Who owns the facility?
The physician group that provides the ancillary services owns 100% of the facility. (Two or more groups can share ownership of ancillary services as discussed below.)

What type of ancillary service can be provided?
A group can provide any type of ancillary services that is related to its practice. We generally focus on physical therapy, occupational therapy, speech pathology, pulmonary rehabilitation and imaging services.

What has changed to make ancillary services more attractive?
The recently finalized Stark regulations provide clear and distinctive guidance as to how groups can provide ancillaries without violating the Stark rules. In addition the new regulations eliminate the requirement that physicians “directly supervise” ancillary services. “Direct supervision” required the presence of a physician whenever a therapist or other staff member provided ancillary services. The final regulations allow ancillary services to be provided anywhere in the same building or in a centralized location without the presence of a physician (subject to otherwise applicable Medicare supervision requirements).

How do groups comply with the Stark rules?
The Stark regulations specifically allow physicians to refer patients for ancillary services under the following conditions:

Supervision

• The referring physician or another group physician must supervise the individual who is providing the ancillary services. This supervision must comply with Medicare payment and coverage rules for the specific therapy.
• For example, physical therapy services do not need to be “directly supervised” and therefore a physician does not need to be present when the services are provided; however, a physician typically must be present when cardiac rehabilitation services are provided.

Location

• Ancillary services can be provided in any office that is owned or leased exclusively by the group. (E.g., a Los Angeles-based group can provide ancillary services in an office suite that it leases in Anaheim.)
• Ancillary services do not need to be provided in or adjacent to the group’s office.

Billing

Ancillary services must be billed by one of the following:

• The physician performing or supervising the service
• The group practice
• A company that is wholly owned by the group
• An independent third-party billing company

Can two or more independent groups or solo practitioners share an ancillary services facility?
Yes, as long as each group (or solo practitioner) that shares the facility has an office where they routinely provide their full range of physician services at the same street address as the facility.

Can an ancillary services facility have outside investors?
If a group shares a facility (as discussed above), other groups or solo practitioners can own a portion of the facility. If not, a group must own 100% of the facility.

Can a facility accept referrals from other physicians?
Yes.

How many patients are necessary?
We have no hard and fast guidelines as to the minimum number of patients that are necessary in order for a group to economically provide its own ancillary services because the size and staffing of the facility can be tailored to meet specific patient levels.

How will ACS help assess the need for ancillary rehabilitation services?
We work with a group’s members and staff to assess practice and referral patterns. This assessment involves examination of a number of factors, including the number of referring physicians, number of active patient files, specialty mix, insurance carriers and commonly-used diagnostic codes. This assessment will help determine whether a group can benefit from providing certain ancillary services and, if so, how the services should be added and operated.

How much capital is necessary to start a rehabilitation facility?
This will depend on the number of patients that will be treated at the facility. In most cases, groups can start physical rehabilitation programs with approximately $150,000 of start-up capital. This amount covers rent, payroll, equipment, deposits, utilities, other costs, and a contingency reserve of approximately $30,000.

Can the start-up capital requirement be financed?
Yes, in the vast majority of cases. Typically, a group will be able to finance start-up capital needs with a line of credit from its bank. Alternatively, we have arranged for financing from Compass Bank. Compass will generally finance 75% of the start-up capital, with interest at a floating rate of 2% over prime, and a 7-year amortization term.

What will patients think of the added services?
Patients are becoming better educated about their medical needs and choices and are seeking physicians who are leaders in their medical community. With the addition of high quality, easily accessible and readily available ancillary services, patients will have a unique opportunity to maintain an active lifestyle at their highest level of independence and function.

Will our current staff be required to devote a significant amount of time to ancillary services?
We assume that your staff is at a full capacity. Our goal is to minimize strain on your existing staff. In fact, the addition of ancillary staff and services should reduce the workload of your current office staff. We have found that the rehabilitation and imaging staff members handle many of the telephone calls and repeated questions from patients, giving your office staff more time to attend to other responsibilities.

Why Use ACS?
A number of groups who are planning to add ancillary PT services ask us to explain why they should use ACS instead of adding PT services on their own, acquiring an existing PT practice or using a local therapist to help them develop a program.

The short response to this question is that we have more experience helping physician groups develop their own PT programs than any other firms or individuals. While groups should certainly consider recruiting local therapists to staff their PT program, we provide the following vital assistance that local therapists are often unable to provide.

Physician-Based PT - ACS specializes in helping medical groups develop and manage their PT services. In contrast, most local therapists are familiar with the operations of an inpatient hospital or outpatient private PT facility, but have little or no experience working within medical groups. Our assistance allows the therapists to be a provider of services-concentrating on their clinical schedule and not on the administrative or marketing tasks that consume much of a community therapist’s day.

Stark - ACS’ legal counsel specializes in Stark and other self-referral rules to help your group comply with all federal and state self-referral restrictions.

Medicare - ACS’ Medicare experts will help you promptly obtain full Medicare reimbursement in compliance with all regulatory requirements.

General Compliance - ACS allows you to have the benefit of “in-house” compliance officers to provide day-to-day assistance with Medicare, HIPAA and other regulatory and compliance issues.

Policies and Procedures - ACS’ development of policies and procedures for dozens of PT programs allows us to help you develop appropriate and useful policies and procedures for your PT practice.

Financial Planning/Performance - ACS’ ongoing management of PT programs for physician groups provides us with the financial information necessary to determine whether your program is reaching its potential and, if not, to help you do so.

Income Allocation - ACS can provide you with options and advice as to how to divide ancillary income among group members.

Management Reporting - ACS can help you use our series of management tools to simply and effectively monitor all aspects of your PT program from patient satisfaction and outcomes to staff productivity.

Space Location - ACS’ will use our experience in locating dozens of PT clinics to help you find a convenient, accessible and affordable location for PT services.

Space Planning - ACS’ PT space planners will help you design a layout that efficiently uses all available space.

Equipment - ACS can use its volume-based buying power to help your group save thousands of dollars on the purchase of equipment.

Staffing Plan - ACS’ can help you implement a staffing plan that insures you have the number of staff members and the optimal staffing ratios necessary for patient coverage while avoiding overstaffing costs.

Recruiting - ACS will use its experience gained from recruiting hundreds of therapists to help you recruit the most qualified PT team available with skill sets that complement your group and meet patient needs.

Staff Compensation - ACS will use its compensation expertise to help you determine appropriate compensation levels and implement an incentive compensation plan that rewards PT staff members who meet the needs of your group and patients.

Staff Training - ACS provides your PT and other staff with comprehensive continuing education on clinical treatment, documentation, coding, medical recordkeeping, productivity and other skills necessary to insure a successful PT program.

Staff Performance/Evaluation - ACS’ expertise and experience in PT staff performance evaluations will help you provide critically important staff evaluations on a regular basis and make key staffing decisions.

Credentialing - ACS’ nationwide credentialing experience will help you obtain reimbursement for PT services from your key payors.

Coding - ACS’ coding experts will help you to promptly and effectively prepare, submit and collect all claims.

Documentation - ACS’ compliance staff will help you insure that documentation supports billing and allow you to minimize denials.

Marketing - ACS’ experience in helping numerous groups build internal referrals will help you develop and implement a plan to maximize appropriate referrals to your PT practice.

New Programs - ACS’ expertise and experience in helping groups evaluate, plan and implement specialty programs, such as neuro rehabilitation, vestibular/gait and balance and pain management, will help you add programs that meet the needs of your group and patients.