This is not the time to put your head in the sand. The “transparency” genie is not going back in the bottle — ever.
• Your overhead is substantial. The pub- lic generally has no idea that most physicians spend 50 percent or more of their gross income on staff, rent, equipment, supplies, health informa- tion technology, professional liability insurance, licenses, certifications and continuing medical education, educa- tion loans, etc.
patients were covered by Medicare Ad- vantage. The database includes only fee- for-service Medicare payments; services provided to patients covered by Medi- care Advantage are not included. Again, if there is a mistake and you should have been included in the data- base, you may want to start by reviewing and updating your listing in the National Plan & Provider Enumeration System at
https://nppes.cms.hhs.gov/NPPES/Wel come.do and then contact CMS. If you were not included and your patients are asking why, you may want to work with the organization that billed on your be- half to develop an appropriate public response.
Among other things, your employer
will want to answer questions and allay any fears your patients or potential pa- tients may express. For example, where evidence suggests physicians should perform at least a minimum number of a specific procedure to obtain optimal
outcomes, you may want to be able to demonstrate that you met that threshold.
What do I do if the numbers are cor- rect but the impression they convey is misleading?
The numbers may give your patients or the public the impression that you are making a lot more money from Medicare than others in your specialty or than you are taking home. Reasons for this may include:
• Others bill under your provider ID, such as physician assistants or nurse practitioners.
• You have been categorized incorrectly and actually practice in a different specialty or subspecialty than the one listed.
• You provide expensive drugs or other services that you pay for, such as che- motherapy drugs.
Notice: The information provided in this article constitutes general commentary and informa- tion on the issues discussed herein and is not intended to provide legal advice on any specific matter. This article should not be considered le- gal advice, and receipt of it does not create an attorney-client relationship.
48 TEXAS MEDICINE June 2014
• Fee-for-service Medicare patients make up a larger-than-average por- tion of your practice. (You don’t see many patients covered by Medicare Advantage, commercial health insur- ance, or other programs.)
• Your particular patient population is sicker than average because you are a subspecialist or otherwise handle more complex patients.
You may want to develop an expla- nation you can share with your patients, referral sources, managed care plans, regulators, or the press that puts this in- formation in perspective. To the extent the data demonstrate your extensive experience with a particular procedure, you may want to point that out. You also can reference the things that make your practice stand out, such as state-of-the- art equipment, foreign language compe- tencies, and extended hours. You also may want to take this op- portunity to highlight your professional qualifications, such as successful partici- pation in the government’s e-prescribing, electronic health record meaningful use, or Physician Quality Reporting System programs. Finally, take this opportunity to review your profile on CMS’s Physi- cian Compare website,
www.medicare .gov/physiciancompare. Make sure that site contains your up-to-date demo- graphic information and correctly re- flects your accomplishments.
What should I do if my numbers con- cern me?
Use this opportunity to compare your data with your peers. While it may be justifiable for a physician to be an outlier, there is no question that outlier status invites scrutiny. These publicly available spreadsheets have dramatically upped the stakes. Experts who have analyzed the entire public database can tell you where you rank by specialty and locality and whether your data raise particular red flags. You owe it to yourself to know where you stand and take charge of your profile. n
Catherine I. Hanson, JD, is of counsel, Whatley Kallas LLP. For more information, contact the Whatley Kallas attorneys at (800) 745-8153 or email info@whatleykal
las.com.
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