Private Practice Olio

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I do not believe that is necessarily the case. Can you provide the specific part of the statute that mandates EHR use in such a circumstance?

I think the requirement is that healthcare providers have to provide unfettered electronic access to their records, which in essence mandates EHRs. I don't have time right now to check on specific.
 
I do not believe that is necessarily the case. Can you provide the specific part of the statute that mandates EHR use in such a circumstance?
I think the CURES act actually explicitly says somewhere that it doesn't apply to paper records, meaning that it wouldn't mandate EHR use. Unless I'm misremembering.

It basically says a patient has to have access to their electronic records. It doesn't say their records have to be electronic.
 
I think the CURES act actually explicitly says somewhere that it doesn't apply to paper records, meaning that it wouldn't mandate EHR use. Unless I'm misremembering.

It basically says a patient has to have access to their electronic records. It doesn't say their records have to be electronic.

I believe you are correct. Our state explicitly states EHRs are not required in many circumstances, and legal guidance I have seen federally is similar to this notion. Also, my patients all have copies of their reports, and the referring provider is also sent a copy. Never been an issue for me.
 
I think the CURES act actually explicitly says somewhere that it doesn't apply to paper records, meaning that it wouldn't mandate EHR use. Unless I'm misremembering.

It basically says a patient has to have access to their electronic records. It doesn't say their records have to be electronic.

In addition to my statee laws and guidance on their HHS site, I found these

"While federal law strongly encourages the use of EHR systems, it doesn't mandate it across all healthcare providers in the United States. The HITECH Act, ARRA, and 21st Century Cures Act have incentivized and supported EHR adoption, particularly among providers participating in Medicaid and Medicare. However, the decision to implement an EHR system ultimately rests with individual healthcare providers, based on their specific circumstances and needs."

and this from a HC law firm

"To be clear, the Cures Act does not require you to adopt an EMR or EHR system at your practice. Additionally, at this time, there is no federal ban prohibiting the use of paper records as part of your practice operations. The Cures Act requirements only apply to electronic patient health information. In other words, if you are using paper records, the Cures Act’s final rulemaking process does not apply to you."
 
In addition to my statee laws and guidance on their HHS site, I found these

"While federal law strongly encourages the use of EHR systems, it doesn't mandate it across all healthcare providers in the United States. The HITECH Act, ARRA, and 21st Century Cures Act have incentivized and supported EHR adoption, particularly among providers participating in Medicaid and Medicare. However, the decision to implement an EHR system ultimately rests with individual healthcare providers, based on their specific circumstances and needs."

and this from a HC law firm

"To be clear, the Cures Act does not require you to adopt an EMR or EHR system at your practice. Additionally, at this time, there is no federal ban prohibiting the use of paper records as part of your practice operations. The Cures Act requirements only apply to electronic patient health information. In other words, if you are using paper records, the Cures Act’s final rulemaking process does not apply to you."

I found similar ¯\_(ツ)_/¯
 
I found similar ¯\_(ツ)_/¯

No worries. Additionally, many private practice EMR systems I know people are using are not actually "interoperable" in terms of communication with other systems. I believe different rules apply in situations such as prescribing and whatnot, but for us small fries, no NBD.
 
Registered agent question for you PP people. Did you act as your own registered agent, hire a registered agent company, or use a local attorney?
 
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Registered agent question for you PP people. Did you act as your own registered agent, hire a registered agent company, or usa a local attorney?
I currently use a company, but may do it for myself at some point. I don't really think the fee tends to be worth it, unless your state has some strange reqs for the registered agent.
 
I did it for privacy reasons at first, but then got lazy and haven’t updated it. $120/yr is the lazy tax I pay. I even set a reminder to change it, but got busy and just renewed another year.
I also pay the lazy tax.
 
I’ve been looking into this and seeing what other local/small businesses do. Many have a lawyer as registered agent, especially the ones that operate out of homes like I plan to (e.g., remote businesses or mobile ones with no physical address). Not sure what else those businesses use the lawyer for, but seems to be an included part of the package to have a healthcare lawyer review consent forms, financial disclosures, etc.
 
Registered agent question for you PP people. Did you act as your own registered agent, hire a registered agent company, or use a local attorney?
I hired one, and found that Northwest Registered Agent has been pretty good and reasonable.
 
Has anyone found billing services or ways to bill that they're happy with? I know that SP has a technically low percentage per session, but that's still taking $10 or so for every patient. Is that just the norm? Any better options?
 
Has anyone found billing services or ways to bill that they're happy with? I know that SP has a technically low percentage per session, but that's still taking $10 or so for every patient. Is that just the norm? Any better options?

Hire an admin person on an hourly basis to do billing for you?
 
I have a niche clinical and consulting practice, but still utilize a billing company to handle my workers comp billing; I think I pay 6-8% for them to handle it.

I do all of my legal billing bc it’s higher $ and I deal directly with the lawyers, as there sometimes needs to be a back and forth about retainers and whatever.

My admin is part-time (1099) and handles workers comp pre-auth, scheduling, coordinating record requests, etc. My counselor (1099) does her own scheduling.

I used to have 1099 contract psych techs, but shifted my biz model after my last one relocated. I’m hoping to transition away from clinical work in the next few years, TBD.
 
I'm years away from going into PP, but with the complexities of billing, whether to take insurance, real estate location, networking, hiring others and what to look for in admin members, communicating with lawyers, etc., are there any recommended resources to learn about all the components? I'm sure much of it comes from experience and mentors, but any recommended readings/books/general resources would be greatly appreciated. I'm familiar with Barisa's Business of Neuropsychology, but I'm not sure if the information is relevant given it came out 15 years ago.
 
Just formed my PLLC. I used a registered agent to shield my address in company formation and ein documents. But the DOL in my state wants my physical address for the business license. How did you get around that? I don't want my address to be public record. The person I talked to at Northwest registered agent said he didn't believe I could use their virtual office to do that. My state won't allow a PO Box for this. Any thoughts? What do people do? Was the guy I talked to wrong? I have no clue.
 
I use a box at a UPS store. I kept it bc I started my practice at the height of COVID and didn’t have a permanent address at the time, but it has worked out great bc they sign for my packages and I get notifications email about them.
 
Just formed my PLLC. I used a registered agent to shield my address in company formation and ein documents. But the DOL in my state wants my physical address for the business license. How did you get around that? I don't want my address to be public record. The person I talked to at Northwest registered agent said he didn't believe I could use their virtual office to do that. My state won't allow a PO Box for this. Any thoughts? What do people do? Was the guy I talked to wrong? I have no clue.
I couldn’t get around it. I used a RA for state registrations & my PO BOX (street address) for EIN. My county required the physical location of where services are being delivered. It’s on my business license which is searchable if someone knew what county I live in and was really determined. In searching for ways around this, I found something online that said shifted my perspective. There are so many ways someone can find our address online that unless we were going to take drastic measures to completely scrub it, one more source is not going to make a difference. Voter registration, property tax records, those random phone number lookup sites, etc. And if you bill insurance or if the client submits out of network claims, you need to provide your home address as the service location if you are telehealth from home. So eventually it will be seen. Most will not notice or care. NPI also requires home address for NPI-1 but not NPI-2 for fully remote practices. However, I’ve found that for billing purposes as a solo LLC, most third parties require use of NPI-1.
 
Hi all. I am, as posted in another thread, excited and terrified to be making the leap from working in the VA for many years to private practice. I currently contract with a practice who handles everything for a 70/30 split for extra money in my evening hours. I was surprised to find how much happier I am, and that I'm actually successful at this in terms of patient demand and patients sticking around and getting better. (In the VA, you get sort of used to people not getting better.) I was wondering how insurance rates work? Currently I get paid fairly well through insurance. But is that rate usually the same for years and years? So would I slowly be losing money over time as inflation goes up and the reimbursement stays the same?
 
Hi all. I am, as posted in another thread, excited and terrified to be making the leap from working in the VA for many years to private practice. I currently contract with a practice who handles everything for a 70/30 split for extra money in my evening hours. I was surprised to find how much happier I am, and that I'm actually successful at this in terms of patient demand and patients sticking around and getting better. (In the VA, you get sort of used to people not getting better.) I was wondering how insurance rates work? Currently I get paid fairly well through insurance. But is that rate usually the same for years and years? So would I slowly be losing money over time as inflation goes up and the reimbursement stays the same?

Rates routinely change. CMS does their thing ebery year, sometimes it changes, sometimes it stays the same. My other insurers update their fee schedules on a certain schedule. Though, probably still lagging inflation. Always a good idea to have multiple income streams and differential rates so you can pivot when need be.
 
Rates routinely change. CMS does their thing ebery year, sometimes it changes, sometimes it stays the same. My other insurers update their fee schedules on a certain schedule. Though, probably still lagging inflation. Always a good idea to have multiple income streams and differential rates so you can pivot when need be.
Thank you for this advice and information so much. I am hoping for a mix of assessment and therapy. I didn't know that rates change. What is CMS?
 
Thank you for this advice and information so much. I am hoping for a mix of assessment and therapy. I didn't know that rates change. What is CMS?

Centers for Medicare and Medicaid Services, don't you get those calls/emails every year from your professional associations to submit comment to protect our reimbursements?
 
Centers for Medicare and Medicaid Services, don't you get those calls/emails every year from your professional associations to submit comment to protect our reimbursements?
Yes - but honestly I have been in the VA bubble so haven't really understood it all. I wish I had the bandwidth to pay more attention, but it has been all-consuming to work there.
 
Yes - but honestly I have been in the VA bubble so haven't really understood it all. I wish I had the bandwidth to pay more attention, but it has been all-consuming to work there.

Not to sound too harsh, but if you're wondering why we have stagnant, and in some cases decreasing reimbursements, this is it, right here. Takes about 2-3 minutes a year to send in a form letter that someone else has already made. We have terrible participation from psychologists when it comes comment time. No one but ourselves and our apathy/complacency to blame.
 
Not to sound too harsh, but if you're wondering why we have stagnant, and in some cases decreasing reimbursements, this is it, right here. Takes about 2-3 minutes a year to send in a form letter that someone else has already made. We have terrible participation from psychologists when it comes comment time. No one but ourselves and our apathy/complacency to blame.
I hear you, but please understand I'm in a terrible place right now with work and could use a little grace coming here for help while I try to figure this all out. The depression of this VA situation is real and working there is incredibly hard right now to the point where I wake up at night panicking. I'm open to the criticism, just please not right now.
 
I hear you, but please understand I'm in a terrible place right now with work and could use a little grace coming here for help while I try to figure this all out. The depression of this VA situation is real and working there is incredibly hard right now to the point where I wake up at night panicking. I'm open to the criticism, just please not right now.
VA is having a rough go of it, as is most civil service, for sure. The good news is that private practice is generally much more tolerable and enjoyable. At least IMO. There are certainly downsides, but (again IMO) they're far outweighed by the positives. At least right now.
 
I hear you, but please understand I'm in a terrible place right now with work and could use a little grace coming here for help while I try to figure this all out. The depression of this VA situation is real and working there is incredibly hard right now to the point where I wake up at night panicking. I'm open to the criticism, just please not right now.

Which leads to the question, what exactly has you waking up at night panicking? I work for the VA too, but fall in the mildly annoyed camp at this point. Granted, my personal work situation has not changed much.
 
VA is having a rough go of it, as is most civil service, for sure. The good news is that private practice is generally much more tolerable and enjoyable. At least IMO. There are certainly downsides, but (again IMO) they're far outweighed by the positives. At least right now.
My spouse keeps bringing up the fact that there is no sick and vacation, which makes me anxious, but it seems like one could plan to accommodate that.
 
Which leads to the question, what exactly has you waking up at night panicking? I work for the VA too, but fall in the mildly annoyed camp at this point. Granted, my personal work situation has not changed much.
There's the national factors and then how they have rolled down to my particular site. It's been bad and there are a lot of people who have become extremely difficult at all levels. I can't say much more without giving away who/where I am, but there are a bunch of factors. It has been hard for a couple years now, and now things have gone in a direction that has made it unbearable. I do think it is site-specific as well specific to my particular job in the agency.
 
My spouse keeps bringing up the fact that there is no sick and vacation, which makes me anxious, but it seems like one could plan to accommodate that.

Do people realize that vacation and sick time is part of your compensation package at jobs? As in, your productivity pays for that? I work fewer hours, and take more vacation, than I did in VA and non-VA hospital jobs, and make far more.
 
Do people realize that vacation and sick time is part of your compensation package at jobs? As in, your productivity pays for that? I work fewer hours, and take more vacation, than I did in VA and non-VA hospital jobs, and make far more.
This is good to hear, thank you.
 
Do people realize that vacation and sick time is part of your compensation package at jobs? As in, your productivity pays for that? I work fewer hours, and take more vacation, than I did in VA and non-VA hospital jobs, and make far more.
Yeah, I'd say at this point, from my perspective, the main benefit to employed positions is healthcare. But even that has tax breaks tied to it if you're paying for it yourself.
 
Yeah, I'd say at this point, from my perspective, the main benefit to employed positions is healthcare. But even that has tax breaks tied to it if you're paying for it yourself.
This is all very encouraging. It's scary to make this leap. But if that's the only benefit, I am already good there as I'm covered under my spouse.
 
This is all very encouraging. It's scary to make this leap. But if that's the only benefit, I am already good there as I'm covered under my spouse.
I'd add that an employed position is potentially more stable, and it can be easier to leave work at work, whereas in PP you need to be better about actively setting whatever boundaries work best for you. Although personally, I prefer being able to work when I want to work much of the time (and being able to decide who and what I'm seeing for that work).
 
I'd add that an employed position is potentially more stable, and it can be easier to leave work at work, whereas in PP you need to be better about actively setting whatever boundaries work best for you. Although personally, I prefer being able to work when I want to work much of the time (and being able to decide who and what I'm seeing for that work).
I have a little taste of this in the small practice. Patients have messaged me on the weekends and while I feel an initial pull to respond, I have set the boundary not to until the work day starts. I could see myself working on treatment plans and so on, however. But I want to keep patients well trained to NOT expect an answer from me outside of normal business hours. The flexibility you describe sounds amazing. It was always limited at the VA and now there is absolutely none. I wouldn't be surprised if they installed a punch clock. Not joking. Punch in with your PIV.
 
I'd add that an employed position is potentially more stable, and it can be easier to leave work at work, whereas in PP you need to be better about actively setting whatever boundaries work best for you. Although personally, I prefer being able to work when I want to work much of the time (and being able to decide who and what I'm seeing for that work).
Watching private equity bankrupt healthcare companies and what is now happening at the VA, I question that piece of conventional wisdom. It is feeling more and more like "go to college so that you can have a good job".
 
There's the national factors and then how they have rolled down to my particular site. It's been bad and there are a lot of people who have become extremely difficult at all levels. I can't say much more without giving away who/where I am, but there are a bunch of factors. It has been hard for a couple years now, and now things have gone in a direction that has made it unbearable. I do think it is site-specific as well specific to my particular job in the agency.

If you don't like your job, get a new one. That is not what is keeping you up at night.

Now lots of VA folks I work with landed a job there out of internship/residency and never contemplated any other options. Having tried many options early on, this is less of a concern to me. Other folks are leveraged to the hilt on student loans, house payments, etc. or counting the days until they can punch the retirement ticket shortly.
 
If you don't like your job, get a new one. That is not what is keeping you up at night.

Now lots of VA folks I work with landed a job there out of internship/residency and never contemplated any other options. Having tried many options early on, this is less of a concern to me. Other folks are leveraged to the hilt on student loans, house payments, etc. or counting the days until they can punch the retirement ticket shortly.
? It is what is keeping me up at night. Not sure why you'd say that? I mean I am upset about the country as a whole, but the anxiety and panic have to do with what's going on at my job and the role that I'm expected to manage in it. Maybe it has deeper rooted stuff, but doesn't everything? And I am getting a new job, that's why I'm here posting, to learn best how to do it. It's more than disliking my job, also. It's a day to day dread for what's going to happen next as well as the job taking away everything that made it special (research, student education, etc).
 
? It is what is keeping me up at night. Not sure why you'd say that? I mean I am upset about the country as a whole, but the anxiety and panic have to do with what's going on at my job and the role that I'm expected to manage in it. Maybe it has deeper rooted stuff, but doesn't everything? And I am getting a new job, that's why I'm here posting, to learn best how to do it. It's more than disliking my job, also. It's a day to day dread for what's going to happen next as well as the job taking away everything that made it special (research, student education, etc).

Any life transition can be anxiety provoking. That said, anxiety is about the difference between expectations and reality. We know the reality of the VA currently. What are/were your expectations you are struggling with at your current job? What are your fears about the new job? Is it being unfamiliar with billing? Concerns about loss of steady income? Fear of failure?

Can't help answer questions if we don't know.
 
Any life transition can be anxiety provoking. That said, anxiety is about the difference between expectations and reality. We know the reality of the VA currently. What are/were your expectations you are struggling with at your current job? What are your fears about the new job? Is it being unfamiliar with billing? Concerns about loss of steady income? Fear of failure?

Can't help answer questions if we don't know.
ok fair-- for my current job, it's a done deal, I'm leaving so I don't think I need to say much more. The problem is the public forum. Maybe it's paranoia but I feel like I could be recognized. I will say I've been in the system a long time, so it's not like I don't know the setting. It's just changed beyond what I can tolerate anymore. I will say that I read the whole VA thread and other stuff on this site and the niche I am in within the VA gets a lot of people posting about how challenging it is.

My fears about the new job are failure and not being able to get enough referrals. I don't think they are realistic fears. My little practice has been successful beyond what I imagined, and I was quickly full with a wait list and had to turn people away. But I've never done work that wasn't salaried, steady income and it's anxiety provoking to make that change. My VA job has shot my confidence to hell, so I get anxious in sessions in a way I haven't felt before, but the patients don't realize because I am good at what I do (I realize this cognitively, but no longer feel it emotionally).
 
Something that might help with some of the anxiety--in the time since I've left employment for PP, I've never really seen a slowdown of postings for jobs for psychologists. The specifics of the jobs may change, but in general, at least right now, if a psychologist needs to find work somewhere, they can probably do so. It might not be a great location or great pay or in a healthy work environment, but the jobs are there.

And as you've experienced, the demand for psychological services in many areas is pretty high. Especially if you take insurance.

I'm guessing you may get a decent AL payout once you leave VA. If so, you could always tuck that away as an emergency fund if you don't need it for any startup costs. And/or set aside some extra money in your business checking account so you can keep paying yourself for a time even if you don't have any income coming in (this is obviously more important if you have employees other than just yourself).
 
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