10 ways to strengthen your medical practice strategic plan

A strategic plan is not just a document written by physicians and managers and then filed away for safekeeping. It is a vision for the practice, owned by the practice.


For a medical practice to succeed, everyone must engage with and live and breathe the plan. Strategy should inform your operations, your structure and how you go about practicing medicine. Your strategic plan should be the pillar against which you assess your priorities, actions and performance. As such, it’s mission critical that your plan is comprehensive and up-to-date.

Here are 10 questions to assess your strategic plan:

1. Will your strategy beat the market?

Each year, perform a thorough analysis to get a clear picture of how the competing forces in your specialty are likely to play out. To grow at an accelerated pace, you will need a meaningful point of difference that can’t be easily copied or nullified. Mindlessly copying another practice’s business model is not a strategy — it is a recipe for mediocrity. Do you really have a winning strategy?

2. Do you have a sustainable competitive advantage?

How will you make money in the future? Do you have a unique strategic position, a concept that you “own” in the minds of your target patients? Do you have special capabilities that can’t be easily copied? Remember that nothing lasts forever, so you need to focus on advantages for both today and tomorrow.

3. Are you focused on a clearly defined target?

Push for the narrowest possible segmentation of your target market. You need to aim for the bull's eye to hit the target. Clearly defining and understanding your target market of patients and referring physicians is one of the most powerful things a practice can do to improve its strategy.

4. Does your strategy put you ahead of the trends?

Many strategies place too much weight on current trends. But as the founder of modern management Peter Drucker said, it is not the trends, but “the changes in the trends” that leaders must stay current with. These changes often creep up so slowly that most practices fail to act until it is too late to mount an effective response, let alone take advantage of it. They are held back by sunk costs, an unwillingness to cannibalize a legacy business or an attachment to yesterday’s formula for success.

Instead, you should always look to the edges. How are your patients shopping for healthcare? What are the innovative new entrant competitors doing? What innovations could change your entire specialty?

5. Does your data give you privileged insights?

It is easy to be overwhelmed with data. The key is to make sense of it all and obtain actionable insights. Do you really understand your patients? Your referring physicians? Your competition? Practices that go out of their way to experience the world from their patients’ perspective will develop better strategies. The same exercise in perspective applies to your referring physicians and competitors, too.

6. Does your strategy embrace uncertainty?

Prioritize all your current threats, or things that could derail your strategy, as part of your annual SWOT analysis (Strengths, Weaknesses, Opportunities, Threats). Consider what action you would take if these worst-case scenarios came to fruition. Could you handle it? Do you have a contingency plan ready to implement?

7. Does your strategy require commitment and trade-offs?

Hedging your bets is not a strategy. A full commitment to a defined course of action is the only path to a sustainable competitive advantage. This requires trade-offs, as you can’t be all things to all people. Remember to consider what you are NOT going to do and accept those self-imposed limitations to stay focused on long-term success.

8. Is your strategy contaminated by bias?

Confirmation bias refers to a tendency to cherry-pick information that confirms existing beliefs or ideas. The best way to avoid this is to ask an outside consultant to facilitate your strategy discussions. That individual has no emotional ties to your practice and will instead lead a rational discussion on your strategic plan’s viability.

9. Is your leadership team fully committed?

Many good strategies and change initiatives fail to be executed because of a lack of commitment among the owners and practice administrators. Just one or two nonbelievers can halt a strategic change. Sell leadership on the plan early on so they can help sell the mission to other employees.

10. Have you translated your strategy into a one- or two-page summary?

Capture your key decisions on a very short document so that everyone in the practice can clearly see where your practice is going, how you plan to get there and what specific actions they need to take to play their part.

Strategic planning provides a practice with a real and lasting competitive advantage when treated as a work in progress rather than as a binder on a shelf or a file in a computer. A living strategic plan will help direct the business to where you and your partners or advisers desire it to go.

Spending time to invest in the future will result in a clear focus, a sense of joint purpose and agreed-upon priorities, consensus among stakeholders, and a basis for measuring progress and impact. Strategic planning is your practice’s road map to that shared vision. Are you ready to get started?

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5 Tips to Help Speech, Occupational and Physical Therapists Get Paid

Ensuring accurate reimbursement is no small task for today’s speech, occupational, and physical therapists. Billing codes are updated annually, payer requirements change frequently, and out-of-pocket costs for patients continue to increase. It’s the perfect storm of challenges that can make or break your busy therapy practice.


The good news is that there are several ways in which therapists can protect the revenue they generate. Following are five tips to consider in 2019 and beyond.

1. Know whether you’re required to participate in the Merit-based Incentive Payment System (MIPS).

Starting in calendar year 2019, speech, occupational, and physical therapists became eligible clinician types. This means these therapists are now required to participate in MIPS if they see more than 200 unique patients with Medicare Part B and provide at least 200 Part B-covered professional services totaling more than $90,000 annually.

Therapists who are required to participate—but fail to do so—will see a seven percent payment reduction for Medicare Part B services starting in 2021. Alternatively, therapists could earn up to a seven percent bonus for favorable participation. Use this resource from the Centers for Medicare & Medicaid Services (CMS) to verify your participation status.

Nancy Rothenberg, vice president of PTPN, provides several tips to help speech, occupational, and physical therapists achieve success under MIPS:
Use an electronic health record (EHR) that will allow you to submit relevant quality measures to the registry or qualified clinical data registry (QCDR) if you intend to use either of these data submission methods. Note that any practice can use these methods, but large practices (i.e., those with more than 15 therapists) are required to use one or the other.

• Retain documentation of improvement activities in the event of an audit.
• When reporting quality measures, be sure to include the correct ICD-10-CM, CPT, and CPT II codes on the claim or when submitting data to the registry or QCDR. These codes are what trigger the quality measure and include or exclude that measure in the reporting process. If you outsource your billing, ensure that your billing company is aware of these codes and reports them appropriately.
• Review any feedback that CMS or the vendor submitting data on your behalf provides, and make operational adjustments as necessary. This feedback is an important source of information that can help you achieve bonus payments and avoid penalties.

2. Know how changes to the Affordable Care Act could affect your practice.

Starting this year, individuals are no longer penalized for failing to obtain healthcare coverage, which means some of a therapist’s patients could move into a true ‘self-pay’ status, says Aimee Heckman, healthcare business consultant at Ease RCM Solutions. Best practice is to verify eligibility before each visit, and collect payment at the time of service, says Heckman. This is true for all patients—including those with insurance—and especially those with high deductible health plans.

Collecting at the point of service is always critical, but it’s especially important during the first few months of the year when deductibles reset, and most patients essentially become self-pay, she adds. Given the volume of services that therapists render, charges can add up quickly. Once a patient receives services and leaves without paying, the chances of collecting that money decreases significantly.

3. Don’t forget to monitor payer denials.

Nobody wants to spend time looking at denials; however, the reality is that denial management is an essential step in terms of mitigating future revenue loss, says Heckman. Look at the remark code for each denial. If possible, correct the error and resubmit the claim. Be sure to address the root cause of the denial so you don’t continue to lose revenue.

4. Review your fee schedules, renegotiate contracts.

Look at the fee schedule for the top five to 10 CPT codes you billed in the last 12 months. What’s the average charge vs. payment for each of these codes by payer? Doing this helps identify your lowest vs. highest paying payers. Leverage your value and what you bring to the table in terms of care quality and cost reduction, says Heckman. Don’t be afraid to walk away if the payer won’t budge, she adds. 

 

5. Provide patients with a variety of payment options.

The days of sending a bill in the mail and expecting to receive a check a few days later are long gone. Instead, patients expect the same bill pay conveniences they experience in other non-healthcare industries, says Heckman: Credit/debit card on file, online payment, and mobile app-based payments. The more options you provide, the more likely you will be to collect the revenue to which you’re entitled, she adds.

Helpful Resources

Centers for Medicare & Medicaid Services: https://qpp.cms.gov/
American Physical Therapy Association: http://www.apta.org/MIPS/
American Speech-Language-Hearing Association: https://www.asha.org/practice/reimbursement/medicare/the-medicare-quality-payment-program/
American Occupational Therapy Association, Inc.: https://www.aota.org/Practice/Manage/value.aspx
Support for small, underserved, and rural practices: https://qpp.cms.gov/about/small-underserved-rural-practices

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The Executive Suite: How to add more care to your treatment

The Executive Suite: How to add more care to your treatment: Physicians are by nature compassionate people. But sometimes life can get in the way of the ability to consistently exhibit care, cand...

How to add more care to your treatment

Physicians are by nature compassionate people. But sometimes life can get in the way of the ability to consistently exhibit care, candor, and concern. A squabble with a neighbor can present as short-temperedness with a colleague just as easily as a poor diet can lead to brain fog and subsequent frustration with a patient. Not only that, but the pressures of a busy practice can be brought home, contaminating the atmosphere of a practitioner’s personal life.


It takes effort to establish and maintain balance between the myriad avenues we walk in life. And while one area, such as work, can be mentally demanding, another area, like staying in shape or raising a family, can be physically taxing to the same degree.

Every component of day-to-day life is interrelated, which is why it’s essential to pay equal attention to your personal, professional, and public priorities. Here are six categories of care that will ultimately enhance the treatment you provide to your patients.

1. Care for yourself

Your personal wellness impacts your patients’ treatment and your staff members’ productivity. If you’re emotionally spent, physically sick, or psychologically stressed, your patients and colleagues will probably suffer some kind of consequence. Though the effects may be subtle, like having them feeling rushed or unheard, your attitude can infect their experience.

The first order of business is to manage your physical and mental health. Make sensible dietary choices, schedule time for pleasure and exercise, and unwind every day through meditation, reading, music, or a hobby. Patients and staff see you as a role model, which is why it’s vital for you to demonstrate healthy habits.

2. Care for family and friends

The people you surround yourself with need you to be present and pleasant. Even though your hours may be long and unpredictable, choose to participate fully when you’re in the company of those who matter most.

Sadly, the busier we are the more likely it is that our family and friends take a back seat. Your loved ones need your support and care as much as you need theirs. Do what you must to carve out time to honor and enrich your personal relationships.

3. Care for your community

Doctors are commonly viewed as pillars of the community. As I noted in this article, you have influence and you’re being watched. Given that neighbors, shopkeepers, and casual acquaintances tend to look up to you, it’s important to be mindful of your behavior in public. Take the lead by accepting your position with pride and representing your role in the community with responsibility and respect.

Another observation tower is social media. We all know that online privacy is a thing of the past. To loosely quote law enforcement, anything you post can — and very possibly will — be used against you. Caution is advised.

4. Care for your staff

Everyone who works in your practice, from your booking clerk to your physician assistant, benefits from your care and attention. They are, after all, the people who keep you organized and able to cope. Ensuring job satisfaction for them guarantees a healthy practice for you.

It’s up to you to establish the tone of your workplace. When cultivating the character of your practice, start with a foundation consisting of these four elements: inclusivity, positivity, efficiency, and civility. Have open, multilateral lines of communication and be fair when offering feedback to your staff. If you want to see real change, start sharing three sincere compliments per day and watch the attitude among your colleagues shift.

5. Care for your workplace

The environment you work in plays a huge role in your career contentment. If worn-out furniture, outdated equipment, peeling paint, and close quarters surround you, consider modernizing the office. A few simple décor updates can make all the difference in how everyone feels when they enter the space.

If you’ve outgrown your current office, either physically or mentally, it may be time for a change. Sometimes moving on is the only way to answer your soul’s call for calm over the chaos you may be experiencing at your present place of work. Pay attention to your yearnings.

6. Care for your patients

Now that you, your people, and your atmosphere have been attended to, you’re in the perfect position to offer the best treatment for your patients. Not only are you better able to provide your full attention, but having your core needs and responsibilities managed means you’re much better able to help manage theirs.

Regular patients will notice even the smallest improvements in attitude and design. And when you take the time to focus on self-care, patients new and old are sure to realize they’re in good hands.

Never underestimate the value of tending to your own care first. When you do, your family, friends, colleagues, and patients will thank you for it.

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The new Anti-Kickback Statute that most Medical practices don’t know about

Is your practice compliant with The Eliminating Kickbacks and Recovery Act of 2018 (EKRA)? If you are asking, “What is the EKRA?” you are not alone—and that is part of the problem.


EKRA is part of the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT for Patients and Communities Act) that President Donald Trump signed into law Oct. 24, 2018.

On the surface, EKRA may appear to be just a rehash of the federal Anti-Kickback Statute that applies to a subset of behavioral health service providers. However, EKRA’s broad definitions of a “healthcare benefit program” and “laboratory” makes the law potentially applicable to almost all physician practices and clinical laboratories.

As its name infers, the EKRA and SUPPORT for Patients and Communities Act was initially intended to be centered on behavioral health services, specifically the problem of “patient brokering” at certain treatment centers, usually in the area of addiction treatment. This means a third party enrolls a patient who needs addiction treatment into a private health insurance plan and then coordinates the patient’s entrance to a treatment facility in exchange for a payment, or kickback. Since commercial insurance is not subject to the federal Anti-Kickback Statute, and many states have little or no additional state level protections, patient brokering has become a widespread practice.

EKRA was drafted to combat this problem and protect a potentially vulnerable patient population. EKRA mirrors language in the Anti-Kickback Statute that specifically prohibits knowingly and willfully soliciting, offering, paying, or receiving anyremuneration in return for referring a patient or patronage to a recovery home, clinical treatment facility, or laboratory. (See 18 USC (a)(1) & (2)). Penalties for each occurrence of violating this law include fines up to $200,000, imprisonment for no more than 10 years, or both.

Most physicians who are not actively involved in behavioral health may not have much interaction with recovery homes or treatment facilities. Physician practices, however, inevitably have countless interactions with laboratories, which the statute defines as to have the same meaning as used in the Clinical Laboratory Improvement Amendments (CLIA). As such, the statute’s prohibition applies to any remuneration associated with any referral for such services, whether or not the laboratory test is related to addiction treatment or recovery.

Furthermore, EKRA is not limited to only federal healthcare programs, such as Anti-Kickback Statute and Stark Law. Rather, the statute applies to any “healthcare benefit program,” defined as any public or private medical benefit plan or contract, i.e., all commercial insurance plans. This is a significant expansion of federal law from what has historically only been subject to state level oversight.

Similar to the Anti-Kickback Statute, EKRA also grants some statutory exceptions to permit certain relationships. These exceptions mirror a number of Anti-Kickback Statute’s safe harbors, including discounts, personal services, and management contracts. However, there are some notable exceptions.

Most importantly, unlike the Anti-Kickback Statute that provides a safe harbor for any amount paid by an employer to an employee with whom there is a bona fide employment relationship, EKRA only exempts compensation when the employee’s and independent contractor’s reimbursement does not vary by the number of individuals referred, the number of tests or procedures performance, or the amount billed or received. (See 18 USC, 220 (b)(2)). As such, the limitations on compensation for independent contractors and employees are essentially the same.

This is dramatic shift from the precedence under the Anti-Kickback Statue that generally allows commissions or percentage-based compensation to employees but not independent contractors. Physician practices and clinical laboratories, as a result of this new ban, will need to re-evaluate their compensation methodology for employees and referring physicians to ensure such reimbursement complies with the EKRA’s more stringent requirements.

For example, physician practices who self-refer to their own laboratory will now, in addition to Stark Law, need to ensure their compensation to employed physicians will not vary based on the number of referrals. Similarly, clinical laboratories will be prohibited from paying their marketing employees on a commission basis. This applies even if physician practices and clinical laboratories have taken steps to ensure they are not treating patients covered by a federal healthcare program. EKRA expressly applies to all health plans.



We must wait and see whether this significant expansion of prohibited conduct, which is well beyond the targeted behavioral health industry, will be limited by Congress or whether future regulations promulgated under this law will provide additional safe harbors. In the meantime, since EKRA is now in effect, physician practices and clinical laboratories need to be attentive to and ensure their operations are in compliance with this new law.

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