Integrated Private Practice :
A Good Idea ?
By Jordan Saint John and Stephen D . Bittinger
What is a Multi-Discipline Practice ?
Healthcare in America is becoming increasingly integrated . For instance , the American Medical Association (“ AMA ”) notes rapid changes in healthcare delivery and an expanding environment of integrated modes of practice 1 . A strong impetus for this change was the enactment of the Affordable Care Act , which created a broad regulatory framework for such initiatives as clinical integration , care coordination , quality and other performance metrics , and cost containment . However , the AMA understandably focuses on physician-led practices that integrate several medical specialties .
By contrast , this article discusses multi-discipline practices , which deliver non-medical modalities alongside more conventional medical services . These non-medical modalities , such as physical therapy , chiropractic , naturopathy , and acupuncture , are often designated by the term “ complementary and alternative medicine ” (“ CAM ”) and are widely accepted in the general populace 2 . Confusingly , such multi-discipline practices are also sometimes known as integrated medicine .
More particularly , this article focuses on multi-discipline practices that integrate medical services with a non-physician ( MD / DO ) provider ( e . g . DC , NP , PA , PT ) through ownership or operation , which we will refer to as integrated practices because of the joint control and / or ownership interests of the non-physician and physician . These practices are frequently set up by the non-physician because of Corporate Practice of Medicine restrictions
(“ CPOM ”), who arranges with a physician to either oversee medical services provided by a mid-level medical practitioner , or to enter a contractual relationship whereby the non-physician provides administrative services through a management service organization (“ MSO ”) to a medical practice , and also offers complementary and alternative medicine services to the patients .
Increasing numbers of non-physicians are utilizing or considering this model , and for good reason . For one , it allows the non-physician to offer more healthcare services to his / her current patients . Non-physician providers are able to financially benefit from the joint relationship with a physician ’ s scope of practice , as long as there is careful compliance with federal and state laws . Meanwhile , the physician benefits through an additional income stream for his / her oversight role and / or through handing off the administrative side of the practice , allowing him / her to concentrate on the practice of medicine .
Despite the attractiveness of these arrangements to both parties under proper legal formation and operation , pitfalls abound , especially when the practice serves federal healthcare program (" FHP ") beneficiaries . Along with a discussion of a typical model of an integrated practice , this article presents some of the possible pitfalls of these arrangements , and is meant to be a cautionary tale .
1 http :// www . ama-assn . org / ama / pub / about-ama / our-people / member-groups-sections / integrated-physician-practice-section / about-us . page .
2 “ Nearly 40 percent of adults report using complementary and alternative medicine .” http :// www . mayoclinic . org / healthy-lifestyle / consumer-health / in-depth / alternative-medicine / art-20045267 ( posted Oct . 18 , 2014 ).
TODAY ’ S PRACTICE : CHANGING THE BUSINESS OF MEDICINE 22