ER Call Coverage FMV and Advanced Practice Providers (APPs)

July 10, 2020

Aguilar Interviewed by HCCA on FMV issues surrounding ER Call Coverage and APPs

In a case about payments for call coverage and advanced practice providers (APPs), Sitka Community Hospital in Alaska agreed to pay $4.125 million in a civil monetary penalty (CMP) settlement with the HHS Office of Inspector General.  According to the settlement, which was obtained through the Freedom of Information Act, OIG contends that from April 1, 2013, to April 25, 2019, Sitka Community Hospital paid remuneration to 16 providers in the form of excessive compensation under emergency department call coverage arrangements and APP arrangements.

Call coverage arrangements between hospitals and providers are common.  It is also common to see APPs participate in the call coverage services as well.  However, if these APPs are employed by the facility, hospitals will need to be careful in how they establish FMV for the physician ER call rates to ensure that no undue benefit is created.  See settlement with St. Vincent’s Medical Center in Bridgeport, Connecticut for providing free APP services to physicians.

Interviewed by HCCA’s Report on Medicare Compliance, Joe Aguilar comments on FMV as it relates to call coverage arrangements and advanced practice providers (APPs).

“Health systems need to concern themselves with a few key value drivers when determining the fair market value call rate for a particular specialty at a specific hospital,” said Joe Aguilar.

Here are some things to consider when paying for call coverage:

  • Concurrent versus nonconcurrent call shifts
  • Use of APPs, fellows, or residents for call
  • Restricted versus unrestricted call shifts
  • Consideration of a stacking analysis for employed physicians

Read more here for things to consider when paying for call coverage

By Joe Aguilar, MBA, MPH, MSN, CVA

Joe Aguilar  is a Partner with HMS Valuation Partners in Atlanta, GA

Search here