Recent Updates on Compliance and Market Rent Legalities
The content discusses recent updates on compliance issues related to budget announcements, ACC site lessors, and market rent legalities. It covers actions taken, including information requests, provider changes, and reviews. Additionally, insights on common law definitions of market rent and tender processes are explored in detail, shedding light on potential inducements and value considerations in rent agreements.
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Presentation Transcript
Budget 2017 Increased compliance announced and funded Feb 2018- revised Red Book published August 2018 DoH (Provider Benefits Integrity Division) requests information from APP s regarding 413 potentially non compliant ACCs November 2018 - 357 ACC site lessors sent request for information (specialist and GP) No specimens ever collected Changed ACC provider and 100% of pathology requests changes to new provider. Atypically high rents based on post code and also on lease type. AGPA Webinar Series May Member Update
October 2018 - 400 ACC site lessors have request for information (specialist and GP) No specimens ever collected Changed ACC provider and 100% of pathology requests changes to new provider. Atypically high rents based on post code and also on lease type. AGPA Webinar Series May Member Update
February 2019 Further 57 ACC lessors are sent letters 95% of original 400 have responded 50 (57) have received no further action at this time letters (May 2019) Remainder continue to be reviewed AGPA Webinar Series May Member Update
Common law definition of market rent Willing buyer and willing seller, with no duress Based on 1907 case law DoH keen to test this against the Act They intend to pick test cases. Act prohibits threats or inducements in determining willing buyer /seller Using threats to reduce pathology rents is a reportable offence. AGPA Webinar Series May Member Update
Tender processes to establish market rent are not a silver bullet Information sections usually state the size and type of practice Number of patients Number of Doctors Practice specialties This is then used by the pathology companies to calculate an expected volume of tests and any trends in test types. Potentially could be seen as an inducement volume and type of test = value = rent AGPA Webinar Series May Member Update
YourGP@Crace 2 Clinical Mix Over 20000 patients registered at the practice Two theatre rooms dedicated to procedures 4 doctors doing skin cancer medicine The largest band of patients middle aged 45-60 YourGP@Crace4kids Opening June 2019 Suites 2-4 we are re branding to capture the market for children
Tender processes need to be transparent Keep records of all emails/ correspondence. Make notes from any meetings. Offers need to be written. Need to state that no volume or type or kind of pathology is implied by the information provided. AGPA Webinar Series May Member Update
For Tenderers Please Note: Tenderers should not infer that the size of the practice is an indication of the number of referrals Our Doctors are free to refer where they wish independent of whom we decide to rent adjoining space to
Remind tenderers that Doctors in accredited practices are free to refer outside the practice. Make it clear in internal documentation that referral to an onsite ACC is not a Practice requirement. AGPA Webinar Series May Member Update
AGPA Webinar Series May Member Update
Associated with Doctors and Practice administration staff (the people who handle the money) Practices and the employee are liable for fraud by employees. Doctors may not be aware of deliberate mischarging by administration staff. Administration staff charging practice needs to be reviewed AGPA Webinar Series May Member Update
PSR remains for inappropriate practice PSR process agrees liability with the Doctor. Practice can also be included if it is determined that the practice influenced behaviour Audit 250 Audits conducted per year Requirement for audit identified statistically or by reporting Aberrant behaviour identified and letter sent Letter to practice as well as the Doctor In the case of Audit the practice is also advised Default liability is 35% for the practice (65:35) AGPA Webinar Series May Member Update
AGPA Webinar Series May Member Update
Liability can be reduced by stating in contracts that Doctors will be 100% liable for mischarging Corporate practices are believed to be asking Doctors to sign charging sheets on a daily basis Discuss billing trends in Practice meetings Make Practice billing trends known amongst Doctors Counsel where there is continued non compliance AGPA Webinar Series May Member Update
AGPA Webinar Series May Member Update
