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Critical Issues to Consider When Exploring the Sale of Your Practice

Given the heightened level of interest in acquisitions of independent anesthesiology groups, physician shareholders are being confronted with a myriad of questions. Many are finding that anesthesiology groups in the local region are being acquired by larger medical groups. What should their practice do? What would be the value of their practice if ...
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MACRA Flexibility for Anesthesia Providers: Set Your Own Pace in 2017

The clinician community—anesthesiologists and nurse anesthetists included—breathed at least a partial sigh of relief last week. The Centers for Medicare and Medicaid Services (CMS) announced that clinicians would not suffer financial penalties in 2019 based on their performance in 2017 under the new Quality Payment Program (QPP) that implements the...
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Advice For Strengthening Your Board

Effective anesthesiology group governance is no longer a luxury but instead an important survival skill. Why?

  • The external environment is threatening— changes in reimbursement, threats from competitors, hospital consolidation—all add up to the need to make decisions, change and adapt.
  • The internal dynamics of many groups are challenging—getting “the entire herd roughly moving west,” dealing with disruptive physicians, developing an agreed upon group strategy—all require a well organized governance system.

Whether your group’s Board includes all the shareholder physicians, or you have chosen a subset of the shareholders to serve as the Board, there are a number of steps that you can take to strengthen your Board’s performance. Here are several of the most important steps that an anesthesiology group Board can take.

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News Anesthesia Practices Can Use: Costs of Care, Opioid Abuse, Green Practices and More

Join the Conversation on Cost Do you have an idea for using improvements in quality to drive reductions in the cost of care?  Has your practice tried something that worked?  Share it. Clinicians and financial managers have plenty of innovative ideas for reducing costs, but these ideas rarely percolate into the public sphere. To change that, Neel Shah, MD, MPP of Harvard Medical School has founded a non-profit organization called Costs of Care to facilitate idea-sharing and learning among healthcare professionals.  Costs of Care sponsors a learning network and a Creating Value Challenge for clinicians, and offers a COST (Culture, Oversight, System support, Training) framework to help clinicians understand and implement high value care interventions in their practices and institutions.   According to Dr. Shah, who spoke at a recent Hospitals and Health Networks webinar, “The New Conversation on Cost,” healthcare organizations need a strategy for reducing costs that combines the insights...
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Addressing Disruptive Behavior in Anesthesia Group Practices

Stress is a part of life for all of us, and anesthesiologists have more than their share in a practice environment where rules seem to shift from day-to-day as the burden of paperwork and performance measurement increases and financial rewards are diminishing or put at risk. Add this to the already daunting pressures associated with long hours in the surgical suites and on-call responsibilities, and it is no wonder that patience wears thin from time-to-time. I have been impressed throughout my career with the manner in which the vast majority of anesthesiologists handle this pressure, but have also seen a few situations where the pressures resulted in behavior that was detrimental to patient satisfaction and/or the reputation of the group. All of us have had times where stress in our personal or professional life has caused us to act or react in a way that we later find regrettable, but for...
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Pharmacogenomics in Anesthesia Care: Is It Time for Your Practice?

The premise is elegant in its simplicity:  The more information you have about a surgical patient’s biology, the greater your ability to tailor anesthesia medication appropriately for that patient and lower their risk of an adverse drug reaction (ADR), longer hospital stay or hospital readmission, and the better and more cost-effective the overall quality and safety of your anesthesia care. It’s an approach that clinicians, scientists and President Obama, through his administration’s Precision Medicine Initiative, hope can be used routinely one day to spare surgical patients from unnecessary risks and complications.  A personalized approach to anesthesia care such as this could also enable anesthesiologists to add value to their institutions and practices as perioperativists, yielding benefits for health systems, payers and, ultimately, society as a whole. Pharmacogenomics, a cornerstone of medical science’s movement toward personalized medicine, uses genetic data to guide drug development and testing and help physicians select the proper medication...
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The Perioperative Surgical Future

“I look upon ourselves as partners in all of this, and that each of us contributes and does what he can do best. We can create ourselves and our future.” – Jonas Salk, 1985 Presented with this opportunity by Dr. Salk, how will each of our anesthesia groups create its own future? How will you as a physician maintain your professional relevance? Will you continue to commit yourself to fading traditional practice patterns and reimbursement models? Or will you take advantage of the paradigm shifts in medicine that are already upon us? Payers are demanding better results, hospital administrators are in need of help, patients are in the middle without access and the specialty of anesthesia needs a tune-up. The perioperative surgical home promises to address it all. Led by the Centers for Medicare and Medicaid Services (CMS), payers are mandating coordinated care and improved quality through pay-for-performance reimbursement models. CMS...
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Anesthesiologists: Battle Burnout and Rediscover Meaning

The developers of the Maslach Burnout Inventory define physician burnout as “an erosion of the soul caused by a deterioration of one’s values, dignity, spirit and will.”  Some suggest its relative absence should be considered a measure of quality.  No matter how one defines it, it is not a good thing—for physicians, care teams, practice management professionals, patients or healthcare organizations.  As the data show, anesthesiologists unquestionably suffer from it right alongside their peers in other specialties. U.S. Surgeon General Vivik Murthy, MD puts it well in explaining why physician burnout is a serious problem:  If healthcare providers aren’t well, it’s hard for them to heal the people for whom they are caring.” While the phenomenon is far from new and has been extensively studied, recent research confirms that physician burnout is widespread and growing.  In a Mayo Clinic survey of more than 6,200 physicians, 54.4 percent reported at least one symptom...
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OIG Advisory Opinion Secrets and Strategies

[Author’s Note: This article is based on my presentation at the 2016 Advanced Institute for Anesthesia Practice Management.] The OIG Advisory Opinion (Advisory Opinion) process allows parties of actual or proposed transactions to obtain the opinion of the Office of Inspector General (OIG) of the U.S. Department of Health & Human Services as to whether that transaction violates the federal Anti-Kickback Statute, 42 U.S.C. § 1320a-7b(b) (AKS). There’s an official process for obtaining an OIG Advisory Opinion. Then there’s the actual way that the process works. And, then there are the secrets and strategies that can be used in connection with opinions. For decades, I considered Advisory Opinions as a set of guideposts as to how the OIG, as the primary agency charged with enforcing the federal AKS, thinks as to the application of that statute. But then I realized that there was a very different way to think of them,...
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A Refresher for Anesthesiologists on Avoiding Fraud and Abuse

An anesthesiologist recently received a several-year prison sentence for prescribing controlled substances without a legitimate medical reason. One of this physician’s patients died from taking hydrocodone, which the physician had prescribed for no legitimate medical purpose. This is an extreme case involving criminal behavior. Still, any allegation of Medicare or Medicaid fraud or abuse surely ranks at the top of an anesthesiologist’s—any physician’s--list of nightmare scenarios. It behooves anesthesiologists, as well as nurse anesthetists and anesthesia practice managers, to know the “red flags” of fraud and abuse that could lead to civil, criminal or enforcement liability. Failure to understand current laws or how to take the appropriate steps could expose you to risk without your even realizing it. Did you know, for example, that the Affordable Care Act (ACA) requires physicians to establish a compliance program and to designate a compliance coordinator in their practices? Or that the ACA established an Open...
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Collecting Dilemma of Anesthesia in 2016

When most practice administrators started in anesthesia billing operations, collecting for services was markedly different than it is today, even if you are relatively new to the special. There are a variety of factors including government regulations, The Patient Protection and Affordable Care Act of 2009 (ACA), bundled payments, high deductible health plans, out-of-network payers and new plan designs, to name a few. The Patient Protection and Affordable Care Act “THE GREAT RACE TO THE BOTTOM” The Patient Protection and Affordable Care Act (ACA), or the ‘Great Race to the Bottom’ as some have coined it, brought massive change to the insurance market. Since the signing of this 2,000- page law in March of 2010, thousands of pages of regulations have been written and implemented. Moreover, additional regulations are on the way as the law gave the Secretary of the Department of Health and Human Services vast latitude to implement the...
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HIPAA Helps Keep Hackers at Bay: Hints for Anesthesia Providers

We would like to say it isn’t so, but ransomware attacks haven’t tapered off; they’ve soared.  So far in 2016, ransomware attacks have risen 300 percent since 2015 (from 1,000 to 4,000 attacks daily), according to a government report.1  The healthcare sector—anesthesia providers included—is especially vulnerable. More than half of hospitals responding to an April survey by the Health Information and Management Systems Society (HIMSS) and Healthcare IT News reported that they had been attacked by ransomware in the previous year.  An additional 25 percent of hospitals said they were either unsure whether they had been attacked, or had no way of knowing.  When it comes to data security, healthcare still lags far behind other industries, including banking and high-reliability fields such as nuclear energy, power utilities and aviation. This susceptibility makes hospitals and practices prime targets for hackers.  Personal health information is 50 times more valuable on the black market...
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Thinking About Medical Errors

Press releases following a recent publication in the British Medical Journal (BMJ) hysterically echoed the article’s headline: “Medical error—the third leading cause of death in the U.S.”1 The authors used a variety of published sources on the incidence, lethality and preventability of medical errors to produce an estimate of 251,000 deaths per year attributable to medical error, out of a total of about 2.6 million. As a cause of death this would rank behind only heart disease (611,000) and cancer (585,000). While the purpose of the authors was to advocate for improved coding of the cause of death in vital statistics, the purpose of the commentary was to alarm the public regarding the current state of healthcare. Should we panic? I think not. Here’s why: First, understand that I’m not a criminal or even an apologist. I hate medical errors and I have devoted my career to their eradication. We should...
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Anesthesia Practices: Check Your Compliance with the Section 1557 Final Rule

The final rule implementing Section 1557 of the Affordable Care Act, Nondiscrimination in Health Programs and Activities, offers important civil rights protections for individuals. Anesthesia practices should understand the final rule, train staff in its provisions (or check with their hospitals on their plans for doing so) and make sure they are on target to meet the final rule’s procedural requirements. An anesthesiology group decides not to provide labor epidural anesthesia to women with limited English proficiency (LEP).1 A nurse ignores an African-American woman in the ER who needs medical attention and makes her wait for an hour, but provides prompt attention to a white male who enters the ER after her. A hospital refuses to treat men with breast cancer because it believes doing so would make female breast cancer patients uncomfortable. As you’ve probably guessed, these scenarios illustrate examples of discrimination under Section 1557 of the Affordable Care Act...
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What Anesthesia Providers Should Know About the Opioid Crisis

SUMMARY The misuse and abuse of prescription opioids has become a serious public health problem in the United States and is a major factor in the recent increase in heroin addiction. Practices can help to curtail this problem by staying abreast of new developments and guidelines stressing the prudent use of narcotics. The death in April of the musician Prince from an accidental overdose of fentanyl is only one of the more highly publicized instances of a public health problem in the United States that has reached epidemic scale.  According to the Department of Health and Human Services (HHS), 44 people die every day in the U.S. from an overdose of prescription painkillers. A recent analysis of more than 800,000 prescriptions written in 2013 showed that pain specialists and anesthesiologists wrote the most opioid prescriptions of any group of healthcare professionals—an average per physician of 900 - 1,100 and 500 prescriptions,...
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VA’s Proposed Rule to Expand Nurses’ Practice Could Impact Anesthesia Specialty

SUMMARY The U.S. Department of Veterans Affairs (VA) has issued a proposed rule to allow advanced practice registered nurses to practice within their full authority at veterans’ hospitals across the country, preempting certain State laws prohibiting the practice. Although certified registered nurse anesthetists (CRNAs) have not yet been given the green light to furnish anesthetics, the VA continues to consider this issue. Introduction Few are unfamiliar with the general state of veterans and healthcare in our country. According to statistics recently released by the VA, an average of 20 veterans died from suicide in 2014. 1 Further, there is a backlog of nearly 500,000 veterans waiting 30 days or longer to receive care at VA facilities across the U.S. This is higher than the numbers from one year ago when reports were released that showed veterans dying while waiting for care as a result of the backlog. 2 In an...
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CMS Becomes Arch Nemesis of Hospitals with Plans for Site-Neutral Rates in Outpatient Payment Rule

Introduction To hospitals, the Centers for Medicaid & Medicare Services (CMS) is acting like the terrible Wicked Witch of the West from the movie the Wizard of Oz because of their proposed plans for site-neutral rate reductions. The proposed modifications in reimbursement are included in the 2017 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System (CMS-1656-P) proposal submitted on July 6, 2016. The law provides for payment system policy changes, quality reporting provisions, and reduced pay rates that many hospitals would prefer to douse with water and have them disappear like the Wicked Witch rather than have payments reduced at their off-campus facilities. CMS is proposing a number of policies they believe will improve the quality of care Medicare patients receive. A key piece of the 2017 proposed legislation is the implementation of Section 603 of the Bipartisan Budget Act of 2015, which will affect how...
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Negotiating Anesthesia Contracts Like a Pro

Prior to addressing the main topic of today’s alert, we felt it necessary to inform our readership of the recent proposed changes made by the Centers for Medicare and Medicaid Services (CMS) in its CY 2017 Proposed Physician Fee Schedule (PPFS). In the CY 2016 PPFS, CMS proposed reexamining the anesthesia codes reported in conjunction with colonoscopy procedures (i.e., 00740 and 00810) as potentially misvalued. In the CY 2017 PPFS, CMS continues to maintain that 00740 and 00810 are misvalued and it “look[s] forward to receiving input from interested parties and specialty societies for consideration during future notice and comment rulemaking.” Moreover, CMS notes that although sedation services are included in certain endoscopic procedures, that anesthesia is being separately reported. As such, “[i]n the CY 2017 PFS proposed rule, CMS is proposing values for the new CPT moderate sedation codes and proposing a uniform methodology for valuation of the procedural codes...
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ICD-10: Are You on Track?

The transition to the International Classification of Diseases and Related Health Problems 10th revision (ICD-10) appears to have gone well so far, despite widespread anxiety that it would wreak havoc across healthcare as providers struggled to comply with the new coding structure, heightened specificity and documentation requirements.  The Centers for Medicare and Medicaid Services (CMS) reports that total claims denials and other claims metrics remained essentially unchanged from the historical baseline to the fourth quarter of calendar year 2015. In a blog post, Andy Slavitt, CMS acting administrator, likened the healthcare industry’s anticipatory concerns surrounding ICD-10 to the Y2K information technology disaster that never took place.  “With preparation, planning, a focus on the customer, collaboration, clear accountability, and metrics, the dire Y2K fears didn’t come to pass.  Instead, ICD-10 became like what actually occurred on Y2K, an implementation and transition most people never heard about,” he said. So far, so good. Nonetheless,...
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What Anesthesia Professionals Need to Know About Medicare Revalidation

All physicians, group practices and other providers who participate in Medicare are required to resubmit and recertify the accuracy of their enrollment information every five years through a revalidation process. Section 6401 (a) of the Affordable Care Act established new screening requirements for providers; required them to be revalidated under those new requirements, and reinforced the revalidation regulations at 42 CFR §424.515.  The first cycle of enrollment revalidations ended as the second cycle began in March 2016. Required Actions Physicians and other clinicians must submit their revalidation applications by the last day of the month in which they are due.  Your Medicare Administrative Contractor (MAC) is expected to notify you of the due date within two to three months of your revalidation deadline, by email or by regular mail.  Generally, this due date will remain with you throughout subsequent revalidation cycles.  Centers for Medicare & Medicaid Services (CMS) also maintains a list...
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