At the time Beaumont Health was formed, the integration efforts to create the new Beaumont Medical Group were focused on unifying operations and management. Currently, BMG functions not as a legal entity itself but within the three separate founding legal entities under a unified management structure with our physicians being directly employed by each of the founding hospital organizations – Beaumont Health System (BHS), Oakwood Healthcare, Inc. (OHI) and Botsford General Hospital (BGH).
Since the 2014 affiliation, several factors have been identified that have caused BMG leadership to proceed with the creation of new BMG legal entities. These factors include:
- Common Identity – The current legal structure reinforces the founding organization nomenclature and is a barrier to establishing a common BMG brand and identity. A new legal entity to unify BMG physicians with a common identity within the construct of Beaumont Health will advance integration efforts.
- MACRA Legislation – The Medicare Access and CHIP-Reauthorization Act (MACRA) was finalized in 2016 which created new penalties and incentives for providers participating in shared savings programs or other risk-bearing models. In 2017 and 2018, all BMG providers across the three founding entities are participating in the Merit Based Incentive Program (MIPS) track. As we look to the future, we want the option for our providers to participate in the Advanced Alternative Payment Model (APM) track. Under our current legal structure, the founding legal entities would not qualify as an APM. Therefore, the go forward structure provides the ability to meet the requirements for APMs and provide BMG with flexibility regarding how to report under MACRA in the future.
- Organizational Complexity – Within the integrated BMG, the services of physician employees of the three founding organizations are billed under multiple legal entities. This structure creates complexity when trying to function as a unified medical group serving all BH hospitals and ambulatory sites. The go forward structure will enhance efficiencies and allow cross-coverage models to both meet system needs and maximize our physician manpower.
For these reasons, BMG is creating three new legal entities: (1) BMG Primary Care Services (2) BMG Specialty Services and (3) BMG Hospital Based Services. These entities will be first tier subsidiaries of Beaumont Health with their own respective Board of Directors, reporting to the Beaumont Health Board of Directors. These new legal entities will become the employers of all BMG physicians between now and 2019. APPs and support staff will remain employees of their respective founding organization. This change will not have any negative impact to our BMG physicians; instead, it will allow for maximization of quality reimbursement under MACRA and a foundation upon which to build a truly unified multispecialty group.
The transition to this new legal structure will begin January 1, 2018, and starting with many of the founding BHS and Botsford specialty and hospital based physicians. Full transition will not occur until January 1, 2019, due to participation with the Medicare Shared Savings Program through the Oakwood ACO by our founding Oakwood physicians as well as BHS and Botsford primary care physicians.
To facilitate the change, BMG physicians may be asked to execute an amendment to their contract and/or sign new payor enrollment paperwork. If you are impacted by this change, you will receive a separate communication with specific instructions.
Please note that this change does not affect participation with physician organizations (PO alignment will not be impacted), nor does it impact any benefits currently provided to our physicians, including participation in retirement plans.
We believe this is a significant and exciting step forward in our integration and look forward to sharing more information with you at our upcoming BMG Town Hall meetings.