Showing posts with label physician practices. Show all posts
Showing posts with label physician practices. Show all posts

Friday, January 21, 2022

Winning the battle for the click: A guide for physician practices

With paid ads and sponsored content dominating the Internet, generating organic traffic is harder than ever.

Paid search cost-per-click (CPC) rates increased 41% year over year in Q3 2021 as competition across channels picked up, according to one report. Further demonstrating this trend, a PwC report commissioned by the Interactive Advertising Bureau found that digital advertising spending grew 12.2% year over year in 2020.

Now, showing up on Page 1 of Google — which is worth its weight in gold — requires ample resources and know-how. Search engine optimization (SEO) campaigns and media partnerships must have the capacity to break through the noise, as the market is no longer characterized by the idyllic cycles of 2021, when pent-up demand for healthcare supported simpler, more organic digital marketing tactics.

Positioning for the future will necessitate that physician practices take more decisive actions to strengthen their arsenal of assets and get battle ready for both the forthcoming economic slowdown, and the rise of epic levels of competition among equally matched players.

Your assets = Your armor


No battle can be fought effectively without the right armor. In the battle for the click, small business’ web personas must be offensively strong (to stand out), and defensively tough (to keep competition from stealing the affections and intentions of prospective and current clients). The early adopter phase, where simply having digital assets was a differentiator, has come and gone.

Given this reality in 2022, most businesses will need digital assets that:
  1. Entice Internet searchers to “click” once they’ve found the business (e.g., a five-star-average rating, coupled with an updated listing, as well as a compelling summary)
  2. Pique users’ interest to explore further (e.g., website that is easy to navigate and supports appointment-booking, or links to patient testimonials).
  3. Persistently remind the user of the care and services available (through Google and/or Facebook ads, an email newsletter sign-up, a web chat feature on the home page or other sticky interactive content).


There are other factors at play influencing ranking and consumer perception. For example, physician groups that utilize best practices in SEO, or have a higher volume of Google reviews, are still more likely to rank higher in a search or query. The presence of optimized content, keywords used in meta tags and headings, and image quality also affect online rankings.

Mending your Achilles’ heel


Sometimes weaknesses in an organization’s web persona, or digital marketing activities, are obvious, such as a poor mobile user experience or dated content. These are easier fixes.

Other times the underlying root causes of poor online performance aren’t obvious.

For example, organizations that thought they employed SEO best practices might suddenly find themselves sidelined on Page 2. This could be due to changes in Google algorithms that influence ranking, or as simple as an increase in competitors across a particular geographic area. Finding the cause is sometimes downright perplexing and requires greater analysis.

Analytics platforms like Google Analytics can help organizations identify weaknesses, as well as strengths, such as which content generates the highest click-through rate. These platforms also offer a wealth of other insights, such as web impressions by audience type. What’s even better: Having an expert on hand who knows how to interpret data and leverage it to benefit the business (e.g., determine which actions or initiatives to prioritize).

Additionally, there are several actions that all small businesses (and larger ones) can take to elevate digital performance. The first is as simple as updating local online directories: Check to ensure all contact information is current and consistent across multiple directories (Yellow Pages, Manta, etc.). Conducting a basic keyword analysis is also a “low hanging fruit” tactic in that it ensures the most powerful keywords are emphasized in the web code tied to content assets such as blogs (there are also several free or low-cost online tools that can perform basic keyword analysis functions).

Every one of these actions helps an organization get into peak performance form — ideally positioned for the click.

And once you’ve won that click…


Don’t be the practice that “wins the battle but loses the war.” In other words, make sure your digital presence is sparkling. Consumers won’t shy away from clicking away from a website that doesn’t load, or a profile of a physician that hasn’t been updated in more than five years.

Keep in mind that the “battle for the click” is different than it was even two years ago — it’s always evolving.

Employing strong digital marketing tactics in all areas — from updating local directory listings to refreshing social media feeds and encouraging clients to leave positive online reviews online — is a constant, ongoing need. For those who are strapped for time, a third-party expert or digital marketing vendor partner can offer the right, budget-friendly tools and guidance small businesses need to attract and retain clients.

The more that healthcare providers can do now to improve their resiliency, web presence, and relevance in an ever-more-competitive world where every click counts, the stronger they’ll be throughout 2022 — when being click-worthy takes on a deeper meaning, and heightened significance.


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Thursday, November 11, 2021

Reminder: Important Stark Effective Date and Physician Group Practices

January 1, 2022 is just around the corner. On December 2, 2020, the Centers for Medicare and Medicaid Services (CMS) published new provisions and exemptions related to the Stark Law (85 Fed. Reg. 77492) and simultaneously, the Department of Health and Human Services – Office of the Inspector (HHS-OIG) published new provisions and safe harbors related to the Anti-Kickback Statute (AKS) (85 Fed. Reg. 77684). Having detailed several of the changes in a three-part series for Physicians Practice, there is one item that was not included in the January 19, 2021 effective date, which demands attention.

Before delving into the specifics of the new changes to the Stark Law, which become effective on January 1, 2022, there are a couple of important reminders concerning the Stark Law. First, unlike the AKS, Stark is not a law with both civil and criminal penalties. Stark is a civil statute. Second, it is important to appreciate what goods and services come under the umbrella of designated health services (DHS) – a term that is specific to the Stark Law. Finally, while there have been modifications to the writing requirement, they are specific and should be read closely. Bottom line is that they are still required – it’s the timing that is at issue. Having said that, I would never have a verbal agreement because of the potential compliance and litigation issues down the road.



By way of background, “[p]hysician group practices commonly rely on the in-office ancillary services exception (IOAS) to protect referrals for DHS among physicians within the practice or for ancillary services provided by the practice.” Practically speaking, so long as the practice satisfies the strict and nuanced requirements to be considered a “group practice” (42 C.F.R. §411.352), both the physicians’ ownership and compensation arrangements may be compliant with the Stark Law. As stated in 66 Fed. Reg. at 876 (Jan. 4, 2001),

Accordingly, the Congress permitted group practice members (and independent contractors who qualify as ‘‘physicians in the group practice’’) to receive shares of the overall profits of the group, so long as those shares do not directly correlate to the volume or value of referrals generated by the member or ‘‘physician in the group practice’’ for DHS performed by someone else. (emphasis added).

Subsequently, on 66 Fed. Reg. at 957 (Jan. 4, 2001), “overall profits” is defined to mean:
the group’s entire profits derived from DHS payable by Medicare or Medicaid or the profits derived from DHS payable by Medicare or Medicaid of any component of the group practice that consists of at least five physicians. The share of overall profits will be deemed not to relate directly to the volume or value of referrals if one of the following conditions is met:

(i) The group’s profits are divided per capita (for example, per member of the group or per physician in the group).

(ii) Revenues derived from DHS are distributed based on the distribution of the group practice’s revenues attributed to services that are not DHS payable by any Federal health care program or private payer.

(iii) Revenues derived from DHS constitute less than 5 percent of the group practice’s total revenues, and the allocated portion of those revenues to each physician in the group practice constitutes 5 percent or less of his or her total compensation from the group.

(iv) Overall profits are divided in a reasonable and verifiable manner that is not directly related to the volume or value of the physician’s referrals of DHS.

The changes in the definition of “overall profits”, which become effective January 1, 2022, are critical to a group’s ongoing compliance with the Stark Law’s permissible compensation models, as well as potentially avoiding a False Claims Act case. As of January 2022, “overall profits” was clarified to mean the profits derived from all DHS of any component of the group that consists of at least five physicians. “Split pooling” – the distribution of profits from DHS on a service-by-service basis – is expressly prohibited. The concern voiced by CMS on page 77563 of the Dec. 2, 2020 Final Rule related to comments received on “split pooling” was that “service-by-services profit shares would allow physicians to receive profits shares more closely related to the services they referred, their specialty, the services they provide, or the expenses they have personally incurred.”

Thus, beginning January 1, 2022, the “split pool” method of allocating DHS profits will no longer meet an exception. “Groups may segregate and allocate DHS profits generated by sub-pools or "pods" of at least five physicians and are permitted to use different profit allocation methodologies among the pods. However, within each pod, groups must use the same compliant methodology. Some examples of permissible methodologies include allocating DHS profits on a per capita basis or based on personal professional productivity (excluding DHS revenues).” Pursuant to the Stark Law’s Final Rule all revenue and expenses from all DHS service lines need to be aggregated and then distributed using the same methodology.


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