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Ask the expert: Should a proctor be paid for his or her duties?

Medical Staff Leader Connection, October 14, 2010

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Historically, members of the medical staff have been expected to donate time to the peer review process, including time as a proctor. However, in recent years, this compact has frayed. Physicians’ time is more valuable than ever before, and time committed to proctoring is money lost from the proctor’s pocket. As a result, some hospitals pay a modest stipend to medical staff members who are asked to proctor a colleague. In some health systems, arrangements are made for members of one medical staff to serve as proctors for colleagues on another medical staff in the system. Sometimes this arrangement can be made without compensation or at a very modest fee. On some medical staffs, a minimal amount of citizenship work is required of every member. Serving as a proctor may enable the member to meet this requirement in lieu of other tasks, such as taking emergency department or clinic call.

Another source of proctors may be a local or regional medical university. Some medical school faculty members, particularly at state-supported schools, believe they have a professional obligation to be available to perform a reasonable amount of external peer review or proctoring. When such arrangements can be made, payment is sometimes unnecessary. However, as the financial pressure on public and private teaching facilities increases, the administrations of those institutions increasingly frown on such faculty volunteer activity.

Note that when a proctor needs to be brought in from outside the organization, payment for his or her service is the norm. Whenever payment for proctoring is required, however, ensure that it does not exceed fair market value (FMV). To do otherwise can run afoul of anti-kickback laws. Keep careful records of the proctoring services for which compensation is being made and the amounts of any payment. Determining FMV for proctoring is no different from calculating FMV for any physician administrative services, such as paying officers on the medical staff or other committee members. You can also check what other hospitals in the area are paying for proctoring services. Most typically range from $50 to $150 per hour. Make such compensation in accordance with a written agreement.

This week’s question and answer are from Proctoring and FPPE: Strategies for Verifying Physician Competence, Second Edition by Robert J. Marder, MD, CMSL, and Mark A. Smith, MD, MBA, CMSL.

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