Episodio 35: Hablemos de cumplimiento normativo: planes de remuneración de médicos y tendencias para 2024

En este episodio, las presentadoras de Let's Talk Compliance, Jana Kolarik, socia del Grupo de Práctica de Atención Médica de Foley, y Angie Caldwell, directora de PYA, hablan sobre los planes de remuneración de los médicos y las últimas tendencias en materia de remuneración de los médicos para 2024.

Para obtener más información sobre la serie de podcasts «Let’s Talk Compliance», haga clicaquí.

Tenga en cuenta que la transcripción de la entrevista que aparece a continuación no es literal. Hacemos todo lo posible por ofrecerle un resumen de lo que se trata durante el programa. ¡Gracias por su consideración y disfrute del programa!

Angie Caldwell

Hello and welcome to the Let’s Talk Compliance podcast series of Health Care Law Today presented by Foley & Lardner and PYA. I’m your co-host, Angie Caldwell, managing principal of the Tampa office for PYA.

Before we begin our show, we want to remind you to subscribe to Health Care Law Today, either on iTunes or your preferred podcast app. Please visit healthcarelawtoday.com or pyapc.com. For today’s show, my co-host, Jana Kolarik, partner in Foley’s Health Care Practice Group, and I will explore physician compensation plans and the latest recent trends in physician compensation of 2024.

Jana, I’m so excited to do this. With Let’s Talk Compliance, we work together of course, to bring other topics throughout the year to our listeners. And then in doing so, you and I often have sidebar conversations about recent trends and other things that we’re seeing in the industry. And so today, we are going to be talking about those trends with our audience and more broadly.

And specifically, most recently, you and I have both experienced many questions around compensation planning, and how do organizations really get off to the right start and set the right foundation around their compensation plans, their compensation documents, as well as their contracts. So, from your perspective, what are the key things that organizations should be doing to set the right foundation for their compensation plans?

Jana Kolarik

Thanks, Angie. I think this is something that you and I have been discussing a lot. We just did a recent blog that mentioned the physician compensation compliance planning, just as a highlight –  here are things to pay attention to. And then we did highlight some current trends that we’ve been dealing with. I’m happy to be doing this podcast here today to sort of round out some of that stuff.

So, as we were talking about this, in my mind there’s certain things, highlights that I am going to mention here at the beginning and then we can flesh these things out. Number one is guardrails. So, as you’re thinking about your compensation plan document and planning for compliance, you need to be thinking about guardrails.

Number two, you need to be thinking about communication, and that’s internally with the physicians related to these compensation plans and how you’re communicating things internally.

Number three, how do you operationalize it [the plan]? And that can be, there we’ll talk about contracts. There, we’ll talk about communication that’s happening on an ongoing basis with your physicians to make sure they understand what’s happening not only at the beginning, which is super important, and that transparency be there, but also throughout the process. So, there are no surprises. People get very agitated (as you and I both know) when compensation is not expected or changes in a compensation are not expected.

And then as a fourth point, we talked about clawbacks. I think the more politically correct (PC) term for that is reconciliations, and how are you dealing with that reconciliation process such that the things that we’ve talked about, the guardrails, the communication, the operationalization, all of those things come down to a potential reconciliation. And you don’t want those things to be a surprise to anybody who is going to be subject to reconciliation. So, all those things build up into that process.

From a guardrail perspective, we talked about creating a policy internally from a compliance perspective, so that it’s part of the framework, it’s part of the fabric of your compliance program. And as part of that, so you talk about one, how agreements are requested just as a very beginning. Who’s requesting them? That goes to and how they’re requesting them and papering that. That goes to the commercial reasonableness piece that we talk about frequently.

Number two, who is drafting and reviewing those agreements to ensure legal and operational compliance? Three, and this, we’re going to blow this out in this discussion, how fair market value is determined? Four, who’s executing the agreement? Are you having different levels of authority make different decisions based on how much money is at play? And five, how are the agreements being tracked with regard to term and termination provisions, which becomes important. A lot of organizations have software that does that for them, which is super helpful.

So, in just talking about fair market value (FMV), I want to talk to you and get your thoughts on the use of surveys versus people like you, valuation consultants, and when do you get that assistance. So, we’ve talked in the past about, but I want your initial thoughts about what does that look like in that policy. And I think getting your input on how to bake that into your plan, into your policy is important.

Angie Caldwell

Yes, [we have talked about] that policy and determining when to go outside for a fair market value opinion. And as you and I have discussed, not every single arrangement needs an outside fair market value opinion. There’s so much that can be done internally within the organization provided that the guardrails are set appropriately, and that the organization then follows those guardrails and documents the outcome of following those guardrails around fair market value. Really, it becomes a part of the policy. And then that policy is based upon the risk tolerance of the organization.

We work with some organizations where the risk tolerance is not very high for their reasons and they understand those reasons. And so, they might send everything out for a fair market value opinion where the total stacked compensation, and I know we’re going to come back to that word here in a minute, is maybe greater than the 60th percentile total, or the 75th percentile, or even perhaps the 90th percentile. Again, it’s all based upon the organization’s risk tolerance, and also what their internal policy and the guardrails that they’ve set include.

I do think it’s important from an FMV perspective, because there are many good reasons why a physician is compensated in excess of the 75th. I know Jana that you and I have commented on this many times in articles and in perhaps even another podcast and at other times that the 75th percentile is not a bright line. It’s not a yes or a no. And so, because of the notion that it is a bright line, it often ends up in a policy or procedure as the “end all.”

I want to say that that [the 75^th percentile] probably shouldn’t necessarily be the cause or the direction of the policy. While 75th percentile is one measure, there should also be other measures that include perhaps compensation per work relative value unit (wRVU), or productivity, or hours worked, or some other guardrails or combinations of guardrails, thresholds within the policy to determine when something goes out for an FMV opinion.

With that, thinking about the stacking then, we are talking about just how you’re determining that threshold and what that total cash compensation is – to really think about that total stack of compensation. Jana, I know you and I have had discussions about this, and I want your thoughts on that – what is your definition of stack? What should the definition of stack be? Because we’ve also talked about using the same terms and the same definitions when describing compensation and the guardrails is very important. What is your definition of stack?

Jana Kolarik

So my definition of stack, and that’s super helpful background. I think my definition of stack is when you’re dealing with a physician who obviously has a clinical life, but also on top of that has a medical directorship, has call pay, has a variety [of compensation]. So you look at the stacking of the compensation.

I think one of the things that’s important to remember with physician compensation, when you’re dealing with the Federal physician self-referral law and you’re dealing with the Anti-kickback Statute, and you’re talking about fair market value, it is a continuing obligation.

When you look at fair market value, you look at the total, as you said, the total compensation that’s going to that physician, and is the total compensation for the physician fair market value for services rendered?

One of the things that we’ve dealt with is: If you have a physician who has a clinical life and then they have a medical directorship, some of this is taken care of if in that medical directorship, for example, you have an hourly component and the physician is turning in time sheets, and so you can track that. You know that hourly piece is fair market value on an hourly basis, and then you understand the clinical life of the physician. And at the beginning, that’s sort of set and they stay at the same production level. So you’re monitoring it. You’re not having to adjust it because they’re staying fairly busy and the same busy as they have been.

But I think as you add more things to that, as you add the call pay, and that was one of the things that we discussed in our blog, and we should probably just mention as a side note here, because it can become important. Call pay is something from a health system perspective, a hospital perspective, it’s frequently expected that if you are an employee, that you will do a certain amount of call pay. That’s generally reflected in your medical [staff] bylaws that have a certain expectation of a certain amount of call. Sometimes that’s deferred to the specialties to make decisions on a more granular basis about what their call will be from an employed physician perspective. But frequently it’s left loose.

So how tight that is, and what the expectations are, and the fact that they be communicated effectively to the physicians and that it be across the board, it’s important that that be generated and understood at the beginning. We’ve dealt recently, and you and I have had many discussions about “day one” call pay.

So paying call to community physicians for specialties is common, so they’re not employed by the health system. And there’s not otherwise maybe an employment agreement that has baked into base compensation, a certain amount of call frankly, from that perspective as well. So you’re paying outside people for call. That’s expected.

For some reason, I get the sense that that expectation of call has bled into some of the other specialties, even if they’re employed physicians. And I want you to talk to us a little bit about how that may affect the compensation if you’re not attuned to the fact that some of this [call] may be included in what you’re already paying. So can you suss that out a little bit for us?

Angie Caldwell

Absolutely. And I’m going to tie it back to what you were saying at the beginning of our discussion today about ensuring that guardrails are set, that definitions are set. That again, from a compliance perspective, all of this needs to be really tied up tight in the contract and within the compensation plan. What we mean by call pay, and what are the terms surrounding call pay.

And then this also ties back into the notion and the definition of stacked compensation, because we want to include call pay on day one, or we’re thinking about call pay on day one rather.

So if you think about survey data, and again, something from a transparency perspective, which was one of your key elements at the top of our discussion. You think about transparency, we also need to think about what surveys an organization is using to determine compensation, analyze compensation, compare compensation for the physician so they know where they are performing against their peers. Within that survey data, call pay is an included element.

So even the surveys are considering total cash compensation (TCC) stacked. It is in there. So when you’re looking at a TCC total cash compensation metric from any of the surveys, it is all-inclusive. So then if as a hospital employer of physicians, you are then adding day one call pay, you have potentially double counted call pay.

So from a stacking perspective then, [if you add in call pay to the survey TCC,] you’ve double counted call. So your stack just got bigger than when comparing and analyzing that physician compensation against your guardrails, and also then determining fair market value compensation.

It’s really important from a definitions perspective, and from a terms perspective, and from a transparency perspective to know what’s in the survey data. And to make sure that the physician understands that when you analyze compensation for FMV, you’re analyzing total compensation for FMV, as well as the individual parts. The individual parts sum up to the total, but we’re also looking at total compensation for that stacked amount.

Jana Kolarik

So what does that look like? If you as a hospital system is using, and best practice is to use more than one survey, so you’re using a couple of surveys. You’re looking at a surgeon, you’re looking at one of the surgical specialties, and you’re pulling [data]. And that particular physician is at the 75th percentile with regard to his or her productivity. So as you’re sort of approaching something and somebody says, “Look, they’re at the 75th percentile.” To me, the questions then that are asked are, what are you looking at when you look at productivity?

Okay, so are you looking at does that physician use advanced practice providers (APPs)? You and I have talked about this multiple times. And then what type of [work relative value unit](wRVUs) are you using to figure out that data?

Because the surprise to me recently was a client who had been using wRVU data and communicating it with physicians, but it wasn’t quite the most accurate wRVU data. Why don’t you take it from there? Those two issues just teed up from a productivity perspective as your approach with this sort of, okay, well the 75th, it should be this. And then we’re going to put on top of that some call pay. And look, it’s market here locally to pay day one call pay. What is your initial reaction to just that out of the gate?

Angie Caldwell

Right. And there’s a lot to that. And my first reaction is, okay, we need to understand what the physician is actually doing. The surveys measure 75th percentile productivity, and that’s measured in wRVUs. But we all know that physicians do more than things that are just measured by wRVUs, including providing call, including all of the things that come into that compensation stacking analysis. So really, it gets down to understanding what the physician is doing, what the minimum work standard is for the physician, and then really adding all of those things together.

And you mentioned APPs. There’s also a supervision of APP element. We know that in many cases a physician is supervising an APP. And so then how does that interplay into the productivity of a physician? So how that interplays is that many times the APP is acting as an extender for the physician’s clinical services. And I know that we’ve written about this and we’ve spoken about this before. Just that from a wRVU productivity perspective, not talking about the other elements of productivity that a physician has, but thinking about that APP and how those extended services show up in the physician’s productivity.

Jana Kolarik

And show up in the billing data to be very clear.

Angie Caldwell

Exactly, show up in the billing data. And then as a result, show up in the physician productivity data. So it’s very important related to your compensation plan as well as your contractual agreement to ensure that wRVU is defined as personally performed, modifier adjusted. And I’m going to let you comment on that specifically, and that everybody understands what that means. Because then that becomes very important then in determining that physician compensation. So Jana, if you could comment a little on terms, and defining wRVU, and what best practices are.

Jana Kolarik

That’s right. You can have things that are billed under your national provider identifier (NPI). And frankly, global surgical packages that include the services, clinical services before, the clinical services after, as well as the surgery itself. You can have situations where you’re billing under the physician NPI in situations of incident-to or split shared. And figuring out or having a sense of who’s actually performing those services. And if you’re using multiple APPs, figuring out the clinical piece of it that is actually being performed by somebody else. And understanding that going into a compensation [plan] for a physician is important.

So if you have a surgeon who’s using four APPs, then you’ll just understand out of the gate that there may be some inflation of the wRVUs at issue because that physician uses [APPs] appropriately, right? Appropriately uses those APPs as extenders for that practice, and it’s showing up under the billing data for that particular physician.

And you mentioned, so that needs to be, when you’re compensating somebody, what’s being billed under that NPI is not necessarily what you compensate that physician for. And that’s one of the things that the Centers for Medicare and Medicaid Services (CMS) made clear in one of the more recent Federal Register issuances where they said, Look, we think that this is being conflated, these concepts of billing versus compensation, and you need to make sure that you’re paying people for the services that they’re performing.

As part of that, when you get your wRVU data, if it’s stripped of the modifiers, then it’s stripped of the things that actually impact wRVUs and will decrease the amount of wRVUs attributable for that particular service. I’ll just give the example of a multiple procedure situation in a surgery. You’re not going to pay the… Well, nobody pays that particular surgeon for doing each one of those procedures for the full [reimbursement] amount during that surgery. There is a modifier adjustment to it. And so the wRVUs are adjusted accordingly.

They should also be adjusted in transparency with the physician so they [the physicians] understand that the true wRVUs being attributed to them are not only adjusted for the APP issue, but also adjusted by modifier. So that’s one of the things that came up recently when we realized that some of the data that had been provided to the physicians at issue had not been modifier adjusted, and so had been frankly inflated and they thought that they were more productive than they really were.

Angie Caldwell

So at the top of our discussion, you mentioned transparency, and it’s a word that I think you and I have both used since then a couple of times. From your perspective, thinking about transparency, what can an organization do to ensure transparency? And I’ll comment upon this as well. But from your perspective, what are some of the best practices you’ve seen?

Jana Kolarik

That’s a great, great, great question. So I think fundamentally, the communication from the beginning of the compensation planning. Look, we’re reviewing the compensation. Who’s at the table, right? So lawyers, I’m a lawyer. I like lawyers. I think lawyers have a seat at the table. Counsel has a seat at the table. And is it inside [or] outside counsel? I think it depends on the complexity of the issue sometimes.

Valuation folks should be at the table, the physician compensation folks should be at the table. Whether you bring in valuation consultant, I think again, depends on the complexity. The outside resources are a complexity-driven issue.

But with regard to the transparency, it should be, physician leadership needs to understand it at the executive level, but also the physician leader of the specialty to understand the nuances and the communication that may be fomenting, being stirred up, related to the physicians [and the compensation plan/planning]. So those things can be addressed and the communication can be effective from the very beginning.

So number one, transparency from the beginning as you’re looking at compensation plans. And then I think transparency with regard to, I mean these issues that we’ve talked about – the continuing fair market value obligation and clearly defining terms. And I want you to comment on all this stuff too, or the things that you find the biggest issues from your perspective. Touch bases – when are the check-ins with the physicians with regard to that compensation that they have during the year? And then that whole issue of reconciliation and being very transparent from the very beginning.

And the last pieces that I’ve mentioned are all things that need to be in the contract. So when you’re baking in concepts into your agreement, whether or not it’s in the agreement itself or it’s in a plan that’s referred to in that agreement, some of these issues need to be very clearly defined and in front of the physicians.

Again, surprises are bad, so no surprises. And that physicians are following along, they’re following the trail of what’s happening with them so that they, again, no surprises from the very beginning. So being at the table, who do you see when you’ve dealt with effective planning? Who’s at the table during that discussion?

Angie Caldwell

Yes, absolutely. And you hit so many good points there, Jana. Again, just from a transparency perspective. But really at the table, you have to have the physician contract or the provider contract administrator and their team. The recruiter needs to also understand the elements of the arrangement. They need to be at the table. Your data analyst needs to be at the table, again, because they are the ones pulling the data or pulling information out of the system for the administrators and for the leaders. They need to understand that, again, the definitions and the terms from a consistency perspective, and counsel. And then like you said, to the extent external consultants are needed, then they’re also at the table.

And so I rattled off five or six folks. And your real goal is that if they are asked about how compensation is determined, if you asked any one of those five or six people for your organization, would they answer the same way and use the same words [terms]? That’s really what you’re trying to get to. Because so many times, organizations will come together and they’ll use different words to describe the same thing, which then actually ends up creating confusion.

And then when that team goes to discuss the agreement, discuss the plan with the physician, if you’re still using different terms, then that leaves the definition of those terms and the use of those terms open to the interpretation of the physician. And as we all know, I would do it – we would all do it – we see the contract or the plan document once, we put it down. And we’re not going to pick it up again until we’re angry and there’s a problem.

So you want to make sure that everyone is using the same language, and then that language is matching what is in the plan document and what is in the contract. So that if (heaven forbid) that does happen [a problem], they’re able to go look at those definitions within those documents. They are hearing the same thing. They’ve heard it across all five or six people within the organization. And it just lessens the confusion, and frankly, opportunity for frustration and opportunity for error within those discussions.

Because as we know, physicians are scientists, and they are looking for anomalies. They are looking for things that don’t meet the pattern/that fall out. And so again, if there’s a rogue term, or a rogue definition, or rogue data in the process, they’re going to find it and they’re going to question it as you would hope that they do.

So Jana, when we’re talking about that, you and I aligned exactly as far as who should be at the table from a best practice perspective, and really focusing on those terms from a consistency perspective.

And along with that, it’s the cadence of the communication as well. I mean, you and I have talked about, gosh, not everybody has the luxury of being able to have a system that reports out monthly, or quarterly, or semi-annually. And so if that luxury is not yours, then the compensation plan document and the contract become your cornerstone for everything.

And then with that, best practice of course would be to communicate with a physician from a transparency perspective more often, which leads me to another point of you have to make sure that the systems that are supporting your reporting for that transparency are doing the right thing, which then ties back to the wRVU.

Jana Kolarik

Correcto.

Angie Caldwell

[Tying back to] the discussion we had a moment ago because it seems simple – the organizations that we work with have been computing wRVUs for a decade or more at this point. But it does happen when systems break down, when payer requirements change, when systems don’t interface correctly, that whole wRVU determination process sometimes breaks down. And that’s not caught until very late in the process.

Which gets us to one of the very last topics that you brought up at the beginning of our discussion about clawbacks. So what do you see as best practices from a contractual perspective related to clawbacks?

Jana Kolarik

It’s a good question and excellent points. I think the contract needs to emphasize the continuing fair market value obligation. And that if it falls outside of fair market value for any reason, then a reconciliation will need to occur. So that, it needs to be just stated in the agreement.

And as you said, one of the pieces that I just want to make a note of, and you and I are on the same page with regard to this as well, is who’s at the table is important, because you need to make sure that these plans of a compensation for a particular specialty, in the grand scheme is doable from an operational perspective. Can you operationalize it? And if you don’t have all the staff that you need in order to operationalize it, that needs to be a consideration from the get-go. And those people who are in charge of monitoring this [compensation/wRVUs] need to be able to operationalize it.

So when you talk about what should be in the contract. –  ideally that reconciliation as I said, continuing fair market value obligation. From a process perspective, I don’t know that it needs to be in the contract, but it should be in the plan that you’re doing it however frequently you can do it. We’ve talked monthly. Monthly is great. If you can do monthly, and you can keep people at least understanding what’s happening. And then you can have the reconciliation happen, for example, quarterly, so that they understand, “Look, we’ve paid you, but you’ve not tracked,” and that “you [physician have] seen this in the monthly statements or you’ve seen this now in the quarterly statement.” And so we will be keeping compensation from you, or you [physician] will be paying back compensation at that point in time.

And look, reconciliation can happen for a number of reasons, and you and I have experienced it. It can be a downturn in productivity. Or for whatever reason, it can be somebody who needs to take an extended vacation – e.g., because of family. It can be somebody who just has decided that they’re in the latter part of their career, and so they’ve decided to step off the gas a little bit.

But whatever that looks like, it’s important that there be, as you said, mechanisms in place in the contract. And it needs to be very clearly stated because people, again, we’ve said no surprises. And people do get sued. Physicians will sue you sometimes, unfortunately, if it isn’t clear and they believe that the contract is to their benefit and not reflecting the reconciliation that you’ve done at the end of a contract or that they haven’t been paid.

So making sure that all that is very clear what they will be paid, when the reconciliation will happen, and getting that information in front of them is important.

Tell me what you’ve seen or what you’ve seen be effective with regard to those reconciliations or those check ins that are happening. Because ideally, if there’s software – that’s beautiful – it can update them on a monthly basis.

If there isn’t, it’s this whole, can you meet, can you check in with them on the quarterly basis face-to-face or at least send an email and have open hours for them to come talk to you? What have you seen be effective there? Talk to me about effectiveness with regard to planning.

Angie Caldwell

To your point, software is wonderful provided that it is working as intended.

Jana Kolarik

Yes, agreed.

Angie Caldwell

And reflects reality, right? And things happen. Things happen with data input. Things happen with schedules, because I know QGenda is a very popular software out there that folks use for scheduling, especially in hospital-based specialties as well as with call coverage.

And so it’s great if it’s keeping up with the last minute changes that occur because a physician’s child is sick, and they need to stay home, and all of those things. So again, thinking about the process, we’ve got to make sure that we’re reconciling with that.

So really [we need to be sure] systems [are] working correctly. Making sure that the check-ins, as you said, are regular. It’s transparent when they’re going to happen, so that the physician knows when to expect the data for the reconciliation so that it just doesn’t show up out of the blue, and they’re expecting it at the sixth month, they’re expecting it at the eighth month, whatever your procedure is. So they know when to expect that.

And it’s really important. Again, we talked about guardrails at the top of our discussion. Ensuring that from a compliance perspective, you have a plan before the horse is too far out of the barn, that you’re able to corral the problem before it becomes a bigger problem.

All of that’s really important. They need to know when it’s coming. They need to know why it’s coming. They need to understand how the information and the data is pulled together, so that they can have a meaningful discussion around that reconciliation. And if the contractual agreement and compensation plan has been documented thoroughly, they will then understand what’s going to happen if their reconciliation is out of whack.

And frankly, it provides the administrators a great opportunity to check their data. If wRVUs are popping out for half of the year, and the physician has 30,000 wRVUs, then likely you know something is wrong in your wRVU computation determination process. So it [the reconciliation] also provides you an opportunity to do a bit of a self audit, if you will, as part of that mechanism and that check-in with the physician throughout the year.

So Jana, just thinking about all of the topics that we’ve discussed, what have we missed that you thought that we should discuss today, or should we wrap for our listeners and talk about some key takeaways?

Jana Kolarik

I think we should talk about key takeaways. One of the things that I want to mention just as a footnote to what we’ve discussed about the reconciliation process is when I say we mentioned Stark, we mentioned Kickback, and fair market value being a continuing obligation, especially if you’re an employee (looking at Stark primarily). If you’re outside of fair market value, that is an obligation for your employed physicians. So, you’ve got to fix that.

So the reconciliation is just part of the compliance process. And if you aren’t, then there are Stark implications for being outside of fair market value, which affect the claims at issue, which can be astronomical [numbers] if you’re dealing with some of these specialties.

So keeping ahead of that and keeping on top of it is important not only for relationships with your physicians, which is hugely important, but also from a compliance perspective to keep things tight and to keep you from having to do self-disclosures, having to explain things a couple of years in when you’ve been outside of fair market value for a number of years, and now you’re having to have those much more difficult discussions with physicians about paying back money. Or you risk losing those physicians because they’re not willing to? So I just wanted to put that as a footnote that the implications of this are relationships, right? But they’re also hugely impactful from a compliance perspective.

Angie Caldwell

Yes. And if I could footnote to your footnote related to… you made such a good point about relationships and about, again, we’ve talked a lot about making sure that everything is documented, and transparent and consistent, and everyone knows what’s going on. If you are in an organization and you find that your physicians are coming to you frustrated constantly about the cadence of communication, about the transparency, about the process – notice I didn’t say about the amount of compensation – that’s a different issue.

But if they’re coming to you with those concerns and expressing frustration, then as an organization, it is time to sit down and think about the compensation plan, the process, the design, and what could be improved.

Because like you said, those relationships are so important. And from a time perspective, it becomes time intensive [issue] to deal with the frustration of the physician. So it’s better to have that plan in place from a consistency and a communication perspective. So key takeaways for our listeners, Jana?

Jana Kolarik

I think I mentioned them at the beginning, but I do think one of the key takeaways is that you have a written policy and plan in place. I mean verbally, us talking through this, you talking through it internally is important. But documenting it and documenting these key things that we’ve mentioned here today, you need to have it in writing, and you need to follow it, and it needs to be available for others to see what the process is. And for others to understand, again, from a relationship perspective and from a compliance perspective. So that would be to me, the big key takeaway. But I mentioned those four things at the beginning of the discussion, and those are fundamentally my key takeaways.

Angie Caldwell

Absolutely. And I would add too that making sure that the process is working as intended. So once you have that document in place, what’s in the document becomes your roadmap for check ins, communication, and process. So making sure that the process is aligning with that document then becomes critical to the organizations that are administering physician compensation.

Jana Kolarik

Agreed. Totally agree. And I just want to do a quick reminder too of our Let’s Talk Compliance annual event, which is happening January 23rd and 24th. So for our listeners, please stay tuned and definitely sign up to get our updates. But we’re going to do two days and we’re going to have CLE, CPE, and CEUs, for the compliance professionals as well. So lawyers can attend, compliance professionals can attend. And we’ll be doing a neat variety of topics this year. So I always look forward to it, so I just want folks to keep that in the back of their mind. It’s coming up!

Angie Caldwell

Absolutely. Our seventh annual. So exciting.

Jana Kolarik

That’s right. It is. It is. So thank you, Angie. You know I always enjoy these discussions and I hope others enjoy as well. It’s always good to get together and thank you. Thank you for this.

Angie Caldwell

You’re very welcome. Thank you.

Jana Kolarik

We want to thank our listeners for joining our Let’s Talk Compliance podcast series with Health Care Law Today – your connection to timely legal updates in the health care and life sciences industry. We encourage you to subscribe to this podcast. Visit Foley’s Health Care Law Today, blog at healthcarelawtoday.com and pyapc.com. If you like this show, don’t forget to subscribe and be sure to rate us five stars. Until next time, I’m Jana Kolarik of Foley & Lardner.

Angie Caldwell

And I’m Angie Caldwell at PYA. Thanks for listening.