Dr. Bob, the group’s compliance officer, has HIPAA on his mind almost all the time, that is, when he’s not thinking about coding or Stark or the federal Anti-Kickback Statute.
Category: Future of Healthcare
Properly done, medical group management is neither a collaborative nor a unanimous process. It is a leadership decision.
As I’ve written before (for example, here) and as you’ve undoubtedly witnessed, medical care is shifting from a hospital and, in many cases, physician office, model to a consumer model. Walk-in clinics in markets and drug stores. Apps bringing nurse practitioners or physicians to one’s door. iPhones as diagnostic equipment.
Yet many medical group governing documents and physician-owned facility agreements contain provisions that are inflexible and destined to be breached (or deemed unenforceable) in light of change. Or, worse, destined to strap down your ability to thrive or even to function.
For example, depending on the entity and its purpose, scheduling provisions, restrictive covenants, and compensation models may be out of tune or stretched to the point of soon being so. Consider a provision that allows a group to determine at which hospital facility a provider will be scheduled during a calendar month, when you now want to schedule her to work at Mark’s Pharmacy or at Mark’s house.
Audit and update your strategies, structures and documents not simply in light of compliance and control, but in terms of focus, flexibility and the future.
No one knows exactly where the road to the future is heading, but the signs indicate that it’s away from where things have been. Do you want to go along for the ride?
Oh, yeah, about Main Street. The highway had bypassed the town.
Comment or contact me if you’d like to discuss this post.
Mark F. Weiss
Earlier this month, the FDA approved the first 3-D printed drug product, Spritam, developed by Aprecia Pharmaceuticals.
The layering process of 3-D printing allows Apecia to tightly package active ingredients in precise dosages.
A far more complex use of that technology is certainly not far behind. One that will open the door to mechanized compounding of drugs at patient-by-patient, individualized dosages: a customized 3-D printed pill for Mr. Smith and a different one for Ms. Jones.
For compounding pharmacists, the expansion of the use of 3-D printing technology will mean even more demand, whether on a small scale of production (i.e., a local pharmacy) or on a large one (e.g., a centralized facility filling hundreds of thousands or millions of prescriptions for individualized medications).
At the small scale end of this continuum, the move from large scale drug manufacturing to individualized drug compounding via 3-D printing is the equivalent of the morphing of the million dollar printing press into the laser printer or ink jet in your home office. It’s the dematerialization and democratization of drug manufacturing.
For physicians in states that either allow them to own interests in pharmacies or to dispense pharmaceuticals from their practices, the technology opens new doors to patient care and to profit.
Underlying all of this, for physicians and pharmacists alike, is the opportunity to do new types of deals with unique structures. That requires a new way of thinking. It also requires careful compliance with a host of regulatory issues, from the federal Anti-Kickback Statute to Stark to the Federal Food, Drug, and Cosmetic Act.
But those are just the problems on the route to outcomes that will be profitable for patients and profitable for providers.
Comment or contact me if you’d like to discuss this post.
Mark F. Weiss
I’ve written before about creating your own business disruption before someone else comes along and disrupts your business.
Google’s driverless cars have logged over 100,000 miles without incident. I don’t know how many car drivers will want to give up the control, but I’d bet that large trucking companies are doing the calculations.
So, I think it’s high time to re-brand non-profit hospitals. We should begin calling them non-taxpaying hospitals.
What story might you be telling, if even (no, especially) to yourself?
Recent news reports have revealed that some non-profit hospital CEOs have received up to 40% increases in salary over the prior year, with some CEO’s compensation hitting the $3 million mark.
Have you made this same mistake? Either by taking a job with idiot savants or, even worse yet, by building a medical group comprised of them?