defining key performance indicators (KPIs) by roles, and implementing a protocol. This article details how to go about putting in place these key components and outlines a roadmap for achieving a sustainable IG initiative.

ACO/MSSP CMS to Increase Participation in the Shared Savings Program
By Ellis “Mac” Knight, MD, MBA, max Reiboldt, CPA, and Nilam Patel, MPH

The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule on December 1, 2014, to improve the Medicare Shared Savings Program (MSSP). The changes will take effect in 2016 and aim to improve the rules and regulations of the overall program. The proposed rule will affect all accountable care organizations (ACOs) considering MSSP and those already participating in the program.