Practice Management

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  • 1.  Physician GAD Coverage

    Posted 06-29-2019 13:31
    One of the most frustrating requirements is to have an MD present during administration of GAD.

    Of course, in a hospital environment MD's are "proximate' to the MRI suite.

    However, in 26 years of business we have never had a negative reaction to GAD to the level that required medical assistance (MD present or our local EMT's).

    We have standardized on Dotarem which - in my opinion and that of my staff radiologists - is a an acceptable and very small risk.

    For our smaller members, eliminating this requirement (with our MRI techs full certified in CPR and emergency response) I feel confident that the risks are infinitesimal.

    Of course, a patient in rental failure, heart disease, etc. will be handled differently but this is a tiny portion of our patients who may be at risk.

    What to do if a patient has a bad reaction?

    Our MRI tech advises the doctor on premises who then WOULD CALL 911 FOR A QUALILFIED EMT!

    I am willing to take the risk - even at the increased expense of liability insurance which will be considerably less (six figures) from what we are presently paying for doctors onsite.

    Comments, Please!


    ------------------------------
    William Kisse
    COO
    Washington Open MRI, Inc.
    Rockville, MD
    bill@womri.com
    (301) 424-4888
    https://www.linkedin.com/in/billkisse/
    ------------------------------


  • 2.  RE: Physician GAD Coverage

    Posted 06-29-2019 17:55

    William,

    You seem well acquainted with the rules, but please allow me to review some of them for discussion purposes, and then I'll express some personal opinions. 

     

    CMS rules requiring a physician to be immediately available for all procedures requiring Direct Supervision, which covers any study during which IV contrast is injected.  Gad is an IV contrast and therefore falls into this category.  Direct Supervision can only be provided by an M.D. or D.O. - PA's and NPs can't provide the supervision.  Generally speaking, any M.D. or D.O. can provide it.  Having said that, some Medicare Administrative Contractors have established policies for IDTFs that only allow Radiologists to provide the supervision, and will not allow non-rads to provide it.  That is within their purview.    I've not heard of MACs limiting supervision to rads in non-IDTFs (i.e., physician offices), but I've not really taken the time to research it, either.  On a related note, I personally always extended Medicare rules to to all government payers when establishing our practice's compliance policies, which mean that we applied Medicare rules to Medicaid, TriCare, etc.    

     

    Over the years there have been several imaging centers and physicians caught not complying with the contrast supervision rules and getting into very serious legal trouble with the OIG.  Obviously, you simply must provide direct supervision for your Medicare patients (and other patients covered by a government plan). 

     

    Commercially insured patients are another matter, at least in theory.  You'd first need to check your state's laws.  Iowa, for example, does not require Direct Supervision for contrast studies by statute.  This means that, technically, facilities can inject contrast without having a physician present. 

     

    Our practice rejected injecting commercially-insured patients with an IV contrast (including Gad) without physician supervision, feeling that, while arguably legal, it was simply poor practice to do so.  Others are free to come to a different conclusion.  I know of one such MRI facility (no longer in business) that operated in that manner.  I'd only caution that those that do this should explore their motivation for practicing medicine in this manner. 

     

    On a related note, if I was a competitor in your market and learned this was standard practice at your facility, I'd market the heck out the fact that you don't provide physician coverage for contrast injections to the referring physician community as well as to the commercial payers directly.  One can argue all day long the risk is low, but good luck with that.  Don't think for a moment others wouldn't learn of this practice. 

     

    I suppose the industry could try to convince CMS to change its supervision rule for Gadolinium.  There is not a snowball's chance in h### of success.  One only needs to read Dotarem's package insert, which reads in part, to see why:

     

    ----------------- WARNINGS AND PRECAUTIONS -----------------

    • Hypersensitivity: Anaphylactoid/anaphylactic reactions with cardiovascular, respiratory or cutaneous manifestations, ranging from mild to severe, including death, have uncommonly occurred. Monitor patients closely for need of emergency cardiorespiratory support.

    ------------------------------------------------------------------------------

     

    With any published risk of death there is simply no way CMS is going to change this rule.  Arguing that the physician is merely going to call the EMT's anyway won't get far.  Frankly, I seriously doubt the ACR would support the change.  IMHO, since this is a clinical issue, the RBMA has no business making that argument.  It can't be about saving money. 

     

    My suggestion to you is to try to find a less expensive way of hiring physician supervision.  For example, can you hire Family Practice residents from a nearby program to come to your facility to sit there?  They're licensed doctors and may appreciate the added income. I'm sure there are other creative ways to find an acceptable solution. 

     

    Sincerely,

     

    Michael Bohl, Chief Strategic Advisor

    Radiology Group, PC, SC

    mbohl@rgimaging.com

     






  • 3.  RE: Physician GAD Coverage

    Posted 06-30-2019 22:29
    Michael makes a good point.  We only cover our hospital's outpatient imaging center until 7:00 pm.  The hospital hired family practice residents (from the hospital's own residency program) to cover all contrast reactions until closing around 9:00 pm.  It has worked well over the past 15 years.  

    When there is a contrast reaction, the doctor (radiologist or family medicine resident) responds and determines whether or not to call 911.  We did have a patient die after the patient was transferred to the ER (less than 1 mile away). 

    Please contact me via email or at 417-894-0878 if you have any questions. Thanks and have a wonderful day. 

    Jay Smith, CPA, MBA 
    Executive Director
    Litton & Giddings Radiological Associates, P.C. 
    P.O. Box 14049
    Springfield, MO 65814 

    All information contained in this email is confidential (and may include Protected Health Information - PHI), belonging to the sender who is legally and/or medically privileged. The information is intended only for the use of the recipient named above. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or taking of any action based on the contents of this email is strictly prohibited. If you have received this email in error, please notify us and destroy the document immediately.







  • 4.  RE: Physician GAD Coverage

    Posted 07-01-2019 13:22

    Michael/Jay:

    Many thanks for your insights and detail into this question!

    As I've been our COO for about one year I'm trying to learn as much as I can about the imaging business and I sincerely appreciate all feedback.

    In all cases - PATIENT SAFETY COMES FIRST - and we have always followed these guidelines to the letter.

    I've spoken with a number of friendly competitors and I hear from some that "As long as the MD is 'proximate' (maybe even 10 minutes away) we're OK".  Not on my watch.

    I look at the 26 years the company has been in business with no physical reaction.  Note that we currently use Dotarem which appears to be among the 'safest' of all GAD.

    I raised the question as I have been a guest in the back of an ambulance multiple times and credit my health (and life) to a quick-acting EMT.

    At the very least I assume that a qualified EMT would be the right person to be at a patient's side as an EMT is always at-the-ready as their career is dedicated to daily serving the needs of patients in varied and unexpected trauma situations.

    Of course in an outpatient situation no matter the qualifications of the MD, upon discovering a serious reaction 911 WOULD BE CALLED and an EMT would administer care until the patient reaches a local hospital.

    All our techs are qualified to assess patient status at all times and I am confident that they do so.

    So as a practical and reasonable case could it possibly be within some safety guidelines to have a qualified tech and EMT on staff to ensure patient safety?

    I know there will be differing opinions, but the most important part of this from a business perspective is if we as outpatient centers must have an MD near the patient these are my most highly-compensated employees.

    Can't we at least lobby 'the powers that be' to ask for additional compensation to cover this additional cost and risk?

    So from a medical standpoint - patient safety comes first. A business perspective must recognize these additional costs with decreased/decreasing reimbursements.

    I recall a family member who had an MRI in a hospital setting and the only staffer present was the MRI tech.

    So in a hospital is the requirement for an MD to be 'proximate' or with the patient at all times during their visit?

    -------

    At some point if we can't make sense out of these sometimes varied and changing draconian rules and reimbursements among the many insurers we are all in a tough position to offer the level of service that our patients deserve and best practices dictate.

    I'm trying my best to learn as much as I can to ensure our future profitability and growth - hence my membership in the RBMA.

    Warmest Regards.

    Bill

    -----------

    Michael:

    "My suggestion to you is to try to find a less expensive way of hiring physician supervision.  For example, can you hire Family Practice residents from a nearby program to come to your facility to sit there?  They're licensed doctors and may appreciate the added income. I'm sure there are other creative ways to find an acceptable solution".

    Any ideas on how I could approach a group or where/how I could advertise for this MD coverage on a PRN basis?



     



    ------------------------------
    William Kisse
    COO
    Washington Open MRI, Inc.
    Rockville, MD
    bill@womri.com
    (301) 424-4888
    https://www.linkedin.com/in/billkisse/
    ------------------------------



  • 5.  RE: Physician GAD Coverage

    Posted 07-08-2019 13:20
    The following was recently published in radiologybusiness.com discussing the results of extensive testing of adverse reactions to GAD.

    We are currently using Doteram (Gadoterate dimeglumine) and although this GAD only represents 2.9% of the overall patient population it doesn't appear to have had any adverse reactions.

    PATIENT SAFETY COMES FIRST.

    Has anyone else had experience with Doteram and any side-effects?

    Thank you

    Bill

    https://www.radiologybusiness.com/topics/care-delivery/researchers-gadolinium-related-adverse-reactions

    ------------------------------
    William Kisse
    COO
    Washington Open MRI, Inc.
    Rockville, MD
    bill@womri.com
    (301) 424-4888
    https://www.linkedin.com/in/billkisse/
    ------------------------------



  • 6.  RE: Physician GAD Coverage

    Posted 07-19-2019 10:59

    Bill, there is new evidence out about Gadolinium Deposition Disease (GDD) and that the contrast with the least deposition in the brain by half over the others is Prohance.  Here is a link to one article on risk management strategies.   Many institutions including Massachusetts General have switched to Prohance for this very reason.  If you google "lawsuit for gadolinium deposition disease" you will get a whole list of attorney firms willing to take these cases.  There was also a presentation at ACR2019 in Washington DC given by H. Benjamin Harvey, MD JD Director of Quality Improvement Department of Radiology Mass Gen that goes into great detail of the retention of gadolinium in the Cerebellum, Cerebrum, Femur and Kidneys for the three contrast agents Dotarem, Gadovist, and Prohance. 

     https://www.radiologybusiness.com/topics/care-delivery/gadolinium-risk-management-3-pillars-sound-strategy

     

    John Griffith

    Administrator

    DakotaRadiology

    2929 5th Street, Suite 230

    Rapid City, SD  57701

    Office: 605.721.8545

    Fax: 605.721.8827

    JGriffith@dakota-radiology.com

    www.dakota-radiology.com

     

    WARNING: CONFIDENTIALITY NOTICE - The information contained in this transmission is the private, confidential property of Dakota Radiology, including patient information protected by federal and state privacy laws. This transmission is privileged communication intended solely for the intended recipient. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or disclosure, or the taking of any other action relevant to the contents of this transmission, is strictly prohibited. If you have received this communication in error, please contact Dakota Radiology at 1-605-342-2852, or reply to the sender.





  • 7.  RE: Physician GAD Coverage

    Posted 08-01-2019 07:50
    Thank you, John.

    I am working with our rep at McKesson to get a cost for this contrast agent.

    I'll keep the group informed of my progress.

    Regards

    Bill​

    ------------------------------
    William Kisse
    COO
    Washington Open MRI, Inc.
    Rockville, MD
    bill@womri.com
    (301) 424-4888
    https://www.linkedin.com/in/billkisse/
    ------------------------------