The PDP Solution

We are in an unsettled era where healthcare is changing rapidly.
How can your business benefit in the changing healthcare landscape?

With PDP's solution, surgeons work together with hospitals and manufacturers to provide the highest quality implants and biologics for patient care – at a lower cost.

The PDP solution empowers surgeons to become effective and valuable decision makers for their institutions. Surgeons drive the selection process and value creation. With the PDP solution, all stakeholders benefit – the surgeon, hospital and manufacturers.

The PDP solution aligns economic incentives for all stakeholders

1. Surgeons gain participation in the lowering of supply chain costs
2. Hospitals benefit from lower costs
3. Manufacturers gain access to potential new customers

PDP is manufacturer neutral and serves as a primary source to access and evaluate quality preference items

The OIG's 2011 Guidance
On September 13, 2011, the OIG submitted a response to the Committee’s request. The OIG summarized its previous guidance, noted that a wide variety of models and related entities exist, and stated that whether any particular entity poses any legal concerns depends on its particular characteristics. The statement itself makes clear that such entities can be properly constructed and operated. The OIG goes on to identify as critical factors "the details of its legal structure; its operational safeguards; and, importantly, the actual conduct of its investors, management entities, suppliers, and customers during the implementation phase and ongoing operations." This statement reflects the OIG’s analysis of the structural and operational features employed by experienced regulatory counsel to build compliant models, including our own. The OIG agreed to conduct a survey of hospitals to confirm that physician entities bring cost savings and improved quality and service to the hospitals with which they have partnered.

The PDP Model
We are confident that PDP’s model reflects the state of the art with respect to each of the characteristics identified by the OIG, and incorporates additional unique features further addressing traditional OIG concerns with physician-owned entities. Most importantly, a singular characteristic of the PDP model is that it is not really a physician owned distributorship (POD) at all, because it is not a distributor or affiliate of any manufacturers. Because it does not incorporate any manufacturer or distributor as an owner or partner, it is not the sort of joint venture with which the OIG has been concerned. The OIG’s existing guidance relates to ventures between Medicare providers and physicians in a position to refer business to them. Our complete independence from manufacturers and their distributors eliminates anyappearance that physician ownership opportunities represent an inducement from them for referrals, the OIG’s primary concern with such ventures. Our model’s insulation of surgeons from financial interactions with manufacturers and hospitals similarly addresses traditional OIG concerns. We welcome the opportunity to discuss our model with you or your counsel at your convenience.