Re: responses from Clinic question

Re: responses from Clinic question

Aaron Laster

2/5/2015

Thank you to everyone who responded. Many people seemed interested in the
responses so here are the results:

1) Per the Medicare supplier standards that we hand each patient, number 29
states the DMEPOS suppliers are prohibited from sharing a practice
location with certain other Medicare providers and suppliers. I think the
clinic days are over due to this clause.



I always assumed when we went to the SNFs that is was because we were
called in as a referral as needed and not running a clinic at a set time to
try to increase our bottom line. The same goes for a home visit. Clinics
and sharing office spaces tends to refer to a residency of a set time where
as facility and home visits are as needed.



2) We have several of both. We have 2 satellite offices. One is open
regular hours 2 days/week with traveling staff and no admin. The other has
now grown to a full time office with one full time admin office manager.
Practitioners have assigned days once or twice per week. Satellite offices
need to be registered with CMS, need to be separately claimed, assessed,
audited, etc by CMS and by ABC if you are facility accredited. Costs are
involved with all of these as well as rules and regulations and policies
that pertain to an office (a landline, for example, and posted hours).
However, a permanent office allows advertising, it is one more location to
add to your literature and this attracts patients. If there is growth
potential in the area, a permanent office is the way to grow it.



We have clinics in areas where we go once or twice a month. These are
rented rooms in a PT dep't of a hospital. Patients are generally referred
ONLY by that hospital or PT dep't. We can't keep any equipment there as
the space is generally rented to others or is not really a room designated
just for us. It's designated to us for those 2 days each month only. It
is more a convenience to the hospital and to the patients. It is safer
than home visits, less liability, less traveling, parallel bar usage when
necessary, etc. And it's a guarantee referral back to the PT dep't in many
cases. Patients are covered under the hospital liability when being seen
there.



Our clinics offer no growth opportunity. We are not necessarily trying to
grow our business in that location or build up to anything. That is the
primary difference. If you're dedicated and trying to GROW an office, do a
satellite office, advertise, solicit the referrals, make it a competition
for your practitioner staff to see who gets the most referrals and who may
one day manage this new office. See who's hungry enough to run with it.
If that's not your intent, clinics are cheaper and easier by far.



3) I wish I could tell you what is legal and correct or not, but we too are
unsure. I've been concerned about this for a while and will tell you in
confidence that we do participate in a variety of clinics without paying
for space. As this seems to benefit all involved, I can imagine that no
payment needs to change hands. Though I've never seen it in print, I've
heard rumors that payment is required to make everything legal.



4) I will share our experience with this situation. Medicare DEMPOS
Supplier Standard #29 which states DMEPOS suppliers are prohibited from
sharing a practice location with certain other Medicare providers and
suppliers seems to forbid most of these types of clinics. The
interpretation is still a little vague but we were sharing a clinic space
with a PT clinic for several years prior to this standard. Once this
standard became known to us both organizations reviewed and determined
there was a chance the relationship could be determined to violate standard
#29. When we looked into the standard the explanation was that we needed
to have separate entrances, billing and front office staff, etc. If we
were open to the public and not just in the clinic seeing patients from
that PT office (or physician office) then that could (and likely would)
constitute an office setting. As such it was susceptible to the
appropriate rules and laws including accreditation and billing standards.
I also spoke to AOPA regarding this standard and they had the same opinion
although they did qualify their opinion by saying if we felt like we could
defend the fact that this was not an office they we could make that
determination ourselves. Our determination was that it was too risky to
maintain the same relationship. We have a policy now that we will only see
patients in these clinic locations if the patient is established with
that provider and we are there as a consult. Otherwise your options are to
see them in your facility or the patient's home if you choose to do that.
This was a significant change for us as we had a few of these clinics
over the years that were very successful for us. I will say that although
the change wasn’t pleasant since we truly felt it was a great way to help
the patients have better access to our services, I don't think it has
really hurt our referrals or overall business once we explained that we
were simply trying to follow the guidelines. Hope our experience helps.



5) At our office we were having discussions about clinics versus
satellite offices. we know of a few other offices that have clinics set
up in a therapists or physicians office where they pay rent for a room or
area for a day to see patients. What are people's experiences and rules
and regulations with this? I feel like this was more common 5-15 years ago
but I still have heard of this for people who go to a doctor or therapists
office periodically.