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| Dear Friend,
Have you put your group's survival on sale?
I’m writing this on the Friday after Thanksgiving, the day that merchants have trained shoppers to expect the lowest prices of the year. Don’t buy that TV in October for $1,947, wait a few weeks and then buy it for $679, free shipping included. Even if the merchants don’t push sales to a single day but to a week or whatever, they’ve trained consumers just the same.
Oh, that’s not the way the press portrays it? For them, sales are a form of entertainment. “Black Friday,” “Cyber Monday,” and, who knows what. It’s more manufactured excitement, although it’s true that it’s a participatory sport, and it’s way more popular than the NFL.
Many medical groups with large numbers (large being relative) of employed or subcontracted physicians have put themselves in the same sort of bind in respect of their workforce.
They’ve created an annual event out of the renewal of employment contracts and subcontracts by legislating a set renewal date. It might be January 1st or it could be April 1st, or whatever, but it’s the date on which many or all of the contracts expire.
The danger is that it sets the group up for being held hostage through collective or just coordinated bargaining by the renewing employees. In a situation in which it’s hard to replace one or two physicians with not just suitably trained but suitably brained others, it’s hell to replace twenty or thirty or a hundred and thirty of them at the same time.
Stagger the renewal dates of your employees’ and subcontractors’ contracts.
Unlike Costco or Amazon, you’ve got nothing to make up on volume on your Black Friday. |
| | | Tuesday - You Can Outsource the Task but You Can't Outsource Responsibility - Success in Motion
Watch the video here, or just keep reading below for a slightly polished transcript:
Whether you are an office-based practitioner, a hospital-based practitioner, it doesn’t make any difference. If you’re billing and collecting and whether you’re doing that in house, or whether you’re delegating to a billing service, the story is the same. You can delegate those tasks but you can’t delegate the responsibility to stay on top of what those who are supposed to be doing, are actually doing.
Group leaders are often shocked to discover that they have a significant collection issue. It might be accounts that should have gone to collections but didn’t go. It could be accounts supposedly in collections, but in limbo, and not worked. Or, and it's a big issue, it might be accounts that have been closed as paid, but with an unwarranted or incorrect contractual adjustment.
Although there's an issue of third-party billing service and collection agency liability, let's focus on the simple fact that these instances are a reminder that out of sight, can’t be out of mind when it comes to your bottom line.
If you don’t have someone in your practice who is on top of collections, you’re making a major management mistake.
If you’ve been making that mistake, stop it.
If you haven’t been making that mistake, well, look how smart you are. |
| | Wednesday -Why Free* Doesn’t Mean Free - Medical Group Minute
Watch the video here, or just keep reading below for a slightly polished transcript:
I was driving when I saw the sign, one of those large plasticized canvas ones, tacked up on the side of a small office building:
"FREE* First Chiropractic Visit"
But unlike the asterisk we're used to seeing, the one that matches with some terms found at the bottom of an advertisement, this one just stood there. Solitary. Telling every passerby that the sign was a . . . lie. That the chiropractor was a liar. That he can't be trusted because there's a catch, one that you're not even being told about.
What's the first thing that you're telling the people that you deal with? Not just patients but colleagues and potential deal partners?
Note that the communication needn't be in writing or even spoken. It might just be an action or even inaction.
The chiropractor was telling me and everyone else driving by that he can't be trusted.
Free* isn't free.
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| | | Listen to the podcast here, or just keep reading for the transcript.
Years ago, I was able to wipe a traffic ticket from my record by attending something billed as, as I recall, “comedy club traffic school.”
So, who says healthcare compliance stories can’t be funny?
We all know the expression “life imitating art”, but hardly anyone talks about “crimes imitating compliance”. That is, until today.
On June 8, 2023, a federal jury convicted the chief compliance officer of a pharmacy holding company, Steven King (yes, it would be funnier if his name were spelled “Stephen”), for fraudulently billing Medicare over $50 million for dispensing lidocaine and diabetic testing supplies that Medicare beneficiaries did not need or want.
The scam, which King and his co-conspirators ran through A1C Holdings LLC, involved pharmacies in multiple states. When A1C secured prescriptions and refills on behalf of its pharmacies for medically unnecessary lidocaine and diabetic testing supplies, it violated Medicare and pharmacy benefit manager rules.
Did the company hire King to keep them on the straight and narrow . . . but he strayed? Or did they hire him because they thought he knew how to run and, so they thought, conceal a scam? I have no idea.
However, the jury believed that King and his confederates ran and then took steps to conceal their scheme, including enrolling their mail order pharmacies as brick-and-mortar retail locations to evade more rigorous oversight, shipping prescription refills for high-reimbursing medications and supplies without patient consent, concealing the ownership of A1C Holdings LLC and its pharmacies, and transferring patients among pharmacies without patient consent.
As the DOJ put it in their press release: “King and his co-conspirators took each of these steps to ensure that Medicare continued to be billed for profitable medications and supplies. As chief compliance officer, King was in a unique position to prevent and report the fraudulent scheme, but he used his position to defraud Medicare instead.”
As I’ve mentioned many times on the blog, medical groups and facilities often create whistleblowers – their own compliance officers and other executives flip on them with regularity. Steven King flipped the entire thing on its head. And, as a result, he faces a maximum penalty of 20 years in prison on his conviction for conspiracy to commit health care fraud and wire fraud.
Although Mr. King served us a heavy slice of schadenfreude, just as compliance, actual compliance, is far more than a compliance plan, he also showed us that compliance is far more than having a chief compliance officer. In fact, sometimes it’s the complete opposite.
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| | | | We all hear, and most of us say, that the pace of change in healthcare is quickening. That means that the pace of required decision-making is increasing, too. Unless, that is, you want to take the “default” route. That’s the one is which you let someone else make the decisions that impact you; you’re just along for the ride. Of course, playing a bit part in scripting your own future isn’t the smart route to stardom. But despite your own best intentions, perhaps it’s your medical group’s governance structure that’s holding you back.
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| In fact, it’s very likely that the problem is systemic. The Medical Group Governance Matrix introduces a simple four-quadrant diagnostic tool to help you find out. It then shows you how to use that tool to build your better, more profitable future. Get your free copy Free.
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| | | | Whenever you're ready, here are 4 ways I can help you and your business:
1. Download a copy of The Success Prescription. My book, The Success Prescription provides you with a framework for thinking about your success. Download a copy of The Success Prescription here.
2. Be a guest on “Wisdom. Applied. Podcast.” Although most of my podcasts involve me addressing an important point for your success, I’m always looking for guests who’d like to be interviewed about their personal and professional achievements and the lessons learned. Email me if you’re interested in participating.
3. Book me to speak to your group or organization. I’ve spoken at dozens of medical group, healthcare organization, university-sponsored, and private events on many topics such as The Impending Death of Hospitals, the strategic use of OIG Advisory Opinions, medical group governance, and succeeding at negotiations. For more information about a custom presentation for you, drop us a line.
4. If You’re Not Yet a Client, Engage Me to Represent You. If you’re interested in increasing your profit and managing your risk of loss, email me to connect directly. |
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