Oplinc
Volume 5, Issue 2 April 2010
The Electronic Health Record Incentive Program

The “American Recovery and Reinvestment Act of 2009” (ARRA) provides financial incentives to help physicians purchase and implement Health Information Technology (HIT) systems. The development of uniform electronic standards that allow HIT systems to communicate with each other is necessary to facilitate adoption and use of HIT therefore, ARRA required the Department of Health and Human Services (HHS) to develop the initial set of uniform standards by December 31, 2009.

The Medicare and Medicaid electronic health records (EHR) incentive program provides incentive payments to eligible professionals (EPs), hospitals and critical-access hospitals who meet the criteria of meaningful use of certified EHRs.

The CMS proposed rule, “Medicare and Medicaid Programs; Electronic Health Record Incentive Program,” published in the January 13, 2010 Federal Register, defines Medicare and Medicaid EPs, outlines the Medicare and Medicaid EHR incentive programs and includes a proposed definition of “meaningful use” of EHR technology. The comment period for the proposed rule ended March 15, 2010. CMS will review the comments received and issue a final rule later this year.

The EHR Incentive Program is a complicated program and care should be taken to thoroughly read the Final Rule once published. This article will focus on the highlights of the program as it pertains to non-hospital based physicians.

Eligible Professionals
Under the rule a Medicare EP is a physician as defined by section 1861 (r) of the ACT. The ACT defines the term “physician” to mean the following five types of professionals, each of which must be legally authorized to practice their profession under state law:

  1. A doctor of medicine or doctor of osteopathy;
  2. A doctor of dental surgery or dental medicine;
  3. A doctor of optometry;
  4. A doctor of podiatric medicine; or
  5. A chiropractor.

A qualifying EP is defined as a healthcare provider who demonstrates meaningful use of a certified EHR for the designated reporting period. The rule defines a Medicaid EP in accordance with section (1903(t) (3) (B) of the Act which lists five types of Medicaid professionals:

  1. Physicians;
  2. Dentists;
  3. Certified nurse-midwives;
  4. Nurse practitioners; and
  5. Physician assistants practicing in an FQHC or RHC that is so led by a physician assistant.

A qualifying Medicaid EP must demonstrate meaningful use of a certified EHR for the designated reporting period and must have a Medicaid patient load of at least 30% (with the exception of pediatricians who need only have a Medicaid patient load of 20%).

While eligible hospitals may receive incentives from both Medicare and Medicaid EPs must select one program. Additionally, Medicaid EPs and hospitals must select one state from which to receive their incentive payment each year.

Reporting Period
For the first year an EP applies for and receives an incentive payment, CMS proposes that an EHR Reporting Period is 90 days for any continuous period beginning and ending within the year. For every year after the first payment year, CMS proposes that the EHR reporting period is the entire year.

Medicare Incentive Payments for EPs
Beginning in 2011 non-hospital based physicians are eligible for Medicare incentive payments based on an amount equal to 75% of the allowed Medicare Part B charges up to a maximum of $18,000 for early adopters, qualified EPs whose first payment year is 2011 or 2012, with a total maximum incentive possible of $44,000 over five years.

As illustrated in Figure 1 below, Medicare incentive payments would be reduced in subsequent payment years, and eliminated in 2017.

Year
of EHR
Imple-mentation

--- Maximum Medicare Incentive ---

Total Possible Medicare Incentives
in
2011
in
2012
in
2013
in
2014
in
2015
in
2016
2011 $18K $12K $8K $4K $2K $0 $44K
2012 N/A $18K $12K $8K $4K $2K $44K
2013 N/A N/A $15K $12K $8K $4K $39K
2014 N/A N/A N/A $12K $8K $4K $24K
Figure 1

EPs who are not meaningful EHR users before 2015 will face a reduction in their Medicare fee schedule of -1% in 2015, -2% in 2016, and -3% in 2017 (see Figure 2). The Secretary of HHS may, on a case-by-case basis, exempt an EP from the reduction in payment if the Secretary determines that compliance with the requirement would result in a significant hardship for the EP. The Secretary's determination to grant an EP an exemption may be renewed on an annual basis, provided that in no case may an EP be granted an exemption for more than 5 years.

Year

Reduction in Fee Schedule for Non-Adoption/Use

2011

$0

2012

$0

2013

$0

2014

$0

2015

-1% of Medicare Fee Schedule

2016

-2% of Medicare Fee Schedule

2017

-3% of Medicare Fee Schedule

Figure 2

Meaningful Use
ARRA stipulates that eligible providers must be a “meaningful user” of his or her certified EHR specifying three types of requirements for meaningful use:

  • Use of certified EHR technology in a meaningful manner (for example, electronic prescribing);
  • That the certified EHR technology is connected in a manner that provides for the electronic exchange of health information to improve the quality of care; and
  • That, in using certified EHR technology, the provider submits to the Secretary information on clinical quality measures and such other measures selected by the Secretary.

The CMS proposed rule outlines a phased in approach to meaningful use involving three stages with increasingly stringent criteria. CMS developed the 25 proposed Stage 1 criteria, that ambulatory physicians must meet, in partnership with The Office of the National Coordinator for Health Information Technology (ONC). Criteria for Stage 2 & 3 will be developed through future rulemaking.

Stage 1 Criteria for Meaningful Use
The proposed Stage 1 criteria for meaningful use focus on electronically capturing health information in a coded format, using that information to track key clinical conditions, communicating that information for care coordination purposes, and initiating the reporting of clinical quality measures and public health information.

Stage 2 Criteria for Meaningful Use
Stage 2 criteria would expand upon the Stage 1 criteria in the areas of disease management, clinical decision support, medication management, support for patient access to their health information, transitions in care, quality measurement and research, and bi-directional communication with public health agencies. CMS may consider applying the criteria more broadly to both the inpatient and outpatient hospital settings.

Stage 3 Criteria for Meaningful Use
Stage 3 criteria would focus on achieving improvements in quality, safety and efficiency, focusing on decision support for national high priority conditions, patient access to self-management tools, access to comprehensive patient data, and improving population health outcomes.

Red Flags Rule

The Fair and Accurate Credit Transactions Act of 2003 (FACTA) required the Federal Trade Commission (FTC) to enact rules to require financial institutions and creditors to develop and implement written identity theft prevention and detection programs to protect consumers from identity theft. On November 9, 2007 the Red Flags Rule was published in the Federal Register.

The Red Flags Rule was first scheduled to take effect on November 1, 2008, however the FTC has delayed enforcement of the Rule four times. The current effective date for enforcement of the Rule is June 1, 2010.

The “Red Flags” Rule, developed by the FTC and other financial regulatory agencies requires creditors and financial institutions with covered accounts to implement programs to identify, detect, and respond to the warning signs, or “red flags”, that could indicate identity theft. FACTA defines a creditor as any entity that regularly extends or renews credit (or arranges for others to do so) including all entities that regularly permit deferred payments for goods or services. Under this definition most physician practices would be considered a covered entity and would have to comply with the Rule.

According to the FTC physicians are creditors and therefore subject to the Red Flags rule, if:

  • Physicians do not require full payment up-front at the time they see patients, but rather bill patients after the physician’s services are rendered
  • The patient is ultimately responsible for medical fees (as is routinely the case with respect to co-pays or deductibles or services not covered by insurance)

On Tuesday October 20, 2009 the House voted to exempt certain small businesses from the Red Flags Rule. The bill, H.R. 3763 would exclude any health care practice, accounting practice, or legal practice with 20 or fewer employees from the meaning of creditor subject to the Red Flags Rule. The bill would also exclude any other business which the FTC determines:

  • Knows all its customers or clients individually;
  • Only performs services in or around the residences of its customers; or
  • Has not experienced incidents of identity theft, and identity theft is rare for businesses of that type.

The bill went to the Senate Committee on Banking, Housing, and Urban Affairs on October 21, 2009. However, as of March 28, 2010 the Senate has yet to vote on the bill. The bill must be passed by the Senate and signed by President Obama before becoming law.

On October 29, 2009 the United States District Court for the District of Columbia ruled that the Red Flag Rules are not applicable to attorneys engaged in the practice of law. The decision by the U.S. District Court for the District of Columbia was the result of a lawsuit filed by the American Bar Association (ABA) protesting the application of the Red Flag Rules to attorneys. In the partial summary judgment the court held that the Red Flag Rules cannot be properly applied to attorneys engaged in the practice of law in the overly broad manner in which the FTC seeks to enforce it. On December 1, 2009, Judge Reggie Walton issued his full opinion in support of the ABA’s motion exempting attorneys. The FTC is appealing its loss of the Red Flags litigation.

On January 27, 2010 the American Medical Association (AMA), the American Dental Association (ADA), the American Osteopathic Association (AOA) and the American Veterinary Medical Association (AVMA) petitioned the FTC to exclude licensed health care professionals (LHCPs) from the Red Flags Rule. In a joint letter to FTC Chairman Jon Leibowitz, the four organizations cite the decision in American Bar Association (ABA) vs FTC stating, “ While acknowledging that there may be minor differences between lawyers and LHCPs for purposes of the applicability of the Rule, we believe that the dispositive considerations underlying that decision apply equally to LHCPs. Apart from technical legal analysis, moreover, we see no basis for concluding that Congress intended to have the Rule apply to LHCPs but not to lawyers. Indeed, implementation of the Rule with respect to LHCPs but not to lawyers would be manifestly unfair and anomalous.”

In the joint letter the organizations specifically request that the FTC take the following two actions:

  • Announce that the Rule will not be applied against LHCPs until at least ninety days after final resolution of the ABA litigation; and
  • Commit that, if the final resolution of the ABA litigation is that the Rule will not be applied to attorneys, the Commission will not apply the Rule to LHCPs either.

The AMA states that it will use the next several months to "convince the FTC and Congress to republish the rule so that there is sufficient opportunity to formally comment and state the AMA's objections to physician inclusion in the program."

While the AMA continues to work for an exemption for physicians they are also providing resources to assist physicians in developing a simple identity theft prevention and detection program that can be incorporated into their existing compliance and HIPAA security and privacy policies. Visit the AMA Web site for more information and resources on this Rule.

Red Flags Rule Resources

The FTC’s Red Flags Web site, www.ftc.gov/redflagsrule, offers resources to help entities determine if they are covered and, if they are, how to comply with the Rule including:

  • An online compliance template that enables companies to design their own Identity Theft Prevention Program through an easy-to-do form,
  • Articles directed to specific businesses and industries,
  • Guidance manuals, and
  • Frequently Asked Questions to help companies navigate the Rule.

Red Flags Rule Enforcement Timeline:

Red Flags Rule TimelineOctober 22, 2008:
The FTC announces they will suspend enforcement of the new “Red Flags Rule” until May 1, 2009, to give creditors and financial institutions additional time in which to develop and implement written identity theft prevention programs.

April 30, 2009:
The FTC announces another three-month delay pushing the compliance date to August 1, 2009. FTC Chairman Jon Leibowitz states the latest delay will allow Congress time to consider whether they wrote the Red Flags Rule provision too broadly, allows time for industries and associations to share guidance with their members, and will provide low-risk entities an opportunity to use the FTC’s soon to be developed template in developing their programs.

July 29, 2009:
The FTC announces another three-month delay with a new enforcement date of November 1, 2009. The FTC states they will provide additional resources and guidance to small businesses and other entities clarifying whether they are covered by the rule and what they must do to comply. The FTC says the three-month delay and increased education and resources are in keeping with the House Appropriations Committee’s recent request that the Commission defer enforcement in conjunction with additional efforts to minimize the burdens of the Rule on health care providers and small businesses with a low risk of identity theft problems.

October 30, 2009:
In a press release dated October 30, 2009 the FTC states they are delaying enforcement of the Rule until June 1, 2010 at the request of Members of Congress. The FTC press release also references the October 30, 2009 ruling by the U.S. District Court for the District of Columbia that the FTC may not apply the Red Flags Rule to attorneys.

June 1, 2010:
Current date for enforcement of the Red Flags Rule.

PECOS

Medicare providers now have until January 3, 2011 to make sure they are properly listed in Medicare’s Provider, Enrollment, Chain and Ownership System (PECOS), Medicare’s newest enrollment system.

Internet-based PECOS will allow physicians and other healthcare professionals to view their Medicare enrollment information on file with Medicare. Physicians and other healthcare professionals can access Internet-based PECOS by using their NPPES User ID and password. They will also be able to access the following fields via Internet-based PECOS:

  • Name – Names can be changed via Internet-based PECOS, however, the updated name will have to match the name on file with the Social Security Administration
  • Credentials – individuals will be able to update their credentials via Internet-based PECOS
  • Specialties – individuals will be able to update their specialty information via Internet-based PECOS
  • Education – individuals will be able to update their education information via Internet-based PECOS
  • Practice Locations – individuals will be able to add, change or delete practice location information
  • Phone Numbers - individuals will be able to add, change or delete phone numbers

Beginning in October 2009 Medicare contractors began including informational edits on claims that listed referring or ordering physicians who were not properly enrolled in PECOS. CMS says Medicare providers who enrolled prior to November 2003 will likely need to re-enroll in PECOS. CMS recommends that all physicians ensure that their enrollments are up to date and compliant by contacting their Medicare contractors or viewing their records online. A current record is one that is in the PECOS database with all the correct information, including National Provider Identifier (NPI).

Information on the CMS Medicare Directory lists three common reasons providers enrolled in Medicare are missing from the website:

  • You are enrolled in Medicare but do not yet have an enrollment record established in PECOS. To resolve this issue, you will need to submit an enrollment application. Use the link "Other Issues" then review the section titled: "Missing from the website but are currently a Medicare enrolled provider – no PECOS record".
  • You are enrolled in Medicare and have an enrollment record in PECOS but are missing your practice location. We need an address in PECOS in order to display you on the website because all searches are done by geographic area. To resolve this issue, you will need to update PECOS with your address location. Please visit "Practice Locations" for more detailed information.
  • You are enrolled in Medicare and have an enrollment record in PECOS but are missing specialty information. We need specialty information in PECOS in order to display you on the website because searches are based on specialty. To resolve this issue, you will need to update PECOS with your specialty information. Please visit "Specialty" for more detailed information.

Providers who have verified that they are properly enrolled in PECOS are not completely out of the woods, if that provider lists a referring physician on a claim and the referring physician is not in PECOS the claim will be rejected. The American Medical Association (AMA) estimates that as many as 200,000 physicians will have to reenroll in the Medicare program to continue receiving payment. For this reason, the AMA has led the successful efforts to postpone the deadline. The first delay extended the deadline to enroll in PECOS until April 5, 2010; the most recent delay further extends the deadline to January 3, 2011.

CMS lists the following directions to physicians and non-physician practitioners wishing to enroll online through the Internet-based PECOS:

For physicians and non-physician practitioners who already have an NPI, there are two basic steps to completing an enrollment action using Internet-based PECOS. Physicians and non-physician practitioners must:

  • Go to Internet-based PECOS and complete, review, and submit the electronic enrollment application.
  • Print, sign and date the 2-page Certification Statement for each enrollment application you submit, and mail the Certification Statement and all supporting paper documentation to your Medicare contractor within 7 days of electronic submission. Note: A Medicare contractor will not process an Internet enrollment application without the signed and dated Certification Statement. Signatures must be original and in ink (blue ink recommended). Copied or stamped signatures will not be accepted. In addition, the effective date of filing an enrollment application is the date your Medicare contractor receives the signed Certification Statement that is associated with the Internet submission.

For physicians and non-physician practitioners who do not have an NPI, there are three basic steps to completing an enrollment action using Internet-based PECOS. Physicians and non-physician practitioners must:

  • Have an NPPES User ID and password to use Internet-based PECOS. To create a web user account and apply for an NPI at NPPES go to https://nppes.cms.hhs.gov/NPPES/.
  • Once you have your NPI, go to Internet-based PECOS and complete, review, and submit the electronic enrollment application.
  • Print, sign and date the 2-page Certification Statement for each enrollment application you submit, and mail the Certification Statement and all supporting paper documentation to your Medicare contractor within 7 days of electronic submission. Note: A Medicare contractor will not process an Internet enrollment application without the signed and dated Certification Statement. Signatures must be original and in ink (blue ink recommended). Copied or stamped signatures will not be accepted. In addition, the effective date of filing an enrollment application is the date your Medicare contractor receives the signed Certification Statement that is associated with the Internet submission.

PECOS RESOURCES

CMS ANNOUNCES IMAGING ACCREDITATION ORGANIZATIONS

approvedThe Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) mandates that the Secretary of the Department of Health and Human Services (HHS) designate organizations to accredit suppliers furnishing the technical component (TC ) of advanced diagnostic imaging services by January 1, 2010. MIPAA requires the Secretary to consider certain factors with regard to accrediting bodies including:

  • The ability of the organization to conduct timely reviews of accreditation applications to include a projection of the organization's national capacity for processing new applications before the January 1, 2012 accreditation deadline;
  • The organization’s agreement to maintain or adopt standards that are equal to, or more stringent than, those of Medicare;
  • The organization's knowledge and experience in the advanced diagnostic imaging arena;
  • The organization’s plan for reducing the burden and cost of accreditation to small and rural suppliers;
  • The organization’s process for the timely interpretation of new advanced diagnostic imaging services into the organization’s accreditation program;
  • A description of the organization’s audit processes including random site visits, site audits, or other strategies for ensuring accredited suppliers maintain adherence to the criteria for accreditation;
  • Whether the organization has established reasonable fees to be charged to suppliers applying for accreditation; and
  • Any other factors the Secretary determines to be appropriate.

In a January 28, 2010 Press Release CMS announced that the following three organizations have been designated as accrediting organizations for medical imaging facilities:

The designation gives the three organizations the authority to accredit providers furnishing the TC of advanced medical imaging procedures. Under MIPPA, providers furnishing these services must be accredited by a designated accrediting organization by January 1, 2012. The accreditation requirement applies only to the suppliers furnishing the imaging services, and not to the physician’s interpretation of the images.

MIPPA defines advanced diagnostic imaging procedures as including diagnostic magnetic resonance imaging (MRI), computed tomography (CT), and nuclear medicine imaging such as positron emission tomography (PET). Imaging services such as x-rays, ultrasound, and fluoroscopy procedures as well diagnostic and screening mammography are excluded from the law.

In announcing the three accreditation organizations, Barry Straube, M.D., CMS Chief Medical Officer and Director of the CMS Office of Standards and Quality states, “While advanced diagnostic imaging procedures can be useful in identifying health problems that might otherwise require surgery, the rapid growth in their use raises important questions of quality and safety. The three organizations that will be accrediting suppliers have the expertise and authority to set a standard of excellence industry-wide.”

The three accrediting organizations had to demonstrate that they were experienced in the advanced diagnostic imaging area, and that their accreditation requirements met or exceeded the standards set out in MIPPA, including requirements for:

  • Qualifications of non-physician personnel performing the imaging;
  • Qualifications and responsibilities of medical directors and supervising physicians;
  • Procedures to ensure the safety of the individuals furnishing the imaging procedure and of the persons to whom the services are furnished;
  • Procedures to ensure the reliability, clarity, and accuracy of the technical quality of the diagnostic images produced by the supplier;
  • Procedures to assist the beneficiary in obtaining his/her imaging records on request; and
  • Procedures to notify CMS of any changes to the imaging modalities subsequent to the accrediting organization’s decision.

spacer
Published by Rise Marie Cleland. Sponsored by Lilly Oncology

Proposed Stage 1 Criteria for Non-Hospital Based Physicians:

CMS proposes to define computerized provider order entry (CPOE) as entailing the physician’s or provider’s use of computer assistance to directly enter medical orders (i.e., medications, consults, lab services, etc) from a computer or mobile device. The order also is documented or captured in a digital, structured, or computable format for use in improving safety and organization. For Stage 1, that does not include the electronic transmittal of that order to the pharmacy, laboratory, or diagnostic imaging center.

1.

Objective: Use CPOE.
Measure: CPOE is used for at least 80 percent of all orders.

2.

Objective: Implement drug-drug, drug-allergy, drug- formulary checks.
Measure: The EP has enabled this functionality.

3.

Objective: Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry or an indication of none recorded as structured data.

4.

Objective: Generate and transmit permissible prescriptions electronically (eRx).
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology.

5.

Objective: Maintain active medication list.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data.

6.

Objective: Maintain active medication allergy list.
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient has no medication allergies) recorded as structured data.

7.

Objective: Record demographics.
Measure: At least 80 percent of all unique patients seen by the EP or admitted to the eligible hospital have demographics recorded as structured data.

8.

Objective: Record and chart changes in vital signs.
Measure: For at least 80 percent of all unique patients age 2 and over seen by the EP, record blood pressure and BMI; additionally, plot growth chart for children age 2 to 20.

9.

Objective: Record smoking status for patients 13 years old or older.
Measure: At least 80 percent of all unique patients 13 years old or older seen by the EP “smoking status” recorded.

10.

Objective: Incorporate clinical lab-test results into EHR as structured data.
Measure: At least 50 percent of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital during the EHR reporting period whose results are in either a positive/negative or numerical format are incorporated in certified EHR technology as structured data.

11.

Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach.
Measure: Generate at least one report listing patients of the EP with a specific condition.

12.

Objective: Report ambulatory quality measures to CMS or the States.
Measure: For 2011, an EP would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this proposed rule. For 2012, an EP would electronically submit the measures as discussed in section II.A.3. of this proposed rule.

13.

Objective: Send reminders to patients per patient preference for preventive/ follow-up care.
Measure: Reminder sent to at least 50 percent of all unique patients seen by the EP that are 50 and over.

14.

Objective: Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules.
Measure: Implement five clinical decision support rules relevant to the clinical quality metrics the EP is responsible for as described further in section II.A.3.

15.

Objective: Check insurance eligibility electronically from public and private payers.
Measure: Insurance eligibility checked electronically for at least 80 percent of all unique patients seen by the EP.

16.

Objective: Submit claims electronically to public and private payers.
Measure: At least 80 percent of all claims filed electronically by the EP.

17.

Objective: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request.
Measure: At least 80 percent of all patients who request an electronic copy of their health information are provided it within 48 hours.

18.

Objective: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies).
Measure: At least 10 percent of all unique patients seen by the EP are provided timely electronic access to their health information.

19.

Objective: Provide clinical summaries to patients for each office visit.
Measure: Clinical summaries provided to patients for at least 80 percent of all office visits.

20.

Objective: Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically.
Measure: Performed at least one test of certified EHR technology's capacity to electronically exchange key clinical information.

21.

Objective: Perform medication reconciliation at relevant encounters and each transition of care.
Measure: Perform medication reconciliation for at least 80 percent of relevant encounters and transitions of care.

22.

Objective: Provide summary care record for each transition of care and referral.
Measure: Provide summary of care record for at least 80 percent of transitions of care and referrals.

23.

Objective: Capability to submit electronic data to immunization registries and actual submission where required and accepted.
Measure: Performed at least one test of certified EHR technology's capacity to submit electronic data to immunization registries.

24.

Objective: Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice.
Measure: Performed at least one test of certified EHR technology's capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an EP or eligible hospital submits such information have the capacity to receive the information electronically).

25.

Objective: Protect electronic health information maintained using certified EHR technology through the implementation of appropriate technical capabilities.
Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a) (1) and implement security updates as necessary.

CONTACT US
Risë Marie Cleland
Rise@Oplinc.com

Oplinc, Inc.
113 W. 7th Street
Suite 205
Vancouver, WA 98660
360.695.1608 office
360.695.6937 fax
www.Oplinc.com
Rise@Oplinc.com

UPCOMING ISSUE
Comments and suggestions for future issues are welcome, please forward correspondence to Risë Marie Cleland by email at: Rise@Oplinc.com

PAST ISSUES
Access all of our previous newsletters.

ABOUT THE EDITOR
Risë Marie Cleland is the Founder and CEO of Oplinc, Inc., a national organization of oncology professionals. Through Oplinc, Inc. Ms. Cleland publishes the weekly Oplinc Fast Facts focusing on the timely dissemination of information pertaining to billing, reimbursement and practice management in the oncology office and Oplinc’s Best Practices Review, which provides a more in-depth look at the issues and challenges facing oncology practices. Ms. Cleland also works as a consultant and advisor for physician practices, pharmaceutical companies and distributors.

IMPORTANT NOTICES
Please note that this newsletter is presented for informational purposes only. It is not intended to provide coding, billing or legal advice. Regulations and policies concerning Medicare reimbursement are a rapidly changing area of the law. While we have made every effort to be current as of the issue date, the information may not be as current or comprehensive when you review it. Please consult with your legal counsel for any specific reimbursement information. For Medicare regulations visit: www.cms.gov.

CPT® is a Trademark of the American Medical Association Current Procedural Terminology (CPT) is copyright 2010 American Medical Association. All Rights Reserved. No fee schedules, basic units, relative values, or related listings are included in CPT. The AMA assumes no liability for the data contained herein.

Copyright ©2010
Oplinc, Inc.
Oplinc, Inc., grants permission to distribute this newsletter without prior permission provided that it is forwarded unedited and in its entirety.

spacer
spacer
Remove me from this distribution list | Sign up to receive this newsletter