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Many insurers and HMOs use the same RVUs that are part of Medicare's resource-based relative value scale (RBRVS). Under RBRVS, total RVUs for each CPT code are the sum of three components: work RVUs, practice-expense RVUs and malpractice RVUs. You may want to clarify with these insurers whether they're using total RVUs or work RVUs to estimate your work. Payment is usually based on total RVUs, but productivity measurements may be based on work RVUs only. You can find all the RVUs under the RBRVS for 2000 in the Nov. 2, 1999, Federal Register.However, since the RBRVS is not the only relative-value scale in existence, you should check with the insurers to find out which scale they're using. Relative-value scales other than RBRVS are usually available from the entity that maintains the scale.

Under the Stark law, a physician who has a financial relationship with an entity, or whose immediate family member has a financial relationship with the entity, may not make a referral to that entity for “designated health services” covered under Medicare or Medicaid unless an exception applies.The Stark law is not applicable to either arrangement you describe. Because counseling for stress or pain management is not one of the designated health services, Stark would not prohibit your referral of a patient to a counselor who is either employed directly by you or employed by the same group practice. Psychological counseling performed as an inpatient or outpatient hospital service or a physician's prescribing of outpatient drugs could however trigger the Stark law.If the counselor is employed by you, Stark would not prevent you from billing for the counselor's services under your tax ID number; however, if you bill the services as “incident-to” services, make sure you are complying with applicable Medicare coverage rules. Also, remember that a qualified psychologist can obtain an independent provider number and bill at 100 percent of the fee schedule.

The first thing you should do is to develop a program to prevent violence in your practice. Such a program will not only save lives but will help you defend your practice in any lawsuits resulting from workplace violence.A no-nonsense violence-prevention program will require that you do the following: Develop a statement that communicates the practice's concern about violence in the workplace and its intent to take immediate action to provide a safe and healthy work environment.Require all employees to attend preparedness seminars, which are available in most cities.Have front-office staff get to know security officers in the building, have the telephone numbers for building security and the local police programmed to speed dial, and identify the office's trouble spots, such as stairwells, elevators and rest rooms.Set zero tolerance for violent words and acts or weapons brought into the practice, whether by patients or staff. If patients or staff engage in violent or potentially violent behavior, issue a warning where appropriate; otherwise, immediately notify law enforcement personnel or security.Encourage staff who experience or witness workplace violence to remain calm and nonconfrontational and immediately report it to a designated person.Consider using an employee survey to identify risks and how security measures can be improved.If practical, designate a threat-assessment team of two or three people to create guidelines, evaluate the effectiveness of existing security measures and set clear goals and objectives regarding practice security.Every practice, whether large or small, should be proactive when it comes to workplace violence — first to protect its employees and second to protect itself from a lawsuit.