Book excerpt: Compensation for proctors
Medical staff members have traditionally donated time to the peer review process, including provision of proctoring service when required. However, practitioners today have less time to spend on medical staff voluntary obligations and requires organizations to rely on external proctors.
It is customary for the organization to compensate external proctors. However, payment must not exceed fair market value (FMV). To do otherwise can run afoul of anti-kickback laws. Keep careful records of the proctoring services for which compensation is being made and the amounts of the payments. Determining FMV for proctoring is no different from calculating FMV for any practitioner administrative services, such as paying medical staff officers and committee members. Check what other hospitals in the area are paying for proctoring services, which could range from $50 to $150 per hour. Make such compensation in accordance with a written agreement.
Some practitioners may argue that if you can pay an external proctor, then you should offer equal reimbursement to the internal proctor. This is an organization-specific decision. The organization has to decide whether it considers providing proctoring/review services part of the membership responsibility or one that is reimbursable. Some hospitals do pay a stipend; others within a healthcare system set up arrangements for members of one medical staff to proctor others on another hospital’s medical staff.
Another source of proctors may be a local or regional medical university. Some medical school faculty members, particularly at state-supported schools, believe they have a professional obligation to perform a reasonable amount of external peer review or proctoring. Payments for such services are typically unnecessary. However, as the financial pressure on public and private teaching facilities increases, the expectation to be paid for these services will increase.
Who is responsible for payment?
In many organizations, the hospital or parent institution incurs the cost of proctoring. In some locales, however, the medical staff treasury pays. It is also reasonable to require the practitioner under review to cover proctoring costs. Where this is the practice, the medical staff bylaws should state that the financial burden will be placed on the practitioner. Numerous institutions require the practitioner under review to share the cost of proctoring, with a portion borne by the hospital and a portion by the practitioner.
In most cases, it is not possible to obtain third-party reimbursement for proctoring. If the proctor does not directly assist or otherwise participate directly in patient care, the third-party payers will not agree to pick up those costs.
The Complete Guide to FPPE: Strategies for Medical Staff Professionals, Physician Leaders, and Quality Directors by Valerie Handunge, MA; Christina W. Giles, MS, CPMSM; Jonathan H. Burroughs, MD, MBA, FACPE; and Evalynn Buczkowski, RN, BSN, MS, is available at www.hcmarketplace.com