Post Acute

HCCA: Compliance in the Post-Acute Environment

On Sunday morning, I attended the session “Compliance in the Post-Acute Environment”. Given that MD Ranger serves an increasing number of these types of organizations, I looked forward to learning more about compliance in this particular space.

The speakers first tackled the tough reality that, while compliance programs for post acute facilities have been mandated by ACA, we still don’t know the specific requirements of these programs. This presentation addressed how compliance officers in the post acute world can “predict” what the OIG and CMS will care about, and structure their compliance program and procedures accordingly.

Overall, it’s safe to say that many elements of an acute care organization’s compliance program translate on the post acute care side of the industry. The speakers emphasized the importance of an easy to understand code of conduct (or compliance policies), as well as a compliance officer that has the resources and authority to do her job. Sanction screening, internal monitoring, enforcement, and measures to address non-compliance were all important elements of post acute compliance programs.

Despite the fact that a lesser number of physicians are involved in post acute care, the speakers took care to mention that a thorough review of your physician contracts is essential to preventing risks like AKB violations or Stark violations. Reviewing agreements with all referral sources can help you document your compliance with federal regulations and ensure that all contracts are fair market value. Integrating physician agreements with your formal compliance program is key.  From our perspective at MD Ranger, we couldn’t have said it better ourselves. Because post acute care organizations are so heavily dependent on referrals from key physicians, documentation of FMV becomes even more critical.

Post acute organizations:  how do you handle physician contract auditing at your facilities?


Physician Contracting Tips for Post Acute Facilities

The Affordable Care Act mandates that all post acute care facilities have compliance programs.  The law also includes stronger penalties for Stark and Anti-Kickback violations.  Post acute administrators have no choice but to get prepared.

Given that time is of the essence, what’s the fastest way to find appropriate medical director rates?  What is the simplest way to document compliance?

High-quality market data is the most straightforward way to ensure that your physician contracts are fair market value.  Once you have chosen the best data or product for your facility, check where your current rates fall within the benchmarks.  If you are under the 75th percentile, you can document your rate as compliant.  If you are selecting rates, determine a market range that will work for your organization across facilities and positions.  Consistency is hallmark to a successful compliance program.

Need more help with physician contracting compliance?  Are you a post acute facility administrator?  Email me at This email address is being protected from spambots. You need JavaScript enabled to view it., and I’d be happy to speak with you about simple strategies to be prepared.


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