POPT

May 13, 2011

I am a physical therapist with a small private practice. Recently I've been

approached by a physician group wanting me to partner with them in a POPT

venture. They are currently referring patients to me and so I want to take

a careful approach to my discussion with them. There has been conversation

in this group (PT Manager) about all the reasons why POPT's are bad for our

profession but I am hoping for some response from the group that will help

me present some reasons that this venture would be a bad idea for them, (the

physician group). I'm sure I need to refer to more than just the ethical

considerations in my conversation with them. Can anyone in the group provide

me with conversation points that will possibly help me convince them that

they should reconsider their plans for this business venture?

May 15, 2011

I was approached with a similar offer to work in a POPT (Medicare

participant who billed PT services as incident to physician's.) Here are a

few reasons this was a bad idea for me: 1. I would have had to limit my

referrals from other referral sources, since PTs in a POPT setting are

required to receive >90% of their referrals from the physician(s) in the

practice. Depending on the type of physician group, this could quickly

homogenize your patient population. 2. Because I would have to bill under

the physician's billing code, I could only practice when the physician was

physically there. This would restrict my ability to perform off-site

treatments, to set up gym programs, to perform home or ergonomic

evaluations, to provide pool therapy at a leased community pool, etc. 3.

Because my PTA bills under my NPI, and I would be billing under the

physician's (not my) billing ID, my PTA could not work in the POPT with me.

The benefits would have been access to their full clinical support system

(scheduling, billing, insurance contracting...), benefits package similar

to the physicians in the practice, and ability to specialize in a very

narrow scope of PT practice. I am sure their interest in me was not

financially-motivated, because they owned the MRIs, anesthesiology suites,

etc. Any profit I could have produced would have been a drop in the bucket.

Now, why would it be bad for them? 1. Start up costs and overhead for

ongoing operations that they would not incur if they just kept referring to

your practice. If they only hire you (and they accept Medicare) they will

need to generate enough referrals to keep you productive, and should expect

to have a modest profit. You may have to explain the differences between

physician billing codes (which charge for " typical " times and PT codes which

charge for " actual " time) They would really need to be able to support 2-3

therapists to make such a venture worthwhile. This may be a good

opportunity for you to educate them that you as an individual practitioner

have already assumed this risk in your practice and would welcome the

opportunity to continue to do so. They may incur added costs if their EMR

and billing software do not support rehab services. 2. Increased

compliance/regulatory oversight. Medicare is looking more closely at these

relationships in terms of the Impossible Day (more codes billed than hours

in the workday.) and they are on the radar of private insurers, too. The

physicians may not be aware that in response to published stories of

fraudulent billing practices (primarily by chiropractors and physicians

billing incident-to PT services) CMS published a final rule upgrading PT

services to Moderate threat for fraud/abuse (Federal Register Feb 2, 2011)

and are closely scrutinizing new PT start-ups and POPTS. The physicians

would be response for fines and penalties for inaccurate PT services billed

under their billing ID. They would need someone to assume the

responsibilities of making sure they have a compliance program and of

staying up-to-date on the changes to ensure continued compliance, or pay

someone (maybe you) to be the rehabilitation director and perform those

responsibilities (that you as an individual practitioner are already

familiar with.)

The real question is what do they expect to gain from the arrangement that

can't be achieved in your current relationship? Commonly cited (not

necessarily in this order:) 1. New revenue stream, 2. Tighter control

over delivery of PT services (specifically, decrease over-utilization

through closer communication with the therapist,) and 3. Improved customer

satisfaction for those who can make one trip on the day that they have PT

and MD visit the same day. If the main concerns are reasons 2 or 3, I'm

positive you can address them in your current model. If the answer is 1,

try not to look surprised when they say it out loud.

One more suggestion. Go with the attitude that *you* are interviewing* them

* and gather information about their customer base, practice needs, future

growth potential, policies and procedures, etc. that will help you better

meet their needs and/or you plan for future growth at your practice. This a

fantastic (and free!!!) marketing opportunity for you; you have their

undivided attention for the entirety of the interview, and can use it to

sell them on the value of your services in the current model. Try to walk

away on an " even though I don't think this fantastic opportunity is for me,

I'd love to be able to continue to work together " note (and give suggestions

of how you can still help meet their patients' needs.)

Good Luck!

Diane , PT

Augusta, GA

---------- Forwarded message ----------

Date: Sun, May 15, 2011 at 6:15 PM

Subject: Re: POPT

To: PTManager