Eternal Rest
The eternal matter of fair compensation to agents and brokers placing business in the NYSIF may be laid to eternal rest if the “second floor,” legislators and regulators listen to the agents’ groups who have eternally pleaded for this measure of fairness. PIANY has just amended legislation to include a requirement for the New York State Insurance Fund to pay commissions to licensed brokers. The bill (S.4558-A), which is sponsored by Sen. Kenneth P. LaValle, R-1, and Assemblyman David I. Weprin, D-24, has been sent to the Senate Insurance Committee for consideration. Read it and weep…or reap…the benefits of pushing your local representative to take this seriously and introduce some fairness to this process.… Physicians—possibly your clients—thinking of transitioning to a concierge model, have some legal and compliance issues to consider, apart from giving his clients a sense of comfort (not abandonment) as the change is made. Here are some issues to share with them:
- Medicare-covered services: If you don’t choose to opt out of Medicare, be careful about concierge services that could be considered Medicare-covered services. The Office of Inspector General of the U.S. Department of Health has not issued any specific guidance on which services may be considered covered services, leaving practices with some uncertainty.
- Written contracts: Practices should have a written contact with each concierge patient. The contract should describe the fee the patient will pay and the services the practice will provide.
- HIPAA issues: If you have a hybrid practice, where you combine traditional and fee-paying patients, and you use a separate company to provide concierge services, there may be a need for a business associate agreement with that company. Be sure you maintain privacy if you communicate with patients via texts or emails.
Point here is that the failure of two major businesses that pioneered direct primary care practice has left the model in question. And then come these exposures.
Ultra-elite concierge practices that charge as much as $80,000 a year to provide care to our state’s wealthiest patients, as interviewed by The New York Times, said business is booming. In addition to 24-hour access, these physicians will make house calls or meet clients at work or an airport. They also will provide their patients with immediate access to the country’s finest specialists and hospitals, unlike most people who have to wait as long as 29 days for an appointment.… Jan Scites and her bright team at MSO are marching straight onward, adding services to the mix for their members. They have just partnered with Finys, a leading national provider of insurance software and services. Finys is a modern enterprise platform with more than 25 implementations for property and casualty (P&C) insurance organizations. Worth a look.