Genesis HealthCare System Policy and Procedure Title:
Physician CME and Business Expense Policy
Manual:
Physician Services
Number:
3
Effective Date: January 27, 2015
Purpose: To establish guidelines for Genesis Physician Services (“GPS”) physician Continuing Medical Education (“CME”) and business expense reimbursements. Scope: All GPS physicians with CME, travel, and/or other expense reimbursement allowance. When a physician has specific provisions for CME and Business Expenses in his/her employment agreement, this policy shall supplement his/her employment agreement, and the scope of this policy shall be limited so as not to conflict with specific contractual terms governing CME and Business Expense allowances. Policy: It is the policy of GPS to reimburse its partnered physicians, within contractual and GPS-policy allowance, for CME and business expenses to maintain and advance their professional practice with GPS. This policy outlines limitations and instructions for physician reimbursements. For any questions or expenses outside of this policy, physicians shall contact his/her Practice Manager or Regional Practice (“PM”) Administrator (“RPA”) to determine whether such expenses will be reimbursed. When necessary, the PM or RPA shall consult with the Chief Physician Network Executive for advice. Procedure: 1. CME Allowance – Each GPS part-time or full-time physician receives a reasonable expense allowance per year for CME and related educational expenses. CME amounts specifically included in physician’s employment agreement shall govern when a dollar amount is specified in physician’s employment agreement. If the agreement states “reasonable CME expenses,” reasonable CME expenses shall be limited to $5,000 per year, pro-rated for a physician who is less than full time. Notwithstanding, the NOC Compensation Sub-Committee may review and recommend to GPS to increase or decrease the amount considered to be reasonable CME expenses per year. 2. Managing Physician’s CME Balance: Each physician should be aware of his/her CME balance available. Physicians may track CME reimbursement and available balance for the year by physician’s paycheck stubs (listed as an expense line-item) or requesting the balance from physician’s RPA. a. Deductions to CME Balance: All CME reimbursements shall be deducted from physician’s CME balance by physician’s RPA or PM to maintain an accurate reporting of CME each year: i. What reimbursed items are deducted from physician’s CME balance? All reasonable expenses related to physician’s educational training/maintenance for his/her GPS practice, including but not limited to the following: 1. CME Courses and Related Travel Expenses (see Section 4 for instructions) 2. Board Certification: Preparation Courses, Examination and Maintenance Costs 3. Annual fees for membership in medical associations 4. Medical books and journals ii. What reimbursed items are NOT deducted from physician’s CME balance? Ohio Medical License/DEA, medical staff memberships requested by GPS, and insurance credentialing fees shall not be deducted from physician’s CME bank when reimbursed to the physician
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Genesis HealthCare System Policy and Procedure unless physician’s employment agreement states to deduct these expenses as CME. iii. Timing of deductions: CME reimbursements shall be deducted from physician’s CME bank for the calendar year in which expenses are incurred so long as expenses are submitted within 30 days of incurring such expenses. Any CME reimbursement submitted by the physician outside the 30 days allowed and approved for reimbursement shall be deducted from the calendar year when payment is made. st b. Resetting CME Balance: CME balances shall reset every January 1 to the full CME allowance based on each physician’s employment agreement and GPS policy. i. For new physicians, CME allowance shall be pro-rated during the initial year. GPS will reimburse or pay directly reasonable expenses incurred prior to physician’s start related to his/her onboarding with his/her GPS practice. If items are paid directly by physician prior to start, reimbursements will be made after physician’s start date and approved CME items will be removed from physician’s initial CME balance for the year. ii. For terminating physicians, ending balance shall be pro-rated for the final year. All requests for reimbursement must be related to CME and other expenses incurred for physician’s GPS practice. Expenses for renewals spanning outside the effective employment period may be pro-rated for partial payment. 3. Non-reimbursable Items: Any items that cannot be documented, that are unrelated to physician’s practice, or that are outside other limitations of physician’s employment agreement and/or GPS policy will not be reimbursed and will be out-of-pocket expenses to the physician (e.g. donations, political action committee support, out-of-state license/DEA, expenses without itemized receipt, travel not required for attending a conference, items exceeding CME limitations). 4. Instructions for CME Travel Expenses (i.e. course fee, travel, lodging, meal expenses) a. Approval Requirements: CME course must be (1) within the United States, (2) related to physician’s responsibilities at Genesis, and (3) within a date range that allows for alternative physician coverage in physician’s absence. Physician is not required to obtain pre-approval when the above requirements are met; if the physician has any question as to whether the above requirements are met, physician should contact their RPA or PM to inquire as to whether the CME expenses will be covered prior to incurring out-of-pocket expenses that may not be reimbursable. b. Limitations on Travel Arrangements and Meals: Physician shall select and pay directly for registration, tuition, travel, lodging and meals related to CME attendance. Physicians shall exercise judgment to avoid excessive and/or unnecessary costs to GPS (e.g. room or car upgrades, late conference application fees, etc.). GPS has the ability to remove excessive and/or unnecessary costs that are submitted by Physician. i. Meals: Maximum reimbursement per day is based on the travel location as set by the RUNZHEIMER REPORT, which lists the 100 largest cities in the United States and is updated on an annual basis. Itemized receipts are required for each meal. ii. Car Rental: Use of car rentals is to be used only when other ground transportation is not available, is more costly, or impractical. iii. Lodging: Physician shall make his/her own hotel reservations. To avoid inter-city travel and obtain lowest cost, physician should stay in designated hotels listed in program brochure when possible. iv. Entertainment, travel companion, and alcohol expenses shall not be reimbursed. 5. Submitting requests for Reimbursements: Physician shall submit reimbursement requests to his/her RPA with itemized receipts and proof of purchase within thirty (30) days from incurring such expenses and attach the appropriate GPS request form (if applicable). a. CME Travel Reimbursement Form – Physician shall complete the Genesis Travel Reimbursement Form, attach all itemized receipts and a conference agenda and/or certificate
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Genesis HealthCare System Policy and Procedure of completion, and submit to his/her RPA within 30 days from return trip. i. Costs associated with entertainment, travel companion, and/or alcohol expenses shall be stricken by the physician for receipts attached that included both reimbursable and nonreimbursable items. b. Requests for additional information or corrections – If the RPA or Accounting requests corrections related to Genesis Travel Reimbursement Form reimbursement, physician shall make corrections promptly so that the Form is returned within the time allowed. 6. Payment to Physician: Approved physician expense reimbursements shall be submitted to accounting by the RPA (or as delegated to the RPA’s practice manager) for payment. a. Reimbursements shall follow the Genesis normal accounting and payroll process to ensure that expenses are correctly categorized within IRS requirements. b. Payment will be made in the next available payroll period, which may be up to 35 days from the date submitted, depending on timing of accounting/payroll processing each pay period. Responsibilities: GPS Partnered Physicians: GPS physicians are responsible for reviewing GPS policies and his/her employment agreement, prior to incurring costs, to determine whether CME or other business expenses are reimbursable. GPS physicians shall ensure appropriate and timely reporting of CME and other approved expenses within the parameters of GPS policy and/or their employment agreements. Regional Practice Administrators: RPAs are responsible for reviewing reimbursements prior to submission to accounting and, if applicable, the CPNO to ensure expenses are reimbursable in accordance with GPS policy and/or physician’s employment agreements and that the physician has funding available for the CME expense. Any request requiring additional information or changes shall be submit back to the physician for correction and sign-off. RPAs are responsible for managing their physicians’ CME balances available – which includes resetting the CME balance each year to the annual amount and deducting paid CMEs based on GPS policy. Accounting/Payroll: The Accounting/Payroll department(s) is responsible for reviewing appropriateness of business expenses and submitting amounts for payment. Accounting/payroll should respond to inquiries regarding status of payment or amounts paid and work with the RPAs to timely resolve physician issues. Chief Physician Network Officer (“CPNO”): CPNO will be responsible for final sign-off on capital items and expenses exceeding $5,000.00. CPNO shall also decide on requests that are outside the physician’s employment agreement and/or GPS policy. References: NA Document Development: Physician Services, Contract & Compliance Manager Document Approval: GPS Operations Leadership Team Network Operations Council Compensation Committee Network Operations Council
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Genesis HealthCare System Policy and Procedure Document History: Review Dates: Revised Dates: Effective Date: 01/27/15
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