Healthcare provider compensation restrictions (% of collections)

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July 05, 2020

by a searcher from Drexel University in Denver, CO, USA

Searchers with Healthcare experience:

Seeking a document outlining Stark and/or other limitations to productivity-based compensation for physicians.
Would love to go in and set every doc to a % of their collections but have been advised that this may be non-compliant in some areas.

Does anyone have anything like this?
Specific to medicare, M'caid, Tricare, & Commercial

For non-heatlhcare folks- salaried/ per-diem compensation is the most common trojan horse in all of healthcare when it comes to providers but it's also the easiest to execute compliantly.

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Reply by a searcher
from Villanova University in York, PA, USA
Paying providers a productivity % of collections (otherwise known as net revenue) is standard across plenty of healthcare service lines. I have not heard of groups paying different %s based on the type of payor/insurance type. I'd reach out to a healthcare attorney as a rule of thumb when doing physician contracts just to be safe.
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Reply by a searcher
from The University of Michigan in Chicago, IL, USA
I've worked with Provider Enterprises across several states and almost all have some form of productivity incentive in their provider comp plans. It can change by specialty and often goes along some base amount with other incentives for quality, outcomes, VBC, etc. depending on the org's strategy. The productivity comp structures are usually based on some $ per wRVU. Look at the average reimbursed per wRVU for that clinic / speciality based on their payor mix and then pay providers some percentage of that (make sure you cover overhead and other costs). Pretty standard practice for the industry so wouldn't expect any regulatory concerns. The Stark concerns are more about bonusing in network referral and getting payment for any downstream services, shouldn't be concerned about bonusing on services provided though
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