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Applied Statistics and Large Numbers
By Dr. Charles F. Fenton III; Esq
One of the next big areas of medical practice risk management that will surface in the near future is the Pattern of Practice Risk.
Pattern of Practice refers to the way that a particular physician practices medicine. With computers, standardized diagnosis and treatment codes – and the budgetary restraints inherent in medical practice – it is becoming easy to statistically analyze a physician’s method of practice.
Outliers – Can Lie
The treatment and diagnosis codes that a physician uses and submits to third party payers can be quantified and compared colleagues in the same or similar specialties. Statistical outliers can be identified.
Assessment
These outliers are then further audited and required to justify their treatments. If no rational basis exists for the statistical differences, the outlier may find himself the subject of a fraud investigation.
Conclusion
Have you ever been involved in a patterns-of-medical-practice audit? If so, please comment on your experience.
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Disclosure of Financial Relationships Report [DFRR] for Hospitals
Were you aware that under a new proposed rule for fiscal 2009, the Centers for Medicare & Medicaid Services [CMS] plans to send an information collection tool – the Disclosure of Financial Relationships Report (DFFR) – to 500 general acute care and specialty hospitals to determine compliance and assist the agency in future rulemaking about reporting requirements and other physician self-referral provisions?
As of December 2006, there were about 6,200 Medicare-participating hospitals, and the CMS said its goal is to begin by sending the report to eight to ten percent of those facilities, as reported in Modern Physician.
While the CMS proposed certain changes to its physician self-referral rules in its fiscal 2008 proposed rule, the agency has not made any of those changes final, and said analysis of the DFRRs may affect subsequent proposals on these and other issues.
Does this help or hinder the Stark I, II and III disclosure reporting requirements? First the docs, and now the hospitals. What’s next?
Any comments?
-Ann
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