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Closing shop; ancillaries; patient privacy
CLOSING A PRACTICE
Q. After two and half years of trying to do solo practice, I have had enough. This is not for me. Ideally, I want to sell my practice. If I can't and I have to close it, what are the steps that I should take to ensure a smooth closing?
A. To close the practice, you need to consider all the logistics based on your practice situation. For example, what will you do with your building? Do you rent, lease, or own? If you rent, you need to notify your landlord about your intentions. If you own, do you plan to sell? Find a real estate agent and start your preparations.
Also, determine what you need to do to move your equipment, files, and furniture - and where you will put them. If you lease your equipment, notify your leaser. If you want to sell the equipment you own, find a seller, have a yard sale, put your equipment up for sale on eBay, or find another way to locate a buyer.
Give your staff adequate notification. You'll want to retain at least one staff member for 30 to 60 days after the close to follow up on your final outstanding accounts. Most physicians find a part-timer for 60 days to be adequate, but it depends on the volume and how many of your accounts are still to be collected.
Remember that a physician has an ethical obligation to notify her patients when she moves or closes her practice to allow them to obtain copies of their medical records or have their records transferred to another practice. Ideally, a physician should notify each patient by letter at least 60 days in advance of closing. Often a physician supplements these written notices with a published notice in her local newspaper scheduled to appear on three or more occasions.
The American Medical Association's Ethics Opinion 7.03, Records of Physicians Upon Retirement or Departure From a Group, states in part: "A patient's records may be necessary to the patient in the future not only for medical care but also for employment, insurance, litigation, or other reasons. When a physician retires or dies, patients should be notified and urged to find a new physician and should be informed that upon authorization, records will be sent to the new physician. Records which may be of value to a patient and which are not forwarded to a new physician should be retained, either by the treating physician, another physician, or such other person lawfully permitted to act as a custodian of the records."
Finally, if you have privileges at a hospital - and especially if you take emergency call - you'll want to give that hospital at least 90 days notice, if not more.
ANCILLARIES IN INTERNAL MEDICINE
Q. What are the best ancillaries for internal medicine groups?
A. That depends on what you like to do, what your market's needs are, and what your payers are willing to cover. Here are some of the ideas we've seen of late:
- CT scans
- Botox
- Sleep labs
- Pulmonary function testing/spirometry
- Vitamins and other nutrition products
- Smoking cessation
- Weight loss clinics
- DEXA
- Hearing tests
Some keys to success include:
- Running your numbers carefully. How exactly will you bill for this new service? Can you make enough on it to cover your expenses? What's the break-even point and when can you expect to reach it?
- Understanding exactly how you will ensure you have adequate, motivated staff to provide the service.
- Thinking about the impact this new service will have on your patient base. For example, offering Botox can change the type of patients you have in your waiting room.
- Having a plan for marketing the service to new and existing patients.
- Evaluating potential competitors. Can you out-perform them?
- Planning your scheduling for the service.
Professional consultant Judy Capko has been authoring a series on practice growth for Physicians Practice. Check out her advice by visiting www.PhysiciansPractice.com and searching by author under "Capko."
PSYCHIATRY CODING
Q. How do I obtain information about psychiatry coding and coding updates aside from American Academy of Professional Coders workshops? Right now, I just utilize the CPT books for any coding questions I might have. Even psychiatry coding software would be helpful.
A. The American Psychiatric Association (APA) offers a Managed Care Help Line (800 343 4671) through which you can access specialists familiar with coding. The APA has also published the CPT Handbook for Psychiatrists that you can order by calling American Psychiatric Publishing, Inc., at 800 368 5777 or by visiting www.appi.org.
Other professional psychiatry organizations (such as state groups and sub-specialty groups) can also offer information. And several programs for Palmtop computers that can help with DS and CPT selection are available at www.healthypalmpilot.com/Diagnosis/Coding.
HIPAA AND APPOINTMENTS
Q. Are we allowed to speak with anyone but the patient regarding patient appointments? For example, can we leave reminders with a patient's family?
A. The Privacy Rule states that you are allowed to speak to the patient directly or to other healthcare professionals about billing and care-related issues. If your patient is present and alert, ask him if you can talk to his family. If he agrees or doesn't object, you can. If your patient is not able to agree - in an emergency, for example - exercise professional judgment and determine whether disclosure is in the best interest of the patient. If so, disclose only information that is directly relevant. The Privacy Rule grants you authority to "make reasonable inferences of the individual's best interest in allowing a person to act on behalf of the individual [patient] to pick up filled prescriptions, medical supplies, X-rays, or other similar forms of protected health information."
Regarding appointment reminders, the Office for Civil Rights' Privacy Guidance explicitly states that covered entities can "communicate with their patients at their homes, whether through the mail or by phone or in some other manner. In addition, the Rule does not prohibit covered entities from leaving messages on answering machines ... A covered entity may also leave a message with a family member or other person who answers the phone when the patient is not at home."
That said, you should notify the patient in your Notice of Privacy Practices that they will be contacted with reminders. Make every effort (and have a policy) to comply with patient requests concerning calling only at home, not at work, or mailing to a P.O. box rather than a home address. Also do whatever you can to further safeguard privacy.
For example, the message you leave with another party should contain only the minimum information; leave a provider name instead of the clinic name, since this will eliminate the release of potential diagnostic information. Here is a sample message: "This message is for Jane Doe. You have an appointment with Dr. Jones on Tuesday at 2 p.m."
Similarly, consider slipping postcard reminders into an envelope or using a format that allows you to at least fold and seal the reminder.
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