When it comes to paying physicians for non-clinical work, it is (too) easy to make mistakes that could cost your organization and could be in violation of Stark and Anti-Kickback laws.
Should you pay highly-compensated specialty physicians for non-clinical positions more than you pay a PCP or a pediatrician? While it could be argued that their time is “worth more”, it is also true that the administrative tasks you are paying them to do shouldn’t necessarily take their clinical salaries into account. How should your organization respond?
Considering opportunity cost is helpful. Opportunity cost assumes that there are other alternatives to the activity you are asking the physician to perform. It’s easy to see that a neurosurgeon might not want to be a medical director if she could use her limited time to practice medicine–and get paid more for it! Furthermore, because medical directorships, chiefs of staff, and other administrative positions often require that a certain specialty of physician be in the role, physicians of higher paying specialties have leverage.
So, what does the government say about this challenge? Not surprisingly, the Office of the Inspector General (OIG) is vague. While it doesn’t forbid compensating higher-paid physicians more in non-clinical roles, it does warn that convoluted compensation structures could mask kickback payments (from Advisory Opinion No. 07-10).
Ultimately, even if you do not base payments on opportunity cost you should at least consider the physician’s perspective. Most always, physicians who have been asked to play an administrative role have considered how else they could be spending their time, not to mention, how much more they could get paid. Depending on your market, this could be highly significant to establishing a fair rate…or it might not.
Experts at MD Ranger recommend that every organization develop policy from their overall goals and clinical service needs. Consistency, data, and documentation should be the backbone of your contracting process. Curious to learn more about medical directorship compensation? Check out our webinar on September 19th at 10:30 am PDT.