Lets say a private practice Urology group with an in-house AP POD lab merges with a large hospital and becomes a Hospital Out-Patient Department. Would this affect the legality and/or billing allowances for their existing Path lab? Could they still operate their Path lab? I'm just not sure I know the answer to this.
HOPD with In-office lab?
- Thread starter ucp1980
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I think they are allowed to operate any way they want. For TC reimbursement purposes, I think it depends on the place of service where the procedure was performed. If these are hospital-registered patients and procedures are performed at the hospital, a lot of the technical billing may fall under the DRG. If the procedures are performed outside of the hospital at the group's office... then it's a different story.
Overall, the PC portion should be able to be billed as usual. I would assume that in order for the PC to be billed, the pathologists doing the reads need to follow MCR rules (e.g. work 75% of time in place where procedures are being performed). I might be out of date when it comes to these things, but I think the operations would remain the same.
Whether or not this set up conflicts with other existing agreements, say between the hospital and the main pathology group... *shrug*. Does the main path group who manages the hospital lab have complete exclusivity for all pathology specimens? This may not even come into play if the specimens are being taken from an office setting outside of the hospital.
Overall, the PC portion should be able to be billed as usual. I would assume that in order for the PC to be billed, the pathologists doing the reads need to follow MCR rules (e.g. work 75% of time in place where procedures are being performed). I might be out of date when it comes to these things, but I think the operations would remain the same.
Whether or not this set up conflicts with other existing agreements, say between the hospital and the main pathology group... *shrug*. Does the main path group who manages the hospital lab have complete exclusivity for all pathology specimens? This may not even come into play if the specimens are being taken from an office setting outside of the hospital.
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Ouch! That is a treacherous position to be in. You need to fix those two positions asap
Oh, don't get me wrong, I don't have any business relationship(s) to this hypothetical scenario. I have a clinician friend on the other side of the country who has a Pod Lab in his group and was asking me about this. I just didn't know the answer. The conversion to HOPD status was kind of a new concept to me, although its seemingly commonplace
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Why would the hospital keep the POD lab open? Route the specimens to the mothership. I've never seen a hospital or PE take over a practice and allow the POD lab to keep operating. Just a bunch of unnecessary costs. Your friend will be losing that business.
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How is the hospital going to bill globally if they don't own a pathology group?
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I assume this would create some sort of conflict since there is an existing group at the hospital. I guess it depends on what that contract looks like.
If the hospital wants to bill global (especially MCR cases), then they would need to certainly employ the pathologist(s) that currently work in the in-office lab. I think there are certain rules that need to be met in order for global billing to be performed. Place of service matters (e.g. hospital outpatient, in-office facility, ASC, etc). Place where specimens are technically processed also matter. Billing with these POD lab arrangements get sticky depending on everyone's ultimate goal and motives.
It might make more sense for the hospital to bill TC and let the pathologists who own the hospital contract bill the professional component independently. It's more straight forward. If there is an overabundance of work, the hospital group could employ the POD pathologist to handle the unexpected bump in outreach volume.
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No way the hospital keeps that POD lab going. Makes no sense to not send the work to the mothership. The broom closet converted to an AP lab will be reverting back to being a broom closet. That group better be planning for the loss of that business. The hospital group will take on the work.
Ok … let me clarify a couple things that might clear up some assumptions you’re making.
1. The hospital (let’s call it Hospital A) does NOT have in-house pathology. There is a private local group of pathologists based at another non-affiliated hospital (hospital B) that is contracted with Hospital A. I.e. they accept specimens from hospital A via courier, and they cover frozens, cytology adequacies, and lab medical directorship at hospital A. There is no mothership, as far as Hospital A Pathology is concerned.
2. The clinical group, their ASC and their POD lab is on the other side of town from Hospital A. Specimens are obtained at their ASC, processed and signed out on-site by a contracted pathologist. There is no planned change in facility location for the immediate future (although I’m told this will likely change eventually).
3. All that is really changing is the tax ID.
Why would the admin at hospital A relinquish all of the Pathology revenue to a 3rd party Pathology group when they can operate a profitable POD lab as part of their HOPD?
Again, my questions returns to the legality of this HOPD/POD lab. The commentary thus far has implied that it doesn’t seem to be an issue of legality, but rather contractual nuances between the players here, which makes sense.
1. The hospital (let’s call it Hospital A) does NOT have in-house pathology. There is a private local group of pathologists based at another non-affiliated hospital (hospital B) that is contracted with Hospital A. I.e. they accept specimens from hospital A via courier, and they cover frozens, cytology adequacies, and lab medical directorship at hospital A. There is no mothership, as far as Hospital A Pathology is concerned.
2. The clinical group, their ASC and their POD lab is on the other side of town from Hospital A. Specimens are obtained at their ASC, processed and signed out on-site by a contracted pathologist. There is no planned change in facility location for the immediate future (although I’m told this will likely change eventually).
3. All that is really changing is the tax ID.
Why would the admin at hospital A relinquish all of the Pathology revenue to a 3rd party Pathology group when they can operate a profitable POD lab as part of their HOPD?
Again, my questions returns to the legality of this HOPD/POD lab. The commentary thus far has implied that it doesn’t seem to be an issue of legality, but rather contractual nuances between the players here, which makes sense.
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Barring any contractual constraints we don't know about... let's assume that Hospital A is not beholden to the group providing coverage to their hospital... I don't see why the hospital should relinquish the ability to use the clinical practice's in-office lab set up. They probably own the old tax ID, which also has the roster of physicians (including the pathologist(s)) and also maintains the appropriate billing credentials. This is something that they would want to keep, especially if it is helping them generate revenue.
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Are we talking just GU specimens? I mean a urology office based pod lab may be set up for prostate/bladder biopsies and turps but that's about it...can't imagine a large hospital is going to let the GU specimens walk out the door for the sake of billing globally a small portion of its specimens, particularly if it runs the risk of irritating the path group that manages frozens, cyto ROSE, laba management, etc...
Unless those specimens aren't coming through Hospital A's door anyway...but I'd think the hospital would be afraid of losing revenue by having patients bypass the hospital? How does the hospital benefit--being able to claim/tout a big urology partnership and agreement that all surgeries / OR time would be done at the hospital?
We have a large private GU group in our area and I don't see them ever partnering up with 1 particular hospital...overwhelming majority of biopsies are done in their offices and read out by some slimeball path that contracts with them...they operate at all the hospitals, I don't see them wanting to lose patients by partnering up with one of the multiple health systems.
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I don’t blame these pathologists for taking these jobs. I saw a job for 500k at a busy GU pod lab. I wouldn’t call them slimepaths. You’d be stupid to not take a job like this unless the work is excruciatingly overwhelming or the clinicians are complete aholes. Plus, there aren’t many jobs (yes even in this supposedly good job market) in my area so a 500k job is enticing. But then you got to think about job security as well if you take one of these in office lab jobs.
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If you are semi retired it wouldn't be a bad gig but I got to think you are hurting your future employment when inevitably the practice is bought out by private equity or a large health system.
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Yes probably better if you already have good surgpath experience in a hospital setting under your belt before taking these jobs. In case you lose your job, you can just look for a hospital based position.
Solaris is a private equity entity that bought out a urology group near us. The pathologists who manned that lab didn’t lose the contract however.
I myself am a GI-Pod lab Pathologist, and don't consider myself a slimeball. I worked for years in a private practice that was owned by a national, now transnational corporation ... you want to talk about slimeballs? go look at the ranks of corporate suits that want to bully young Pathologists, pay them modestly, and restrict their career options by draconian contracts.
I built great relationships with my GI colleagues who treat me with respect and as one of their own. I feel valued for my expertise, and am paid handsomely in return - not only with financial gains that cut my time track to "semi retired" by about a decade (north of $750K annually), but also with autonomy and ample time to enjoy my life outside of work.
I love being a pathologist, was trained at excellent institutions, and am damn good at it. I am also good at understanding most aspects of the business climate in our community, and know what I'm worth. I feel bad for pathologists out there that accept being paid less than half of what they draw, and allow no-talent corporate clowns and their sales cheerleaders to control their practice and usurp their rewards.
I really hope this FTC ban on non-competes goes through, because i think it will go a long way to help such Pathologists. In any case, to anybody bashing POD lab pathologists just because they're POD lab pathologists - I would say please know better that we're not all poorly trained whipping boys for clinical groups ... some of us just prefer being paid what we're worth, in an industry landscape where that is becoming ever more challenging to accomplish. If you can't see good opportunities for yourself and seize them, that's your problem, not the fault of the "exception to the Stark Law". Besides, if there ever were some legal changes that banned the POD lab arrangements (BIG IF), my god what a great position i'd be in!
But I digress . . . lets not turn this thread into a POD lab pro/con. I believe that horse was killed long ago. wait ... did I just do that?
I built great relationships with my GI colleagues who treat me with respect and as one of their own. I feel valued for my expertise, and am paid handsomely in return - not only with financial gains that cut my time track to "semi retired" by about a decade (north of $750K annually), but also with autonomy and ample time to enjoy my life outside of work.
I love being a pathologist, was trained at excellent institutions, and am damn good at it. I am also good at understanding most aspects of the business climate in our community, and know what I'm worth. I feel bad for pathologists out there that accept being paid less than half of what they draw, and allow no-talent corporate clowns and their sales cheerleaders to control their practice and usurp their rewards.
I really hope this FTC ban on non-competes goes through, because i think it will go a long way to help such Pathologists. In any case, to anybody bashing POD lab pathologists just because they're POD lab pathologists - I would say please know better that we're not all poorly trained whipping boys for clinical groups ... some of us just prefer being paid what we're worth, in an industry landscape where that is becoming ever more challenging to accomplish. If you can't see good opportunities for yourself and seize them, that's your problem, not the fault of the "exception to the Stark Law". Besides, if there ever were some legal changes that banned the POD lab arrangements (BIG IF), my god what a great position i'd be in!
But I digress . . . lets not turn this thread into a POD lab pro/con. I believe that horse was killed long ago. wait ... did I just do that?
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You’re no slimepath. Good for you. I’d do it if I was in your shoes. People just player hating.I myself am a GI-Pod lab Pathologist, and don't consider myself a slimeball. I worked for years in a private practice that was owned by a national, now transnational corporation ... you want to talk about slimeballs? go look at the ranks of corporate suits that want to bully young Pathologists, pay them modestly, and restrict their career options by draconian contracts.
I built great relationships with my GI colleagues who treat me with respect and as one of their own. I feel valued for my expertise, and am paid handsomely in return - not only with financial gains that cut my time track to "semi retired" by about a decade (north of $750K annually), but also with autonomy and ample time to enjoy my life outside of work.
I love being a pathologist, was trained at excellent institutions, and am damn good at it. I am also good at understanding most aspects of the business climate in our community, and know what I'm worth. I feel bad for pathologists out there that accept being paid less than half of what they draw, and allow no-talent corporate clowns and their sales cheerleaders to control their practice and usurp their rewards.
I really hope this FTC ban on non-competes goes through, because i think it will go a long way to help such Pathologists. In any case, to anybody bashing POD lab pathologists just because they're POD lab pathologists - I would say please know better that we're not all poorly trained whipping boys for clinical groups ... some of us just prefer being paid what we're worth, in an industry landscape where that is becoming ever more challenging to accomplish. If you can't see good opportunities for yourself and seize them, that's your problem, not the fault of the "exception to the Stark Law". Besides, if there ever were some legal changes that banned the POD lab arrangements (BIG IF), my god what a great position i'd be in!
But I digress . . . lets not turn this thread into a POD lab pro/con. I believe that horse was killed long ago. wait ... did I just do that?
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I agree that you should be paid what you're worth. I think POD labs have this stigma for "underpaying" to some degree. If you're making north of $750K... how much is your employer banking off of you? Is their overhead really that much? At the end of the day, a job is a job, and your happiness is all that matters. The only person you need to look out for is yourself. No one else will (at least not to the extent that you deserve).I myself am a GI-Pod lab Pathologist, and don't consider myself a slimeball. I worked for years in a private practice that was owned by a national, now transnational corporation ... you want to talk about slimeballs? go look at the ranks of corporate suits that want to bully young Pathologists, pay them modestly, and restrict their career options by draconian contracts.
I built great relationships with my GI colleagues who treat me with respect and as one of their own. I feel valued for my expertise, and am paid handsomely in return - not only with financial gains that cut my time track to "semi retired" by about a decade (north of $750K annually), but also with autonomy and ample time to enjoy my life outside of work.
I love being a pathologist, was trained at excellent institutions, and am damn good at it. I am also good at understanding most aspects of the business climate in our community, and know what I'm worth. I feel bad for pathologists out there that accept being paid less than half of what they draw, and allow no-talent corporate clowns and their sales cheerleaders to control their practice and usurp their rewards.
I really hope this FTC ban on non-competes goes through, because i think it will go a long way to help such Pathologists. In any case, to anybody bashing POD lab pathologists just because they're POD lab pathologists - I would say please know better that we're not all poorly trained whipping boys for clinical groups ... some of us just prefer being paid what we're worth, in an industry landscape where that is becoming ever more challenging to accomplish. If you can't see good opportunities for yourself and seize them, that's your problem, not the fault of the "exception to the Stark Law". Besides, if there ever were some legal changes that banned the POD lab arrangements (BIG IF), my god what a great position i'd be in!
But I digress . . . lets not turn this thread into a POD lab pro/con. I believe that horse was killed long ago. wait ... did I just do that?
The only advice that I can give to anyone who is employed (and not the employer)... be very careful with whom you choose to work with. You're letting them bill on your behalf. Ultimately, it is your name on the line. You will go down with the ship if a carrier or CMS decides to do an audit. There are certain labs that come to mind when you read about things like "false claims act" etc. Examples have been made.
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The slime balls are the people who own pathology labs and offer 200k a year for signing out craploads of GI and offer you two weeks of vacation. How about those people who paid $700 an hour (prob worst rates in all of medicine) for locums few years back and people here on SDN were saying how we were just complainers lol.
I am self-employed, so I work with them as a 1099. No doubt the Clinical group is pocketing A LOT off of me, but they share better than any Pathology groups do (including ones I've worked for, and one's I've interviewed at over the years. Don't even get me started on academic institutions).
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What kind of daily case/slide volume do you see at the pod lab?
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My friend has to look at 100 88305 at Quest and makes less than half of what you make. Imagine how much you are making for them after a career working for them. Some people don’t have any other options though sadly.
Goes to show you, you are always making money for someone else unless you have your own business. Might as well do well for yourself while doing so.
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...and there's no oversupply. Right
There is an over supply of poorly trained pathologist, pathologist with poor work ethics and pathologist with poor spoken/written English.
Recently I had to review some cases by a certified pathologist who is supposed to have over a decade of working experience. Some of the cases a PGY3 can do better than that person.
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Any examples of this poor quality work?
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This is what happens when A: anyone can get into pathology B: almost everyone passes the boards
I won't divulge too much details, but some of the lesions that were missed would've been 10 second "spotters" on board exam, and at other times the gross description would not pass a PGY3 rotation in that specialty.
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I didn't say he was a slimepath, like the term applies because he works at a pod lab, i said slimball path...because the few times i've talked to him he's been an ahole, he personally is a slimeball, and upcharges everything, ordering literally every single solitary IHC and special he can legally charge for. I suppose I should have been more specific but the fact everyone instantly made that connection is interesting.
And I'm not saying i wouldn't take a job at a GI group over a slide mill like Quest or LabCorp if I was burned out in a corporate mill or disillusioned at my group, but that doesn't mean I think the pod lab arrangement is a good idea or hasn't impacted our profession for the worse.
I'm happy for your adequate compensation; but your scenario is the exception not the norm, and by a wide margin. 125 88305s / day is good volume but not insane, particularly when it's GI biopsies, and you can attribute your financial outcome to your hard work, path acumen and self-acknowledged skill set, but let's be honest...GI doctors (and derms and urologists) are not screening their path applicants for the top 10%...they want someone they can trust, get the work done on time, and not **ck up...those of us banking >95th percentile are not the hardest working most savvy pathologists avail, there's an immense amount of luck, circumstances (including regional reimbursement rates) and personal connections involved.
And I'm not saying i wouldn't take a job at a GI group over a slide mill like Quest or LabCorp if I was burned out in a corporate mill or disillusioned at my group, but that doesn't mean I think the pod lab arrangement is a good idea or hasn't impacted our profession for the worse.
I'm happy for your adequate compensation; but your scenario is the exception not the norm, and by a wide margin. 125 88305s / day is good volume but not insane, particularly when it's GI biopsies, and you can attribute your financial outcome to your hard work, path acumen and self-acknowledged skill set, but let's be honest...GI doctors (and derms and urologists) are not screening their path applicants for the top 10%...they want someone they can trust, get the work done on time, and not **ck up...those of us banking >95th percentile are not the hardest working most savvy pathologists avail, there's an immense amount of luck, circumstances (including regional reimbursement rates) and personal connections involved.
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Regardless, it's hard to not be irritated by these arrangements when you've seen your derm, gi and gu volume dry up the last 5-10 years because despite being prompt, not screwing up, generating timely reports, and being ever so accommodating, you're still kicked to the curb when the gi, gu and derm groups find someone to do the work for cheaper.
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you're absolutely right about everything you mention in both of your posts, with the exception of the GI docs "screening for top docs". They are pretty damn picky here, which is how I ended up with the opportunity show them what quality looks like.
Nevertheless, I can absolutely understand your frustration. When I was a resident I used to condemn these arrangements on the regular. I wish they didn't exist, to be honest. But they do. If you can't stop the tsunami, better get a good boat. Not to mention the fact that since I deeply care about the quality of diagnostics in my community, I almost feel an obligation to make sure some of these practices aren't relying on bad pathologists, which they have in the past.
And to respond to HeyDalaron - I would say one of the most egregiously common problems is the over diagnosis of H. pylori, barret's (with/without dysplasia), and non-colon IBD-related lesions ... among others (Medical Liver!!). I swear half the C. Diff cases in our area are unnecessarily iatrogenic (thats probably hyperbole, but you get my drift)
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I've seen a lot of big national labs and some regional labs egregiously overdo things on special stains. I know that there is rampant "up front orders" in most of these places as well. All I can say is to bring a life vest for your boat because I cannot help but think that everyone who reads GI pathology is going to get the "bundle hammer" thrown down.
Are you being serious or joking?
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Time and experience has taught me to be accepting of in-office pathology labs and self-referral arrangements that use the IOAS stark loophole. I am happy the in-office pathologist is happy with his/her gig and $750K salary (so classy). Glad he/she feels valued by his/her money greedy gastroenterologist colleagues. Working in an in-office pathology lab is certainly not risk-diversified but will likely be stable over the next 5-10 years. While I do not participate in these arrangements, I understand and do not judge these pathologists. I don't expect any near-term change to outpatient pathology billing. As usual, I laugh when I receive my annual AMA membership letter with dues. My message to gastroenterologists, Ob/Gyns, dermatologists, and urologists is: I am not your colleague. I am your adversary. I will engage with the insurance industry and CMS/HHS to advocate for bundled billing arrangements as long as I am in practice.
You always have to have a contingency plan, I agree. That said, I really don't see how bundled payments are going to affect outpatient GI in the near future. It has been on the table for over a decade in the context of in-patient GI, and that has still not had a large degree of participation or impact on the outpatient practice(s).
Would be curious to hear more about your understanding of this though. It seems to me that bundled payments are there to keep you "on or under budget", and when the outpatient GI pathology is as straightforward as it is in terms of processing and minimal extra stains/ancillary costs, seems like it would be more manageable as the expenditures are more "fixed" than a hospital based lab. That said, the overall cost cutting is certainly a factor in and of itself
The beauty of forums like this is that I can forego the "class" so that I can help inform this community on what a practice /career can look like. I know I always looked to this community for candid descriptions of their experience(s), and I found it valuable. I would certainly never brag about this in the flesh. . . . and its not a salary, its just S-corp revenue ;-)
It's all well and good, until your GI "colleagues" realize they can pay someone else $350K instead of $750K. They can each get a new, lower end Tesla with the savings. Every year. Agree with Doormat's statement - these folks are adversaries.
I believe there is still an oversupply.
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Its all well and good until your hospital fires your group. You jealous hospital guys always say the same BS.
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The frog has now been thoroughly boiled when $750K in 2023 dollars is the exemplar of “greed”. That was a very good (not great) figure in 1990.
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Everyone is expendable. The goal should be as ucp1980 stated -- have a contingency plan aka be more diversified. No one is safe. I've put people out of business. I've had business taken from me. Adapt or die.
Ever consider the possibility that GI docs actually WANT their patients to get better? Sucky pathologists don't help with that.
I am sure they are quaking in their boots.
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Blame the academics. Not us pp folks!
True. Just keeping our fingers crossed that someone doesn't come along and offer our overlords something cheaper.
So what is the optimal practice situation, at least before we save a lot and diversify with other income streams? Don't want to keep moving and begging to try to maintain my standard of living, such as it is.
