Practice Management

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  • 1.  Practice Expenses

    Posted 09-17-2021 12:06
    In calculating rvu's it is my understanding that practice expense includes operational expenditures, such as rent, utilities, labor, and expenses associated with billing and collections.  Is the rent in the calculation simply related to billing costs or is there other rent included?  I have a facility that thinks we should be paying rent for our reading room and feels we are being paid for it in the practice expense portion of the rvu.

    Any thoughts on this?





    ------------------------------
    [Sheila] [Witous] [MBA, CPA, CGMA]
    [Chief Administrative Officer]
    [Radiology, Inc.]
    [South Bend] [IN]
    [(574) 258-1100 ext. 205]
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  • 2.  RE: Practice Expenses

    Posted 09-17-2021 12:21

    Sheila,

    You can find the RVU descriptions in this booklet: How to Use the MPFS Look-Up Tool Booklet (MLN901344) (cms.gov) (see page 5)

     

    The MPFS uses 3 separate RVUs to calculate a payment:

    1. The Work RVU reflects the relative time and intensity associated with furnishing a Medicare PFS service

    2. The Practice Expense (PE) RVU reflects the costs of maintaining a practice (such as renting office space, buying supplies and equipment, and staff costs)

    3. The Malpractice (MP) RVU reflects the costs of malpractice insurance

     

    Sincerely,

    Renée C. Engle, RCC, RCCIR, FRBMA

    Senior Vice President, Client Services

    MSN Healthcare Solutions

    signature logo

    rengle@msnllc.com

    678-342-2578 (O)  | 770-815-4650 (M) | 678-342-5359 (F)

     






  • 3.  RE: Practice Expenses

    Posted 09-20-2021 14:55

    Thank you for the response, Renee.  Unfortunately, this does not answer my more granular question.  Specifically, what would stop a Clinic or Hospital from charging rent to my rad for the reading room space they are supplying to my rad?

     

    Thank you,

    Sheila

     

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  • 4.  RE: Practice Expenses

    Posted 09-20-2021 15:37
    Hi Sheila

    I think the answer to your granular question is nothing...it's going to be a negotiation.  

    The best argument I can give against rent is that they probably want radiologists to be onsite.  If they're going to make you pay for the work space, then I would want to consider the alternatives, assuming there are any.  I would also ask whether they're making any other hospital based physicians pay rent for their workspace (hopefully knowing the answer is no ahead of time).  If rent is going to be charged for using the hospital reading room, then I would have to start thinking about the free work your rads are doing for them that is not included in RVU's....seems like a slippery slope, and really bad for a hospital/radiology group partnership.

    It would be interesting to know how many groups pay rent, and what percentage of those are doing outside work in the hospital reading room.  I've never heard of paying rent unless outside work is being done, though I'm sure your hospital isn't the first to think of it.

    To your original question, I'm not an expert on how RVU's are built, but I believe rent is treated as an indirect expense.   As I understand it, indirect expenses are basically allocated based on the physician work and direct practice expense, sort of like an overhead percentage.  More work and more direct expense gets proportionately more indirect expense.  So, arguably rent is covered in the PE RVU.  Of course, you get paid the same by Medicare whether you pay rent or not.

    ------------------------------
    David Smith FACMPE
    Executive Director
    United Imaging Consultants
    Mission KS
    (785) 393-8387
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  • 5.  RE: Practice Expenses

    Posted 09-20-2021 16:03

    Sheila,

    I read your question to request the components of the RVU, sorry. David makes some very good points. To add to David's comments.

     

    Rent is included in the practice expense (PE). If you look at the procedures that have a TC/26 split it is easy to see that the PE is heavily weighted to the TC portion or what the hospital would bill. This may help your case.

     

    Let's take the below example.

     

    STATUS

    MEDICARE

    WORK

    NON-FAC

    NA

    FACILITY

    NA

    MP

    NON-FACILITY

    FACILITY

    HCPCS

    MOD

    DESCRIPTION

    CODE

    PAYMENT

    RVU

    PE RVU

    INDICATOR

    PE RVU

    INDICATOR

    RVU

    TOTAL

    TOTAL

    71045

    X-ray exam chest 1 view

    A

    0.18

    0.55

    0.55

    NA

    0.02

    0.75

    0.75

    71045

    TC

    X-ray exam chest 1 view

    A

    0.00

    0.48

    0.48

    NA

    0.01

    0.49

    0.49

    71045

    26

    X-ray exam chest 1 view

    A

    0.18

    0.07

    0.07

    0.01

    0.26

    0.26

     

     

    I've also added a more detailed description of the components below:

     

    Introduction to Relative Value Units and How Medicare Reimbursement in Calculated Medicare pays physicians for services based on submission of a claim using one or more specific CPT® codes. Each CPT® code has a Relative Value Unit (RVU) assigned to it which, when multiplied by the conversion factor (CF) and a geographical adjustment (GPCI), creates the compensation level for a particular service. To understand this more fully, the calculations can be broken into three components – RVUs, the geographical adjustment and the conversion factor. Relative value units (RVUs) – RVUs capture the three following components of patient care.

     

    1. Physician work RVU – The relative level of time, skill, training and intensity to provide a given service. Each CPT® code is targeted for review at least every five years to determine the work RVU for a particular service and consider if it remains the same as the value previously set. Code values can increase or decrease if the components of service have changed during the preceding years. A code with a higher RVU work takes more time, more intensity or some combination of these two. Some radiation oncology codes, such as treatment codes, have no associated physician work.

     

    2. Practice Expense RVU – This component addresses the costs of maintaining a practice including rent, equipment, supplies and nonphysician staff costs. The practice expense RVU is now calculated using a "bottom up" methodology where the direct costs of providing a service are calculated (staff time, supplies and equipment time) and indirect costs are allocated. Indirect costs are those that cannot be directly attributed the provision of a service, such as having a waiting room or a billing service. Direct costs are those that can be assigned to a specific service; a direct cost would be the actual supplies, equipment and staff time used for a given CPT code. Frequently, a CPT® code will be assigned a practice expense RVU for a facility setting, such as a hospital, and a different practice expense RVU for a nonfacility setting, such as a freestanding center. Generally, freestanding radiation oncology centers receive more practice expense compensation than hospital-based centers, since the practice expense of owning and operating equipment and providing staff resources are significantly more than the practice expenses covered by the physician in a hospital setting. As an aside, the hospital is paid under Hospital Outpatient Prospective Payment System (HOPPS or OPPS) for the radiation oncology equipment and services. Hospital-based physicians are paid under the Medicare Physician Fee Schedule (MPFS) in the same manner as freestanding-based physicians. 2009 is the third year of transition to a new methodology for calculating practice expense. The new methodology will be fully implemented in 2010. Therefore, the 2009 practice expense RVUs are often described as "transitioned" or "transitional."

     

    3. Malpractice RVUs - These are generally the smallest component of the RVU values and represent payment for the professional liability expenses. RUC and CMS rules suggest that these expenses are to be reviewed and updated on a bi-annual basis, but in practice, that has frequently not occurred. Geographic Practice Cost Indices (GPCI) - Geographic Practice Cost Indices account for the geographic differences in the cost of practice across the country. CMS calculates an individual GPCI for each of the RVU components -- physician work, practice expense and malpractice. GPCIs are reviewed every three years.

     

     

    Sincerely,

    Renée C. Engle, RCC, RCCIR, FRBMA

    Senior Vice President, Client Services

    MSN Healthcare Solutions

     

    rengle@msnllc.com

    678-342-2578 (O)  | 770-815-4650 (M) | 678-342-5359 (F)
    MSNLLC.com

     






  • 6.  RE: Practice Expenses

    Posted 09-22-2021 10:58
    This is kind of off topic but I've found it interesting.

    Has anyone ever summed their three categories of RVU's over the year and then compared the ratio of all three categories to your actual matching expense ratios?  For example, the MP RVU's account for x% of the total RVU's.  Does this amount equal or come close to your MP Premiums/Total Expenses.  Just using Renee's one code above would indicate your MP premium should be 3.84% [0.01/(.18+.07+.01)] of your fees/collections (at least on this one code).

    A little mind exercise if you have some extra time on you hands.......Chris

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    R. Christopher Sluder CPA
    Administrator
    Rome Radiology Group
    Rome GA
    (706) 291-2661
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  • 7.  RE: Practice Expenses

    Posted 09-23-2021 12:37
    The hospital bills and gets paid the technical component for the study the radiolgist reads in the reading room either via hospital outpatient prospective payment system or the hospital inpatient prospective payment system.  This covers the costs of the room, equipment, etc.  The indirect practice expense (PE) the radiologist is paid in their professional component (PC) in the facility setting is meant to only cover administrative costs, costs of CME and billing.  This is per Medicare's definition.  I've heard of hospitals trying to negotiate part of radiologists PE in the PC for many reasons but it is not usually warranted.  Usually a money grab.  I support what David said, do they do this for every physician who bills the PC only and works in their hospital?

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    Pam Kassing, MPA, FRBMA
    Cornville, AZ
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  • 8.  RE: Practice Expenses

    Posted 09-23-2021 14:56
    I would think an argument could be made that the rad group paying the hospital for the reading room violates Stark and could be seen an an inducement from the group to the hospital in exchange for the PSA since such practice is not industry standard.  An experienced healthcare attorney representing the group may be able to make this case.


    Deborah MacFarlane
    949.378.8308