Continuing efforts to identify and stop Silent PPO arrangements is essential. At a minimum, physicians signing PPO contracts should ensure the following:
- That discounts will be extended only to enrollees of the PPO who have cards identifying them as such;
- That all PPO members eligible for discounts will be subject to steerage rnechanisms; contract language that promises "best efforts” by the PPO to steer enrollees usually is of minimal value under most state law;
- That the types of entities that can be added to the network are identified in advance, and that providers receive timely notice when payors or employers are added;
- That all members added to the PPO be subject to the same steerage mechanisms;
- That any discounts applicable to a PPO enrollee be disclosed at the time coverage is verified; and
- That the sale or other unauthorized use of contract rate information is specifically prohibited.