Beginning January 1, 2013, healthcare organizations owned by both chiropractors and M.D.s (or D.O.s) will have to obtain a Florida Health Care Clinic License (HCCL) in order to take care of patients whose care is compensated by PIP. These sort of “integrated practices” are clearly on the upswing, especially after the tough new PIP Clinic regulations were passed this year, which makes providing care to patients injured in motor vehicle accidents tricky.
Integrated practices are not a new solution to a new problem. In their most altruistic terms, they ensure the delivery of a broader range of healthcare services to patients. In a more mercenary light, they are an effective means of ensuring that more of the healthcare dollar stays in one place. That said, contrary to what many consultants or other advisors may say, they are not “easy” and clearly pose a much greater legal risk to physicians than a “regular” practice. They are targets of governmental investigators and payers alike, so great care must be taken when forming and operating them. Even the most innocent mistake like taking in patients from the community solely for physical therapy or inaccurately billing under the provider number of a physician who did not actually treat the patient can have both civil monetary and criminal consequences.
These practices have been around for decades, but Florida law just got tougher on them. Starting January 1, 2013, Florida practices that are owned jointly by both chiropractors and M.D.s (or D.O.s) will need a health care clinic license to take care of PIP patients. Professionals will need to get in gear NOW, since obtaining an HCCL can take 90 days or more.
