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Hospital sponsored clinic set up

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  • Hospital sponsored clinic set up

    My small private neurology group has been providing inpatient/ED consult services to one hospital. Now we are looking into setting up a clinic within this hospital to provide the outpatient service. The hospital will provide EMR, computers, office and likely medical assistants and schedulers. We are not yet certain if we will be paying rent for the office space although they may not require us. We don't get paid any salary or service fee from the hospital; we charge and collect directly from the payors. For neurology clinics the main source of revenue is the clinic procedures (EEG, EMG, botox). We need to make sure we get to collect full reimbursement including the facility fees for these procedures done by our own technicians using our own machines although done in the hospital provided office building. What would be the best way to ensure this happens? We do not want to lose the facility fees which make up the most of the reimbursement for these procedures. The value of our outpatient service to the hospital would be preventing the leakage of patients to other competing hospital groups, increased revenue via radiology, labs and admissions. Without us, this hospital has no access to neurology service at this time as it is very difficult to recruit one.

    Does any of you have this kind of clinic set up with hospitals?
    Thank you in advance for your insights.
    Last edited by Neurologo; 05-31-2020, 11:16 PM.

  • #2
    Welcome to the board.

    Not much experience, but my hospital charges the specialties for their clinics if they are not being paid a flat fee. Use of space (rent), staff, supplies, in varying amounts.

    To clarify, you are wanting to collect the professional & facility fees for the procedures?

    I also would recommend checking with a healthcare attorney for your plan if you haven’t already. Not charging rent wades into Stark / Anti-Kickback waters, from what I’ve seen online & in-person.
    "Oh look another bajillion point declin-Ooooh!!! A coupon for pizza!!!!" <--- This is what everyone's IPS should be. ✓✓✓

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    • #3
      Right. We want to collect facility fees along with professional and technician fees just like independent medical clinics do. The hospital won't pay us anything for our services; we charge and collect directly from the payors. We will pay rent to avoid violating Stark law.

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      • #4
        Originally posted by Neurologo View Post
        Right. We want to collect facility fees along with professional and technician fees just like independent medical clinics do. The hospital won't pay us anything for our services; we charge and collect directly from the payors. We will pay rent to avoid violating Stark law.
        Not that familiar. But suspect hospital obviously would want those facility fees. Whether you can rent space in a hospital and not have it be part of their hospital "facility" for billing purposes is an interesting question

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        • #5
          Healthcare attorney is needed. I would guess that if you were not paying rent the hospital could lay claim to the facility fees. Paying rent helps your argument. To me, its like renting space from a medical office at that point. The name on the lawn just happens to say "O'Town Hospital".
          "Oh look another bajillion point declin-Ooooh!!! A coupon for pizza!!!!" <--- This is what everyone's IPS should be. ✓✓✓

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          • #6
            Paying rent seems to be the safer thing to do. Once the clinic gets more traffic I will also hire our own MAs who can also set up appointments. So at that point the only thing the hospital is sponsoring is the EMR.

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            • #7
              It’s not only Stark, it’s getting the relationship with the hospital in writing. You really need a healthcare attorney. A hospital would love to acquire a successful outpatient clinic that is up and running successfully. The point is the exit plan for building an outpatient clinic needs to be considered.
              Anecdotally, they want to acquire the group and you decline. Rent goes up a factor of 10. They have leverage with the rent. You move and they hire staff. Simply a healthcare attorney needs to protect your interests. You are building a business.

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