Compliance/Internal Control Services

Health systems face significant challenges when working to integrate and effectively manage physician relationships in the current regulatory environment. Increasing use of strategies such as compensation plans based on work RVU production or outcomes data places new requirements for controls over accumulation of quasi-financial data not typically considered in your organization’s internal control structure.

Whether you are recruiting physicians into private practice, employing physicians in not-for-profit health care corporations or purchasing entire practices, you need to plan and control these affiliations to comply with applicable fair market value requirements from Stark, Anti-Kickback and Excess Benefit Rule perspectives, at the time of initial transactions and on an ongoing basis.

Specific service offerings within this suite include:

“Vital Signs” Provider Relationship Internal Controls Analysis

This analysis offers rapid feedback on hospital performance in a number of key internal control functions related to physician relationships. This service also provides a high-level summary of key internal control areas and recommendations regarding industrywide best practices.

“Vital Signs” Compensation Plan Internal Control Analysis

This analysis provides rapid feedback regarding internal controls and processes surrounding the calculation of provider compensation in your organization. Provider compensation plan designs are becoming increasingly complex, frequently including factors such as Work RVU production that have not traditionally been encompassed in an organization’s accounting or internal control systems. In addition, provider compensation is closely scrutinized for compliance, with multiple potential hazards if plans are not accurately and consistently calculated. This service will provide a high-level analysis of your current internal control structure surrounding provider compensation calculations and recommendations for improvements.

Physician Integration Compliance Process Analysis

Relationships between health systems and physicians are subject to intense scrutiny from a host of regulators and stakeholders. Proactive control and ongoing management of these multiple arrangements is vital to avoid potentially significant penalties or even threats to continued program participation associated with these increasingly complex regulations. Our solution provides a structured approach to identifying, assessing and managing physician relationships, using a risk-based methodology to direct more effort to higher-risk relationships and arrangements. The outcome includes a database of identified physician arrangements and procedures for ongoing management and control of this information.

Fair Market Value Compliance Services

Whether health systems are purchasing a business or entering into a contractual relationship, we can help guide them to an appropriate valuation that complies with the Stark Regulations, the Federal Anti-Kickback Statute and not-for-profit rules, if applicable. This subset of due diligence is important as a part of your overall compliance plan because it ties into employed physician compensation, other existing financial relationships with physicians and due diligence engagements for potential arrangements.

Fo more information visit BKD Fair Market Value Services

Physician Compensation & Contractual Payment Process Analysis

Because physicians and health systems are often in low-trust climates, BKD can independently verify that physicians are being paid correctly and attest to this for physicians, the health system and other stakeholders. Our testing and reporting processes can help keep parties on the same page and reduce doubt about accuracy and intentions.

These offerings are designed to be molded into an individual plan to meet your specific needs.

Ear, Nose & Throat Associates

“Before we started with BKD, our accounting firm only did our business accounting and personal tax preparation. We needed more than that. We needed advice, recommendations, suggestions, statistical analysis and market evaluation. BKD has been that advisor who brings us new ideas.”

“BKD has been valuable for us not only in the advice, suggestions, and analysis, but also as a resource for our internal staff development. Our BKD advisor may have started as an analyst, but has subsequently become an integral part of our office to where the staff views him as one of our staff members and looks to him for suggestions and guidance.”

— David Stein, M.D., President
Ear, Nose & Throat Associates

Jordan Valley Community Health Center

“BKD was recommended to me 10 years ago as an accounting firm with a specialty niche focused on community health centers. Since that time, I have used BKD at two different facilities for a full range of financial services. Their professionals have provided us with audit, tax, coding and billing and cost report services and have assisted us in operations management and revenue enhancement. Routinely, implementation of their recommendations had a positive influence on the financial outcomes of our program. In addition to their efforts at the individual health centers, BKD is actively involved at both the national and state levels in addressing issues of interest related to health centers and their ongoing fiscal viability. This broad range of experience and knowledge has made them among the best in the industry.”

— Brooks Miller, Executive Director
Jordan Valley Community Health Center
Springfield, Missouri

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