Research Finance
- Billing Compliance
- Financial Management
- Accounting
- Financial Reporting
- Budgeting/Forecasting/ Research Cost Accounting
- Contact Research Administration Finance Department
Billing Compliance.
The primary research compliance function within Banner Research finance involves research billing. Key areas of financial risk in clinical research include:
Undercharging – Conducting clinical studies without receiving adequate reimbursement for the costs of the study. This is primarily a financial risk, but may be a concern for not-for-profits if the under-recovery of costs could be viewed as a subsidization of a for-profit enterprise such as a pharmaceutical or medical device company.
Mischarging – Billing patients or their insurance carriers for the costs of research, especially where those costs have already been covered by the sponsor of the study.
Overcharging – Receiving payments from pharmaceutical sponsors that significantly exceed the costs of the research, especially for Phase 4 marketing studies, could be construed as a violation of the anti-kickback law.” (Staman, Matthew W. Infrastructure for Clinical Research – Managing Financial Risks. The Bureau of National Affairs; Medical Research Law & Policy Report, Vol 3, No. 8, 04/21/2004, pp. 313-316.)
Recently the Office of the Inspector General (OIG) has begun to focus on research billing compliance giving researchers a new incentive to look closely at cost calculations for clinical research, time and effort reporting for grants, budget negotiations and third party billing practices.
Depending on the nature of the research project, patients may be enrolled in a study that involves patient care items and services occurring on a Banner campus. This is considered research with the potential for “Banner billing”.
To avoid mischarging, Banner Research finance performs a detailed review of the study mandated activities to determine which services required by the protocol are billable to a third party payer. This is called a coverage analysis.
Once these billable services are identified, all remaining patient care services performed solely to accommodate the protocol along with anticipated labor expenses are quantified. This is known as a cost analysis and it is the basis for budget negotiations with study sponsors.
The cost analysis further defines a range of expense that identifies and directs Banner negotiations so that study budgets are not under or over usual and customary reimbursement for services. Once a study is approved, all items and services paid by the sponsor or determined to be “not billable” to a third party payer are earmarked to avoid mischarging. Upon finance notification of subject enrollment, these patient care services are removed from the patient’s claim before it is released to the payer.
Financial Management.
Banner Research finance is focused on sound fiscal stewardship of Banner research dollars, while at the same time, being mindful of protecting human subject interests.
The standardized cost and coverage analysis tools facilitate budget negotiations that maximize Banner’s return on investment within Banner’s legal risk tolerance. This means that for research studies reviewed by finance, with all consideration for billing and legal risks, study reimbursement has been maximized and all financial risks and responsibilities have been fully disclosed to the subjects potentially seeking a research treatment option.
Because research expenses lie within facility budgets, projects that cannot be negotiated within the stated system-wide business tolerance are referred back to the respective facility finance team for a business decision before they are given our approval.
Accounting.
Banner is the usual “payee” for all clinical trial payments and Banner Research finance is responsible for all research financial accounting. Payments received at Banner Research are reconciled with actual study benchmark activity such as subject enrollment and follow up visits as well as reimbursement for equipment and supplies.
Upon sponsor payment, the finance department generates and distributes investigator payments consistent with the agreed upon study budgets. Banner Research finance also facilitates recovery of all Institutional Review Board (IRB) related expenses via facility departmental transfers and study sponsor invoicing. Research Administration finance tracks all research related costs and revenue in specific “research accounting units”.
Financial Reporting.
Along with the responsibility for research financial accounting, Banner Research finance generates financial reports for all research activity in the Banner system.
Banner Research finance prepares a monthly Banner Health Research Statement of Operations Report that details research revenue and expenses for the overall system scaled all the way through individual facility reports and down to research accounting units within Banner facilities. This report also illustrates non-financial performance metrics such as new study approvals and currently open/active projects as well as timelines for new submission approvals.
Budgeting/ Forecasting/ Research Cost Accounting.
Banner Research finance prepares and manages the annual operating budget, capital budget and strategic financial plan for both the research institute and the IRB. Banner Research finance also works in partnership with facility finance departments to forecast and budget research dollars within facility budgets.
Contact Research Administration Finance Department
Research Study Budget
Budget negotiations—
Lisa Diaz (602) 747-9705
lisa.diaz@bannerhealth.com
Research Budgeting and Forecasting—
Bob Scalise (602) 747-9701
robert.scalise@bannerhealth.com
Cost and Coverage Analysis -
Lisa Diaz (602) 747-9705
lisa.diaz@bannerhealth.com
IRB Invoicing—
Gordon Schneider (602) 747-9709
gordon.schneider@bannerhealth.com
Study Deposits—
Gordon Schneider (602) 747-9709
gordon.schneider@bannerhealth.com
Research Financial Package
Bob Scalise (602) 747-9701
robert.scalise@bannerhealth.com
Research Billing
Patient charges—
Gordon Schneider (602) 747-9709
gordon.schneider@bannerhealth.com
Cost and Coverage Analysis—
Lisa Diaz (602) 747-9705
lisa.diaz@bannerhealth.com
Research Payments
IRB invoicing—
Gordon Schneider (602) 747-9709
gordon.schneider@bannerhealth.com
Study Deposits—
Gordon Schneider (602) 747-9709
gordon.schneider@bannerhealth.com
Research Grants
Rachel Small (602) 747-9725
rachel.small@bannerhealth.com
Time and Effort Reporting
Rachel Small (602) 747-9725
rachel.small@bannerhealth.com
Facilities and Administrative Rate (Indirect Cost Rate)
Rachel Small (602) 747-9725
rachel.small@bannerhealth.com
