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ASA NEWSLETTER
 
 
March 1998
Volume 62
Number 3
 
PRACTICE MANAGEMENT

Why Can't We Form A Union?

Karin Bierstein
,
Practice Management Coordinator



Physicians often feel that they have no bargaining power when they are presented with a third-party payer contract. One response is to think "union," which would theoretically permit the physicians to negotiate as a single group and prevent individual low bidding or capitulation.

Why does this not work?

Most readers have at one time or another heard the lawyers object, "antitrust." Federal antitrust law prohibits collective activity to fix prices or to enforce fixed prices. So do most state antitrust statutes. Bargaining over fees by physicians in independent practices, or agreeing not to deal with an insurer who rejects those fees, would constitute illegal collective price-fixing or group boycott activity.

Aren't labor unions exempt from the antitrust laws?

Yes, but only employed physicians would qualify for the exemption. The exemption, a product of federal antitrust and labor statutes as well as of Supreme Court interpretation, extends only to the conduct of labor unions involved in a labor dispute. The dispute must concern the terms and conditions of employment. Thus, a labor organization can negotiate only on behalf of employees, although other persons may join the organization. The exemption does not protect independent contractors, which most physicians are.

But am I not an employee of my corporation?

Physicians may be employees of a professional corporation or of a partnership, as most private-practice anesthesiologists are and, therefore, the P.C. or partnership can negotiate for the group, but it cannot collaborate with other independent groups to increase its leverage.

Don't other independent contractors, such as truck drivers, engage in collective bargaining?

Yes, and so do screenwriters and musicians, but only under limited circumstances. In these occupations, the majority of the participants are in an employment relationship, and some portion of the workers operate as independent contractors.

The independent contractors are allowed to be part of the collective bargaining agreements so that they cannot be used by employers to undermine the collective bargaining agreements achieved by the employees. This prevents employers from subverting a collective bargaining agreement by hiring nonunion independent contractors at lower compensation rates than called for by the union contract.

Aren't physicians so highly controlled by health plans that they are, in reality, employees who should be allowed to bargain collectively?

No. An independent contractor does not become an employee just because the contractor lacks the clout to negotiate terms of dealing and has to accept terms offered by a purchaser of the contractor's services, i.e., a health plan.

What determines whether a person is an independent contractor as opposed to an employee ?

The criteria that courts use to determine whether a person is an independent contractor or an employee and how those fit or do not fit physician relationships with health plans are:

1. The extent of control that the alleged employer may exercise over the organization and management of the individual's work. High levels of control indicate employment.

  • Physicians contracting with a health plan are generally not subject to the same kind of control that an employee is. Physicians who accept "take it or leave it" payment offers and utilization protocols can be compared to other independent contractors who work pursuant to specifications supplied by the purchaser of their services.

2. Whether the worker is engaged in a distinct occupation or business. Such occupations or businesses point toward independent contractor status.

  • Physicians are in a distinct occupation or business.

3. The kind of occupation and whether the work involved is usually done under the direction of an employer.

  • Traditionally, most physicians have not been employed, although that is changing.

4. The skill required for the work involved. High degrees of skill indicate independent contractor status.

  • A very high degree of skill is required to be a physician.

5. Whether the alleged employer supplies the instrumentalities, tools and the place of work. If not, that indicates independent contractor status.

  • Anesthesiologists generally work in a hospital or surgical center and the hospital provides the equipment, the drugs and supplies and the operating suite. But the hospital is not the alleged employer; the health plan is. Employee status is further undercut by the fact that many anesthesiologists employ and utilize their own nurse anesthetists.

6. The length of time for which the worker is hired. Long-term relationships indicate employment status.

  • Physicians tend to be terminable "at will" in their relationships with health plans.

7. Whether the pay is by time period or by the job. Time periods, especially long-term, indicate employment.

  • If physicians are paid on a fee-for-service basis, pay is by the job and that indicates independent contractor status. If on a capitation basis, it is less clear, but it is more like a job-basis payment than a salary.

8. Whether the work is part of the regular business of the employer. If not, independent contractor status is more likely.

  • Health care delivery is usually not the business of a health plan, but the lines are starting to blur as health plans take more responsibility for delivery. However, if the health plan clearly contracts for delivery and does not hire any physicians, that indicates independent contractor status.

9. Whether the alleged employer and the worker believe that they have created an employment relationship.

  • Typically, both sides do not believe that an employment relationship has been created.

10. Whether the alleged employer is in business. If not, that indicates independent contractor status. However, being in business does not, by itself, indicate that persons who do work for the business are employees.

  • Health plans are clearly in business, but there is usually a clear difference between its employees and the physicians who contract to provide services to it as independent contractors.

It is obviously difficult for physicians who do not have a W-2 relationship to demonstrate that they are employees of a health plan. The National Labor Relations Board (NLRB) has never certified any organization to represent physicians in independent practice in collective negotiations with a third-party payer. Certification is required to trigger the alleged employer's duty to bargain with the representative.

In January, the Philadelphia regional office of the NLRB rejected a petition by the United Food and Commercial Workers to represent several hundred New Jersey physicians who had contracts with AmeriHealth HMO. The regional director rejected the argument that the physicians were employees, stating, "Most significantly, the physicians themselves make the fundamental decisions that determine the profitability of their practices." She noted that AmeriHealth patients occupied a fraction of the doctors' time and produced a fraction of their income. The physicians had almost total control over their own expenses, determining office size and location as well as staff size and compensation levels. There was no evidence that AmeriHealth could restrict the physicians from expanding, contracting or selling their practices.

The union has appealed the decision to the national office of the NLRB.

Then why are so many groups of doctors forming or joining unions?

Anger and desperation, combined with some measure of optimism, are often the reasons. Most of these groups do not claim to expect to be able to bargain through their unions over fees. Many of them want to organize in order to protect the quality of patient care. Regaining control over patient care decisions was the stated objective of collective bargaining with the AmeriHealth HMO - and still the NLRB denied certification.

Even though physicians cannot use a union to compel third-party payers to negotiate, several groups have seen advantages in affiliating with an established union. This was the case for about 2,000 doctors in a physician-owned HMO on Long Island, who last year joined the Office and Professional Employees International Union. The doctors joined partly for the purpose of encouraging union health plans with thousands of members to sign up with their fledgling HMO. They were also hoping to obtain the support of the AFL-CIO in lobbying for state and federal legislation to limit health plans' interference in the doctor-patient relationship and the exercise of professional judgment.

Similarly, the New York State Podiatric Medical Association voted as a group to join the First National Guild for Health Care Providers of the Lower Extremities, which was also affiliated with the AFL-CIO. The podiatrists were seeking legislative relief from, among other things, the power of health plan gatekeeper physicians to block patient access to specialists. Collective activity to petition government, i.e., to lobby, is protected by the Constitution and cannot be the basis of an antitrust conviction.

Would it really help us if we were to become employees?

The ultimate answer depends on the issues to be negotiated and the parties' relative bargaining strength. More immediately, it may also depend on whether the employed physicians are considered "supervisory." If they are, they are not entitled to the protection of the labor laws.

The physicians at Thomas Davis Medical Clinic in Tucson, Arizona, last year joined the Federation of Physicians and Dentists, an affiliate of the American Federation of State, County and Municipal Employees. The physicians were employed by the clinic's HMO owner. They organized (at the instigation of an anesthesiologist) in revolt against a cost-cutting program that would eliminate doctors as well as administrative personnel, increasing patient load and clerical work. Also inspirational were the owner's restrictions on referrals to specialists. In this instance, the NLRB did certify the union as the physicians' collective bargaining agent, rejecting a claim that the doctors were supervisory employees, and the NLRB has now gone to court to force the owner to negotiate.

Should we go to Congress?

It would almost certainly be a waste of time. Historically, there has been no support for legislating an antitrust exemption for physicians or any other professional or industry group (at least not since the passage of the McCarran-Ferguson Act in 1945, exempting the insurance industry). Congress has no compelling incentive to enhance physicians' ability to deal collectively with third-party payers. This is particularly true in the wake of the definition of antitrust "safety zones" for physician networks elaborated in the Department of Justice's and the Federal Trade Commission's 1996 "Statements of Enforcement Policy and Analytical Principles Relating to Health Care and Antitrust."

Well, what can we do?

Anesthesiologists can form networks, consistent with the "Statements of Enforcement Policy" mentioned above (and discussed more fully in the "Practice Management" column in the October 1996 NEWSLETTER). You can also organize the collection and distribution of marketplace information, e.g., fee information, in the manner allowed by the Statements. You can enhance your marketplace clout by increasing the size of the professional corporations and partnerships to which you belong - again, with the ultimate restrictions of the antimonopolization provisions of the antitrust laws in mind. You can take advantage of an affiliation with an existing labor union, for purposes other than raising fees, as have some of the physician groups mentioned in this article. You can affiliate with other physicians through multispecialty groups or management services organizations. There really are options.

Acknowledgement:

I would like to thank Edward B. Hirshfeld, Esq., Associate General Counsel at the American Medical Association, for providing a good deal of the information in this column as well as an ongoing education.

 


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