Acting as a roadmap through the changes in healthcare and healthcare law that occur almost daily, this presentation uses a case study to illustrate real-world issues and concerns associated with the compensation redesign process, including types of compensation models, service-specific compensation components, legal and contractual issue identification and mitigation, fair market value challenges
1. WORKING THROUGH A SYSTEM-WIDE COMPENSATION REDESIGN
AND LIVING TO TELL THE STORY
AHLA Physicians and Hospitals Law Institute
FEBRUARY 5-7, 2018
Feels Like the Odyssey?
2. Page 1
Kris Shepard - Carolinas Healthcare System
Deputy General Counsel (present)
Vice President - Physician Network Development and Central
Contracting (previous)
Annapoorani Bhat - PYA
Valuation
Fair Market Value Compensation Valuation
Business Valuation
Intellectual Property
Commercial Reasonableness
Speakers
3. Page 2
Outline
Types of Models
Legal/ Contractual
Considerations
Fair Market Value
Challenges
Basics
Comp
Redesign
Case Study
Carolinas
Healthcare
9. Page 8
What is compensation?
Direct Financial: Pay, productivity/quality bonus
Indirect Financial: Benefits, vacation, retirement plan
Non-Financial: Career development, advancement
opportunities, work environment, living environment
Basics
10. Page 9
Why redesign compensation structure?
Correct pay inequity
Minimize disparities between arrangements
Move away from fixed salaries and toward pay for
productivity, pay for value
Create consistency with alternative payment models
Basics
11. Page 10
Top Challenges
Finding a solution that works across specialties
Contract compliance post execution
Ensure regulatory compliance
Compensation plan governance
Basics
13. Page 12
Practices may have disparate models due to:
Legacy contracts not updated with time
Wide variations in specialties
Compensation models not modified after physician
practice acquisitions
Compensation redesign exercise aims to:
Streamline models
Create arrangements/contracts that are easy to
administer
Types of Compensation Models
14. Page 13
Base salary
Base + productivity-based compensation
wRVU
Encounters
Collections (revenue-based models)
Additional shifts
Bonus based on quality measures
Types of Compensation Models
15. Page 14
AMGA 2017 Medical Group Compensation and
Productivity Survey
83% of organizations that implement production-based
compensation plans for physicians rely on wRVU as a
measure of productivity
Types of Compensation Models
2005 2010 2016
40%
60%
83%
16. Page 15
Example 1 – Base + Productivity Bonus
Base of $250,000
$50 per wRVU in excess of 5,000 wRVUs (threshold)
Base will be revisited each contract period
Additional compensation: (i) payments for mid-level
supervision, (ii) medical directorship, (iii) excess call pay
10% of Base Compensation at risk for achievement of
quality metrics
Types of Compensation Models
17. Page 16
Example 2 – Shift-based model
Base of $250,000 which assumed full-time work load to
be 12 hour shifts, 7 days a week, every other week
Every additional shift is paid $115 per hour
Additional compensation: (i) payments for mid-level
supervision, (ii) medical directorship, (iii) excess call
pay
7% of Base Compensation at risk for achievement of
quality metrics
Types of Compensation Models
18. Page 17
Alternative Payment Models (APM) –
Need to find alignment between compensation models
and how payers are reimbursing for services
Types of APMs
Pay for performance (P4P)
Shared savings arrangements
Episodic payments (bundled payments)
Global budgets
Types of Compensation Models
20. Page 19
Fair Market Value Challenges
Case Study – Psychiatry
Emergency Department
Inpatient Care
Consult Liaison
Outpatient – Child, Geriatric, Adult
Tele-Psychiatry
Rural Hospital Coverage
21. Page 20
Fair Market Value Challenges
Case Study – Psychiatry
Coverage Model – Shift-Based
Day versus night shift
1-week on, 1-week off versus 5-day work week
Supported by mid-levels (or not)
22. Page 21
Fair Market Value Challenges
Case Study – Psychiatry
Productivity-Based Model – wRVU
Issue with compensation per wRVU benchmark data
Need to support any such model with coding reviews
before and after model is established
Ensure that total compensation after including varying
components of compensation does not fall outside FMV
25. Page 24
More than 7,600 beds
Accounts for approximately 12 million patients
More than 900 locations
Teaching hospital for University of North Carolina-
Chapel Hill School of Medicine
Long history of operations in the Carolinas
Carolinas HealthCare System (CHS)
27. Page 26
More than 2,500 employed physicians system-wide
Nearly 500 primary care
Large specialty groups (Internal Medicine/Family
Medicine, Hospitalists, OB/GYN, Pediatrics)
Over 1 million unique patients and $1 billion in net
revenues per year
CHS Medical Group (CHSMG)
28. Page 27
Variability in Compensation
Three distinct models with 100s of different
variations
29. Page 28
Variability in Compensation
Limited incentive for quality, service, care
management/cost control
Complicated decision-making:
Benefit funding
Manpower planning
Overhead responsibility
Ancillary revenue (infusion, lab, imaging)
Use and role of Advanced Care Providers (ACPs)
31. Page 30
Models Within Comp Plan
Clinical
BaseSalary
Individual
wRVU
Production
Incentive
Percentage of Base - Performance Incentive
Group
wRVU
Production
Incentive
Fixed
Percentage
Production
Incentive
Excess Shift
Pay
No
Production
Incentive
wRVU Models:
Medical Administration, Education and Research, and Additional Professional
Services
System Incentive
Shift/Salary
Models:
Shift + wRVU
Models:
Production
Incentive
32. Page 31
What’s New?
Reduced Variation in
Core Clinical
Compensation Models
• wRVUs are the
primary component for
measuring productivity;
some specialties will
be on shift-based or
salary models
• Consistent rates used
by specialty to ensure
fairness across
CHSMG
Consistent
Performance Incentive
• Specified percentage
of clinical
compensation
available as
performance incentive
• Weighted between
quality and patient
experience
(alternatives permitted
if metrics are not
available)
• Metrics intended to
reflect System and
Care Division priorities
for the benefit of our
patients
Physician Oversight
and Leadership of Plan
• Formation of Physician
Compensation
Committee made up of
physician leaders
• Steering Committee
made up of subject
matter experts
• Flexibility to modify
plan to maintain
appropriate care
delivery incentives and
match organizational
priorities
33. Page 32
Timeline
2014
• Planning begins; need to change recognized
• Hired external firm to assist with design work, including gathering feedback from
physician leaders and developing compensation philosophy
2015
• Leadership changes within Medical Group; announcement of CEO retirement
• Comp philosophy and unified design completed; no implementation plan
• From Mid 2015 to Mid 2016 Physicians are in the DARK
2016
• New CEO New mission and strategy tied to Affordability | Value | Growth
• Hired two firms to provide implementation support and FMV analysis, and a third
for additional design
2017
• Implementation in two phases
• +91% signature rate
35. Page 34
Fair market value and Stark Law compliance
Third-party opinion
Reliance on published national surveys
Team-based incentive models
Pay equity
Coding/compliance
Contractual matters
Form versus customization
Contract versus policy versus trust
Governance through compensation committee
Legal and Contractual Issues
36. Page 35
Importance of leadership, especially physician leaders
Communication challenges
Carrots and sticks
Prepare to be surprised
Real-time reporting capabilities
Implementation Issues
37. Page 36
Summary
Compensation Redesign
May be triggered by various factors
Requires buy-in from physicians and corporate
leadership for success
Actual execution enabled by contracting team and
business group – critical members of team
Support of consulting resources, experts in the field
critical to success
Checks and balances post redesign ensures continued
success