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Physician Compensation Management Process Health Ethics Trust Central Region Certification Intensive Course

August 6, 2013 1

Premier Health •  •  •  •  •  • 

Local system Not owned by a large corporation Primarily centralized management Big Board Compliance & Audit Committee Sole Compliance Officer aka individual heroics 2

What’s your goal? •  Do you know your endpoint? •  Do you have support from management? •  Do you have a sponsor? •  Have you identified an issue – what’s your “burning platform”? •  Can you demonstrate savings? 3

How to start… •  What do you already have in place?

(current state assessment) –  Is there a committee that can do the reviews? –  Existing review process – per Corporate Compliance policy for physician contract review –  Engaged internal executive committee (CCC) –  Focus – Anti-kickback and Stark in internal CCC meeting –  Dedicated CEO asking the right questions –  Very supportive in-house counsel –  Very persistent compliance officer 4

What’s next? Where do we have gaps? •  What is the goal of the CEO’s request? –  Design a physician compensation review process –  that meets (to the best of our ability) the IRS rebuttable presumption –  for executive compensation.

•  What are the standards of the IRS rebuttable presumption? •  What would the process look like if we reviewed 100% of the contracts? •  How do you make that manageable? •  Who approves the contracts? Who has the authority? •  What’s the appetite of the governing body?


Filling the Gaps •  Selection process on the contracts that should be reviewed •  •  •  • 

Outside counsel Tax expert Define “insider” Think of a funnel…..

•  Detailed review with key stakeholders •  What do they understand, what don’t they understand?

•  Determine approval authority – no matter how painful •  Better educate the internal committee (CCC) •  Educate the Board on their new function •  Ongoing education with each contract presented for review 6

Final Product •  Board approved process and delegated authority for approval •  Education of the Board required

•  “How to” notebook •  •  •  •  •  • 

Executive Summary Statutory Overview, flowchart Defined terms Defined benchmarks Specific guidelines for each type of contract Everything we could thing of related to a physician contract

•  Consistent reference to process when introducing a contract for review •  Support and reinforcement from in-house counsel and operations •  Overall willingness of senior management to understand and participate in the process •  Willingness of Board to be educated, conduct the review and ask questions •  Support from System Leadership – new step in our review process


Ongoing Review Does the process work? What have we missed? What needs changing? •  Internal with in-house counsel & compliance •  Compliance Tracking •  Report two times per year to CCC •  Report two times per year to Compliance & Audit

•  Corporate Compliance Committee-minutes, denoting approval/ conditions •  Compliance & Audit Committee-minutes, denoting approval/ conditions •  “Big” Board by way of C&A minutes •  Ongoing education regarding settlements with physician arrangements •  Discussion about a review process of another hospital or system •  Review and sign off by outside counsel •  Request review by Internal Audit 8

Words of Advice •  OVER communicate the “proposed” process •  Meet with everyone that will listen—even those that won’t

•  Who gets to vote? •  It’s best for them, it’s best for the process

•  A non-compliance champion •  Go slowly but keep moving – “Successive Approximation” •  Constant presentation of settlements – start your burning platform •  Compensation consultant 9


Dianne Dieterle Judge, MS Ed, JD System VP, Chief Compliance & Enterprise Risk Officer Premier Health 110 North Main St. Suite 930 Dayton, OH 45402 937.499.9794 10

physician compensation management process  

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