OIG Issues Advisory Opinion Regarding Physician On-Call Pay

A key factor noted in the opinion is that, based on an independent valuation, the hospital certified that the per diem rates are commercially reasonable and fair market value for the services provided.

Other OIG considerations included the following:

  • The hospital administers a per diem fee, calculated annually in advance, to specialist physicians to provide unrestricted on-call coverage for the emergency department.
  • All specialists on the hospital’s medical staff are offered the opportunity to participate in the call arrangement. Thus, the on-call pay cannot be offered to select physicians or physician groups only within the specialty.
  • Physicians who elect to participate in the program enter into one-year written agreements containing automatic renewal provisions, under which they agree to serve on the call coverage panel.
  • The arrangement is limited to specialists who are only required to provide “unrestricted call” (does not require physical presence at the hospital during the call time but requires availability within 30 minutes).
  • Physicians who participate must agree to provide the inpatient care required by any patient that is admitted by the physician. The participating physician is also required to provide certain follow-up care in their offices, without additional compensation, following discharge of the patient.
  • A uniform methodology is used by the hospital to allocate call coverage equitably among participants within each specialty.
  • Physicians are monitored for compliance with the program requirements.

The OIG concluded that it would not impose administrative sanctions on the hospital in conjunction with the arrangement as described in the opinion.

In December of 2011, SullivanCotter released its seventh annual Physician On-Call Pay Survey Report. The report includes data from 189 organizations, including Level I, II and III trauma centers, non-trauma center hospitals, medical groups and other facilities providing on-call services. On-call pay rates from over 40 physician and advanced practice clinician specialties are presented in the survey by call type (restricted versus unrestricted) and are reported by trauma center status and trauma call versus non-trauma call.

Other on-call pay practices covered in the survey that directly correlate to factors the OIG considered in its recent opinion include the following:

  • Organizational payer mix.
  • Prevalence of payment for on-call coverage, by specialty.
  • Practices used to compensate physicians for providing services when called in.
  • Prevalence of “excess call” (the practice of requiring some number of uncompensated call coverage shifts before becoming eligible for on-call pay), by specialty.
  • Number of physicians participating in call rotation, by specialty.
  • Telephonic on-call coverage practices.

According to the 2011 survey participants, the following pay variables affected the reported rates paid for on-call coverage:

  • Local market rates.
  • National market rates.
  • Frequency of call.
  • Likelihood of being called in when on-call.
  • Acuity and intensity of care provided when on-call.
  • Payer mix.
  • Amount of inpatient follow-up care required.
  • Malpractice risk.

SullivanCotter’s 2012 Physician On-Call Pay Survey Report is currently closed for participation. The survey report is scheduled to be published in late January 2013. To pre-order a copy of this survey report, or to participate in a future release of the survey, please contact SullivanCotter’s Survey Team at surveys@sullivancotter.com.

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