Bon Secours Mercy Health is a non-profit Catholic health system comprised of acute and long-term care, assisted living, home care and hospice services, and other facilities throughout the United States and Ireland. As quoted on its website, Bon Secours’ mission is to “extend the compassionate ministry of Jesus by improving the health and well-being of our communities and bring good help to those in need, especially people who are poor, dying and underserved.” Its stated values are human dignity, integrity, compassion, stewardship, and service. Bon Secours is very committed to its community and serves it through advocacy, community programs, economic development, and conducting a community health needs assessment. My internship was with Susan McCarthy, the Director of Nursing Operations for Bon Secours Richmond Outpatient Infusion Centers. The system of outpatient infusion sites are all provider-based clinics and fall under the scope of Bon Secours Richmond Community Hospital. In my tenure as an intern, I was responsible for attending meetings with Susan, recording notes and minutes, rounding on the six outpatient infusion sites, conducting research, and completing other projects as assigned. My biggest project this semester was creating a welcome packet for new infusion patients.

Provider-based regulations from CMS have been an area of focus during my time at Bon Secours. The six infusion sites are all a part of Richmond Community Hospital as provider-based clinics. According to LaHue (2016), the term provider-based “refers to a Medicare billing status and process for physician services that are provided in a hospital outpatient clinic.” This means that the facility is owned by and integrated with a hospital and thus has the ability to bill Medicare as a hospital outpatient department (Levinson, 2016). Billing in this manner results in higher payments to the facility (Levinson, 2016). This type of clinic must meet Medicare’s regulations for provider-based clinics (LaHue, 2016). For example, the facility may be on or off the hospital campus, but must meet other requirements (Levinson, 2016). The rules and regulations regarding provider-based clinics have created problems in the scope of Susan’s role as a director. Because this billing structure results in higher revenue for the hospital, we want to ensure that we do everything in our power to remain compliant and lock-in that revenue source.

During the internship, we attended several calls and meetings regarding provider-based practice rules to make sure that the infusion sites are compliant. This involved collaborating with other professionals and higher-ups. Currently, CMS does not require a provider-based clinic to file an attestation (the attestation and review process is voluntary), but the site must still meet all regulations and criteria (LaHue, 2016). This is where Bon Secours’ Richmond Outpatient Infusion sites are at in this process. Susan is collaborating with other professionals and leaders to create a binder for each infusion site that shows how it is compliant with these rules. Another way she is doing so is updating signage at each infusion site. It is important to show that each site is connected to the “home” site of Richmond Community Hospital. For example, the Hanover, VA infusion site has a sign at the door that states “Hanover Outpatient Infusion, a part of Richmond Community Hospital.” This change in signage has been documented in the attestation binder. Other items in these attestation binders show reporting structures for staff and verbiage from the hospital oncology medical director’s contract to show how he is involved with the outpatient facilities.

Additionally, the provider-based rules are causing some headaches as the Bremo infusion site tries to expand its premises. The practice cannot grow in its current location, but would lose a large source of revenue if it moved to a different address off-site. Changing the address would violate provider-based regulations and it would no longer qualify to be a part of Richmond Community Hospital. An option being explored is taking over neighboring suites in the hospital, but this could also put its provider-based status into jeopardy. The legal team is currently reviewing CMS guidelines; so far it is looking like the site cannot expand without losing the provider-based status.

Provider-based clinics are coming under more scrutiny (LaHue, 2016). “Half of hospitals owned at least one provider-based facility” (Levinson, 2016, p. 3). Additionally, Gooch (2016) states that hospital systems are projected to own nearly sixty percent of physician practices. CMS does not have an agency or process that keeps track of provider-based facilities nationwide or their revenue (Gooch, 2016). CMS has taken steps towards improving its monitoring of provider-based facilities, but many gaps exist (Levinson, 2016). Many facilities are not voluntarily attesting for their clinics or have difficulty providing proper documentation to CMS in a formal review (Levinson, 2016). It has also been noted that there is no evidence that services from a provider-based facility deliver benefits that justify or offset the additional costs to Medicare and Medicare beneficiaries (Levinson, 2016). For these reasons, it has been recommended that the provider-based designation be eliminated, or payments be equalized for equivalent services (Levinson, 2016).

Critics have valid arguments to eliminate or modify the provider-based system. However, hospitals have argued that often these facilities offer more comprehensive services, such as labs, pharmacies, and x-rays (Gooch, 2016). Additionally, Bon Secours is a non-profit organization. The non-profit status requires the health system to provide a “community benefit” (James, 2016). This ranges from charity care, to promoting community health, to conducting a health needs assessment (James, 2016). The Bon Secours Richmond Health System alone provides numerous community programs such as workforce development, a bereavement center, a “care-a-van” free primary care service, and community partnerships (Bon Secours, 2019). The higher revenue generated from the provider-based outpatient infusion centers allows more money to be put back into the community.

While the provider-based designation remains in place, my professional recommendation for Bon Secours Richmond is to continue with the voluntary attestation binders and consult with the legal team to ensure the documents are compliant. It has been noted that when under review, many hospitals have difficulty providing supporting documents to demonstrate compliance (Levinson, 2016). The completed attestation binder would eliminate that conflict. To remain compliant in the future, I recommend creating a yearly formal review process. This process would allow the organization to stay abreast of any CMS regulation changes, perform a gap analysis, and address any necessary changes.

Since merging with Mercy Health, Bon Secours has achieved a global footprint beyond the borders of the United States. Bon Secours Mercy Health merged with Bon Secours Health System based in Dublin, Ireland in 2019 (Gooch, 2019). This health system was Ireland’s largest private healthcare provider (Gooch, 2019). Following the merger, Bon Secours Mercy Health now totals 60,000 employees across 50 hospitals and 50 home health agencies (Gooch, 2019). Before the merger, the system in Ireland was a part of the Bon Secours portfolio, but unrelated to operations in the United States (Gooch, 2019). The merger brings Ireland into the fold and will lead to more synergy and creativity (Gooch, 2019). There was a 100-day plan for integration and plans for development over the next five years are in the works (Gooch, 2019). This is a great opportunity to share knowledge “across the pond” and become more integrated (Gooch, 2019). Today, technology bridges the distance between countries and can streamline processes (Gooch, 2019). The organization can use this to its advantage to see processes that have been utilized successfully in Ireland and try to mirror them in the United States, and vice versa. My recommendations for a future state following this merger are to focus on the bigger picture once the quick wins are under its belt.

Overall, Bon Secours is taking steps in the right direction in the Richmond market as far as CMS compliance. The future of provider-based facilities is questionable over the next few years; however, while this structure is still in place, it is imperative to remain compliant. Otherwise, revenue generated by the infusion sites could fall into jeopardy. Losing this extra revenue could severely impact Bon Secours’ community outreach efforts. The attestation binders are nearly complete as I finish my internship. Additionally, Bon Secours Mercy Health system is growing beyond the borders of the United States and becoming a global organization. It will be interesting to see new ideas coming from “across the pond” in Ireland and seeing how they translate into the United States healthcare arena.

References

James, J. (2016). Health Policy Brief: Nonprofit Hospitals’ Community Benefit Requirements. Health Affairs, 1–5. doi: 10.1377/hpb20160225.954803

Gooch, K. (2016, June 13). 7 things to know about provider-based billing. Retrieved March 5, 2020, from https://www.beckershospitalreview.com/finance/7-things-to-know-about-provider-based-billing.html

Gooch, K. (2019, July 25). Bon Secours Mercy Health CEO talks Ireland merger: ‘Blood is thicker than water’. Retrieved March 5, 2020, from https://www.beckershospitalreview.com/hospital-transactions-and-valuation/bon-secours-mercy-health-ceo-talks-ireland-merger-blood-is-thicker-than-water.html

LaHue, V. (2019, February 3). Top 10 questions regarding provider-based clinics. Retrieved March 5, 2020, from https://www.wipfli.com/insights/blogs/health-care-perspectives-blog/160203-provider-based-clinics

Levinson, D. R. (2016, June). CMS Is Taking Steps to Improve Oversight of Provider-Based Facilities, But Vulnerabilities Remain. Retrieved March 5, 2020, from https://www.oversight.gov/sites/default/files/oig-reports/oei-04-12-00380.pdf