Concierge Medicine Key Legal Considerations 医疗部重点法律考虑.pptVIP

Case Study 1: Practice Patient Analysis Summary Cost approach approximates the physician compensation received in clinical practice for provision of the services absent any other benefit available to the patients in concierge program. Family practice and internal medicine doctors generally earn more for specialized services such as those provided in the concierge program. The cost approach which looked at weighted average compensation per hour and compensation per wRVU and tRVU across all procedures does not adequately capture the complexity and specialized nature of the concierge services. The market approach approximates what the physicians would charge for the provision of comparable procedures to those offered. Does not consider the added benefits received by patients in the concierge program. Case Study 1: Practice Patient Conclusion FMV Conclusion Annual Concierge Fee Specialty Average Charge Internal Medicine $1,554.82 Family Practice $1,553.47 Case Study 2: Concierge Company Practice Determine FMV of Fee Concierge Medicine Company Charges Physician Practice Facts to Consider AKS Statute of Primary Importance – depends on whether physician is seeing patients participating in federal programs State anti-kickback and fee-splitting laws may also be implicated Case Study 2: Concierge Company Practice Approaches to Value Income – Not Relevant Cost – Relevant Market – Relevant What to Consider when Determining FMV Internal Information All Promotional Literature Agreement Between Physician Practice Company Length of Time Right to Cancel Rights Responsibilities of Parties to Agreement What Services Does Company Provide to Physicians Staff Providing Services Level of Professional Cost to Provide the Services Case Study 2: Concierge Company Practice External Sources of Information What Companies Providing Similar Marketing Services to Non-Physicians are Charging Clients Reasonable Markup or Gross Margin for Marketing Companies Franchise Fees for Non-Me