Transcript The Bermuda Market in 2005

Demystifying CMS Nonpayment Strategies and
Mandatory Insurer Reporting Requirements
Presented by:
Roberta Carroll
Senior Vice President
Aon Healthcare
MMSEA
Session Objectives
 Review how the current climate impacts strategy
 Identify CMS Non-payment strategies including:
– Medicare Secondary Payer Statutes
– DRA and Hospital-Acquired Conditions
– Mandatory Insurer Reporting under MMSEA
 Review the penalties for non-compliance
 Understand what it means (takes) to be compliant
 Prioritize what to do first
2
Understanding the Current Climate
3
Current Environment – Ready for Change


Global spotlight on governance and finance
– Diminished reimbursement
– Credit risk/Interest rate risk
– Need for the efficient allocation of capital
– Economic Downturn
– Number of un-under-insureds
Centers for Medicare and Medicaid
– Inpatient Prospective Payment System [IPPS]
– Hospital Acquired Conditions [HAC]
– Medicare Secondary Payer Statutes [MSP]
– MMSEA
4
Capital Crisis
 Borrowed money (debt) - comes
form bond offerings and loans from
banks and other financial institutions
 Philanthropy - refers to charitable
donations
 Reserves - refers to savings hospitals
build up over time by having a positive
net income and a return on invested
money
 Capital - refers to the money used to
fund investments in facilities and
equipment
 Equity – refers to selling an ownership
interest (used less frequently)
5
Survey Highlights
 Borrowing is severely
constrained
 Charitable donations has
become harder
 ½ have put capital projects
on hold:
 Capital decisions are
affected as uncertainty
mounts, operating
performance declines and
the value of reserves fails
due to stock market and
other investment woes
– 82% facility projects
– 65% clinical technology
– 62% information
technology
 Affects ability to meet
community needs and goals
such as improved quality,
efficiency and coordination
of care
6
Impact of the Economic Downturn on Hospitals
FINAL
January 14, 2009
Research and Analysis by Avalere Health
Survey Results
 Financial health is worsening as
patient seek less care and
investment gains turns to losses
 Difficult and expensive to
finance facility and technology
needs
– Making/considering cutbacks
– Increased cost of borrowing
– Decreases access to financing
 Stress on state and federal
budgets raise worries about cuts
to Medicare and Medicaid
provider payment
 Number and mix of patient
seeking care is changing
– Lower admissions and elective
procedures
– Rising unemployment leading
to increased uncompensated
care

Hospitals and health care are a
critical part of the economy
– 45% of new private sector jobs
were created in the health
sector in 2007
– Hospitals employ more that 5
million people
 Physicians seeking financial
support from hospitals
8
Unemployment is Rising
Unemployment Rate (Non-farm), 2007-2008
8.0%
% Unemployment
7.0%
6.0%
5.0%
44% increase
4.0%
3.0%
Jan07
Feb- Mar- Apr07
07
07
May- Jun07
07
Jul- Aug07
07
Sep- Oct- Nov- Dec- Jan- Feb- Mar- Apr07
07
07
07
08
08
08
08
May- Jun08
08
Jul- Aug08
08
Sep- Oct- Nov- Dec08
08
08
08
Department of Labor, Bureau of Labor Statistics, Labor Force Statistics. (2008). Access at:
http://www.bls.gov/oco/cg/cgs035.htm.
9
HFMA Survey
 The factors that will most
affect long-term financial
position and the ability to fulfill
mission include:
– Patient volume
– Uninsured/underinsured
– Non-operating income
Investment income
Philanthropic giving
– Capital access and cost of debt
– Regulatory and payment “wild
cards”
10
Issue
2008
2007
2006
Financial Challenges
77%
70%
72%
Patient Safety & Quality
43%
NA
NA
Care for uninsured
41%
38%
37%
Physician-hospital relations
32%
35%
40%
Personnel shortages
30%
30%
30%
Governmental mandates
26%
22%
23%
Patient Satisfaction
22%
17%
16%
Capacity
16%
11%
11%
Technology
9%
8%
8%
Not-for-profit status
2%
4%
3%
Malpractice Insurance
2%
2%
3%
Disaster preparedness
1%
1%
1%
Patient safety
Na
29%
27%
Quality
NA
33%
29%
Financial challenges
continue to rank 1st
on the list of hospital
CEOs top concerns in
‘08, with patient
safety and quality
their 2nd most
prominent concern
Not easy tasks
Patient Safety
and Quality
Concerns in
Order of
Importance
Redesigning care processes
66%
Redesigning work environment
66%
Compliance with accrediting organizations
60%
Medication errors
57%
Hospital-associated infections
47%
Nonpayment for “never events”
43%
P4P
41%
Leapfrog demands
40%
Public outcomes reporting
40%
Surgical mistakes
24%
Other
7%
Governance Refocused
 Fiscal – new focus on the Board’s oversight of organizational
finance
 Reputation – conflicts of interest and perception of wrong
doing
 Clinical – only 27% of hospital boards spend 25% of time on
quality
 Executive compensation is being linked to quality and safety
improvement
13
Medicare as a Secondary Payer
[MSP]
 Medicare when first enacted in 1965 was a primary payer of health
benefits with few exceptions [Federal Black Lung Program, Workers’
Compensation, Veterans Administration]
 §953 COBRA of 1980 = Medicare Secondary Payer (MPS) statute was
enacted making Medicare a 2nd payer to Automobile, Liability and NoFault coverage
 Medicare Secondary Payer Act: Section 1862(b) of Social Security Act
(1980)
14
What is a Primary Plan?
 Under MSP statutes a “primary plan” includes:
– Group health plan [GHP]
– Liability insurance policy or plan (which includes a self-insured plan)
– “No-fault” insurance policy
– Workers’ compensation law or plan
 The premise underlying the MSP program is that 3rd parties may not
shift the cost of medical expenses attributed to their wrongdoing from
themselves to the taxpayers.
15
What is MMSEA?
(Medicare, Medicaid, and SCHIP Extension Act of 2007)
 AKA- Senate Bill S.2449; MSCHIP; MMSEA/111; MIR (Mandatory
Information Reporting) Section 111; or simply 111, MMSEA
(pronounced “MC”)
 Signed into law on December 29, 2007, and includes
modifications to MSP laws
 Section 111 [see 42 U.S.C. 1395y(b)(7)&(b)(8) - [PL 110-173]
– Imposes reporting requirements upon GHPs, liability insurance plans
[including self-insurance], no-fault insurance plans and workers’
compensation plans
– Section 7 GHP reporting - Effective January 1, 2009
– Section 8 non-GHP plans - Effective July 1, 2009
16
Responsible Reporting Entities?
CMS defines RRE as follows:
 Entity who has paid a settlement, award, judgment, or other
payment on or after July 1, 2009 with a Medicare eligible
beneficiary (or claimant), or has responsibility for ongoing
medical payments to a claimant on or after July 1, 2009.
17
“MMSEA Section 111“
Major Elements of the Law
 “Self Insured” for non-GHP as defined by CMS includes
– Any entity that pays its own claims
– An entity that engages in a business, trade, or profession
shall be deemed to have a self-insured plan if it carries its
own risk (whether by a failure to obtain insurance, or
otherwise) in whole or in part.
– Any entity that “self-insures” a deductible insurance
program.
– Any entity that pays or funds the settlement of its own
claims
18
Complying with MMSEA


First, determine if you are an RRE
– Do you have a guaranteed cost program?
 If yes, you are not an RRE
– Are you self-insured or have a captive?
 If yes, you are an RRE
– Do you have a deductible?
 If funded by the carrier – not an RRE
 If you fund the deductible, either directly or through
your TPA - you are an RRE
A TPA cannot be an RRE under NGHP
19
Risk Retention Pools
 CMS recognizes that some entities may elect to manage their loss exposures
for liability, no-fault, or workers’ compensation by joining with other similarly
situated entities in forming self-insurance pools (such as joint powers
authorities or risk retention pools where permitted by law). ALL of the
following conditions must be met in order for the “pool” to qualify as an RRE:
a. The “pool” itself must be a separate legal entity.
b. The pool must have full responsibility to resolve and pay claims using pool
funds.
c. The individual participating members or entities may not be involved in the
decisions in how individual claims are resolved.
 IF ANY ONE OF THESE CONDITIONS IS NOT MET, THEN THE PARTICIPATING
MEMBER REMAINS AN RRE. If you are a member of a risk retention pool, we
strongly encourage you to have discussions with your pool managers, brokers,
and consultants to discuss these conditions and how they affect your legal
responsibilities under MMSEA
20
Are Captives RREs?
 Further clarification from CMS on how captives will be treated
under MMSEA is being awaited. Because CMS has been very
consistent with “follow the money” it is anticipate rules will be
promulgated based on if there has been any actual risk transfer.
– In circumstances where the captive is a wholly owned subsidiary of
a company and accepts no risks outside of the parent company, it is
anticipated that CMS will allow that company flexibility in
designating an RRE. I
– If the captive accepts risks outside of the parent and takes on
characteristics of a risk retention “pool” then it is anticipated that
CMS will treat that captive like a pool.
– Ensure that all captive polices are written on a “reimbursement”
basis where the owner/parent pays claims and the captives
reimburses the parent/owner after the fact.
21
RRE Registration

Registration for reporting and file submission with the COBC
must be completed by the RRE. (May 1, 2009 – September 30, 2009)

An RRE may register as many times as necessary for various
lines of coverage

An RRE can appoint an RA; however, only one Registered Agent
may be appointed per RRE

A Registered Agent may represent multiple RREs

An agent may not register for an RRE

CMS provides computer-based training (“CBT”) for RREs preregistration. You can call COBC’s EDI Department to register for
on-line training at 646-458-6740.
22
Responsibilities of an RRE
 Register as a RRE
 Implement claim procedures for identification of Medicareeligible beneficiaries (including SSN or HICN)
 Prepare electronic reporting files (currently 150 data elements)
formatted to COBC’s Input Claim File Layout
 Provide electronic reports to COBC on new claims on a quarterly
schedule assigned to the RRE by the COBC
 RRE can assign a Reporting Agent (RA) at the time of registration.
However, RREs remain responsible for any civil money penalties
(CMP) allowed under MMSEA/111
23
Authorized Representative
 Each RRE must assign or name an Authorized Representative. The
Authorized Representative:
Individual with legal authority to bind the organization to a contract
Has ultimate accountability for RRE’s compliance
Cannot be a user of the COBSW.
Cannot be an agent of the RRE.
May perform the initial registration on the COBSW, but will not be
provided with a Login ID.
Will designate the Account Manager.
Must approve the account setup, by physically signing the profile
report including the Data Use Agreement, and returning it to the
COBC.
Will be the recipient of COBC notifications related to non-compliance
with Section 111 reporting requirements.
24
Appointment of a Reporting Agent
 CMS allows the retention of Reporting Agents (RA) for purposes
of reporting claims to CMS
 While RRE may retain an RA, the RRE remains responsible for civil
penalties under the Act.
 TPAs are not allowed to be RREs under Section 8
Third-party administrators (TPAs) as defined by CMS for purposes
for 42 U.S.C. 1395y(b)(7) & (8) are never RREs for purposes of 42
U.S.C. 1395y(b)(8) [liability (including self-insurance), no-fault,
and workers’ compensation reporting] based solely upon their
status as this type of TPA. (Note that for purposes of 42 U.S.C.
1395y (b)(7) reporting for group health plan arrangements, this
type of TPA is automatically an RRE.)
25
Reporting
 Who Must Report:
– An applicable plan
The term 'applicable plan' means the following laws, plans, or
other arrangements, including the fiduciary or administrator for
such law, plan, or arrangement:
(i) Liability insurance (including self-insurance).
(ii) No-fault insurance.
(iii) Workers' compensation laws or plans." 42 U.S.C.1395y(b)(8)(F)
 What Must Be Reported:
– The identity of a Medicare beneficiary whose illness, injury, incident,
or accident was at issue as well as such other information specified
by the Secretary to enable an appropriate determination concerning
coordination of benefits, including any applicable recovery claim.
Data elements determined by the Secretary.
26
Projected Population Growth &
Medicare Impact
Year
Total
Population
65 years & older
% of Total
Population 65 &
Older
2010
310,233,000
40,229,000
12.97%
2020
341,387,000
54,804,000
16.07%
2030
373,504,000
72,092,000
19.3%
2050
439,010,000
88,547,000
20.2%
Projections of the Population for the United States: 2010-2050 (NP2008 T1 & T2, August 14, 2008.
Population Division, U.S. Census Bureau
27
Reporting Thresholds for Liability Insurance
(including Self Insurance) for “TPOC”
 July 1, 2009 to December 31, 2010
– $0 to $5,000*
 January 1, 2011 through December 31, 2011
– $0 to $2,000*
 January 1, 2012 through December 31, 2012
– $0 to $600*
* Where multiple records submitted on the same claim by the same
RRE, the combined TPOC CANNOT EXCEED the total threshold
amount!
Example: July 2, 2009, liability settlement with Medical Payments
coverage settlement of $4,000 and Indemnity of $1,000. Total TPOC
of $5,000 threshold met and must be reported under MMSEA.
28
Important Dates & Deadlines
 March 2009
CMS released NGHP Users Guide. Guide will provide specific information on the
means and methods required of RREs and their RAs comply with MMSEA
Section 111
 May 11, 2009
Alert extending the registration, testing and reporting dates
 May 1, 2009 – September 30, 2009
RREs must register with the COBC on their secure website RREs should be
prepared to identify their reporting agent to the COBC at the time of
registration.
 July 1, 2010
Test and Production Query Input Files Accepted
29
Important Dates & Deadlines
 January 1, 2010
Claim Input File Testing Begins
 January 1, 2010
Production Claim Input Files Accepted
 April 1, 2010 to June 20, 2010
Initial Claim Input File Submission Due – (based on assigned reporting
window date (within 7-day window)
 April 1, 2010
Noncompliance enforcement and penalties after April 2010
30
Coordination of Benefits Contractors
 Pending litigation is reported by plaintiff attorneys
– CFR 411.52 says the beneficiary must file a claim
– Beneficiary hires an attorney and they must contact the COBC
– Why do plaintiff attorneys alert COBC before settlement?
 They need the information to litigate for special damages (e.g., medical
bills)
 If they don’t, they could be liable for malpractice when Medicare seeks
recovery from the beneficiary after settlement
– Medicare holds plaintiff attorneys responsible under Section 1862.
[41 U.S.C. 1395y] 1862 (b)
 “…the United States may recover under this clause from any entity that
has received payment from a primary plan or from the proceeds of a
primary plan's payment to any entity.”
31
COBS and the Common Working File
 What does the COBC do whey they learn of a claim?
– Record pending liability suit on the Common Working File (CWF)
– Providers and Intermediaries consult CWF to accept or deny
Medicare claims
32
Medicare Prescription Drug, Improvement,
and Modernization Act of 2003
Pub. L. No. 108-173, § 301, 117 Stat.2066, 2221
 Elaborated the definition of “self-insured” to include corporations that simply
carry the risk of not purchasing insurance (MMA § 301(b)(1))
 Made clear that Medicare may make a conditional payment when the primary
plan has not made or is not reasonably expected to make prompt payment.
 Clarifying language: Pursuant to 42 U.S.C. 1395y(b)(2)(B)(iii), in order to recover payment
made under this title for an item or service, the United States may bring an action against any
or all entities that are or were required or responsible (directly, as an insurer or self-insurer, as
a third-party administrator, as an employer that sponsors or contributes to a group health
plan, or large group health plan, or otherwise) to make payment with respect to the same item
or service (or any portion thereof) under a primary plan. The United States may, in accordance
with paragraph (3)(A) collect double damages against any such entity. In addition, the United
States may recover under this clause from any entity that has received payment from a
primary plan or from the proceeds of a primary plan’s payment to any entity.
33
Conditional Payments
 CFR 411.52 allows Medicare to pay conditionally if:
– Medicare does not reasonably expect the 3rd party insurer
to make its primary payment promptly. Promptly is
considered to be within 120 days.
– Or the liability insurer has denied the claim
34
Recovering Conditional Payments
 The Medicare Secondary Payer Recovery Contractor (MSPRC)
– Recovering conditional payments after a liability settlement
– From the beneficiary
Demands are sent to the beneficiary with a copy to the
attorney
If the demand is not paid in 60 days interest begins
accruing and the beneficiary receives an Intent To
Recover (ITR) Letter threatening collection by the
Department of Treasury
If the demand is not paid in 120 days then the beneficiary
is referred to Treasury
35
“Follow the Money”
 Insurers and Self-Insured have had a reporting obligation
– Anyone having “knowledge” of a situation where Medicare should
not pay primary had an obligation to report or be subject to double
damages Section 1862 [42 U.S.C. 1395y]
– Recovery from Insurers and Self-Insured is not part of the normal
MSPRC process
– Medicare can seek recovery and damages from Insurers and SelfInsured through the courts
 Insurers and Self-Insured settled with the beneficiary
– Beneficiary has the money
– The MSPRC follows the money and seeks recovery from the
beneficiary
36
Protecting Medicare’s Interest
 It is easier to recover the money before it gets in the hands of
the beneficiary
– The beneficiary is less likely than an attorney
or insurer to know about Medicare’s right to recover
conditional payments
– Some refer to this as “Protecting Medicare’s Interest”
– There are no explicit laws or regulations requiring entities to
protect Medicare’s interest
– MSP holds the beneficiary responsible right up to collections
from Treasury
37
Protecting Medicare’s Interest cont…
 If there is no attorney involved
– You can determine the conditional payment amount by requesting
an Interim Conditional Payment Letter (CPL) from the MSPRC and
withhold that amount from settlement for reimbursement to
Medicare
– If you are aware of Medicare claims by virtue of direct knowledge
from the Medicare Secondary Payer Recovery Contractor (MSPRC)
or by indirect knowledge from the fact you paid no medicals, then
consider sending a two party check to the MSPRC with details
about the beneficiary and incident
– At a minimum, make sure the beneficiary is aware of Medicare’s
right to recover and seek a release at settlement
38
Penalties for Non-Compliance
 Section 111 of the MMSEA added certain reporting
requirements and civil penalties to Section 1862(b) [42 USC
1395y(b)] upon “any entity, a plan administrator” who fails to
comply with the reporting requirements under the Act. Those
entities (further described by CMS as “Responsible Reporting
Entities” “shall be subject to civil money penalty of $1,000 for
each day of noncompliance for each individual for which the
information [required] should have been submitted.” While
MMSEA Section 111 adds the reporting requirements and
penalties, it does not change any of the other provisions of
the MSP statutes under Section 1862(b).
39
Steps for Reporting
 Determine individuals that will be the RRE’s Authorized
Representative, Account Manager and Account Designees.
 Determine whether reporting agents will be used.
 Determine how claim files will be submitted – one file for the RRE
or separate files based on line of business, agent, subsidiaries,
etc., which will require more than one RRE ID.
 Determine which file transmission method you will use. If you
choose SFTP/HTTPS, you will transmit files via the COBSW. If you
choose Connect:Direct (AGNS) establish a connection to AGNS, if
you don’t have one yet, and create transmission jobs and
datasets.
 Complete your registration for each RRE ID needed, including file
transmission information on the COB Secure Web site (COBSW)
between May 1, 2009, and September 30, 2009.
40
Steps for Reporting cont…
 Receive your profile report via e-mail indicating your registration
and account setup were accepted by the COBC.
 Verify, sign and return your profile report to the COBC.
 Review file specifications, develop software to produce Section 111
files, and schedule your internal quarterly submission process.
 Test each Section 111 file type you will be exchanging with the
COBC.
 Submit your initial Claim Input File by your assigned production live
date.
 Submit your Query File as needed but no more than monthly
ongoing.
 Submit your quarterly Claim Input File ongoing during your assigned
submission periods.
41
Facts to Remember!
 If the insurance and self-insured company reports they have
met the Mandatory Insurer Reporting statutes
 Medicare Secondary Payer statutes are a separate issue from
Mandatory Insurer Reporting under MMSEA
 Medicare Secondary Payer Recovery Contractor (MSPRC)
follows the money and seeks recovery of conditional payments
from the beneficiary, and not the liability insurer
 Medicare may seek damages from others if they cannot collect
from the beneficiary, but these cases are rare and pursued in
the courts
42
Strategies for Compliance
1. Review current claims management practices in managing MSP
claims for all lines of coverage contemplated under MMSEA.
2. Analyze exposure as an RRE as respects your current insurance
program.
3. Understand the registration process and timeframes
4. Analyze current TPA’s claims practices with CMS’s proposed (and
final) reporting protocols in CMS Users Guide with proposed
recommendations and action plans.
5. Develop MMSEA claims “best practices” for use and consideration
by their current TPAs.
43
Strategies for Compliance cont…
6. Have processes in place to respond to error codes, compliance
flags or disposition code requiring the RRE to resubmit the
claim.
7. Review current TPA or Reporting Agent contracts. Evaluate
contractual risk transfer of MMSEA/111 and MSP exposures to
TPA or Reporting Agent.
8. Review current E&O coverage (TPA/RA) to ensure it also
includes coverage for statutory civil penalties as an element of
damages.
9. Perform compliance audits to ensure compliance. Change
program as necessary
44
Relationship with HACs
 Continuing in its effort to
preserve the Medicare Trust
and just as CMS has
implemented the nonpayment strategy for HospitalAcquired Conditions (HACs) ,
the Mandatory Insurer
Reporting (MIR) Requirements
under MMSEA will reinforce
efforts to ensure Medicare is a
secondary payer (MSP) when
other applicable Plans are
45
available.
Rational for Hospital Acquired Conditions
 Passive payer ►active purchaser
 Fee-for-service schedules and PPS are not based on quality or
unnecessary cost avoidance
 Nonpayment for HAC promotes better quality while avoiding
unnecessary costs
 Supports Medicare’s VBP
 Public support to pay less for HAC
46
Deficit Reduction Act of 2005
 Section 5001(c) of Public Law 109-171 required CMS to identify
by October 1, 2007 at least two preventable complications of
care that could cause patients to be assigned to a higher paying
DRG.
 Those conditions were mandated to be:
– high cost or high volume or both,
– result in the assignment of a case to a DRG that has a higher
payment when present as a secondary diagnosis, and
– be reasonably preventable through the application of evidencebased guidelines.
47
Deficit Reduction Act of 2005
 The DRA mandated that for discharges occurring on or after
October 1, 2008, the presence of one or more of these
preventable conditions would not lead to the patient being
assigned to a higher paying DRG. That is, the case would be
paid as though the secondary diagnosis was not present.
 The DRA required hospitals to submit the secondary diagnoses
that are present on admission (POA) when reporting payment
information for discharges on or after October 1, 2007.
48
HAC & “Never Events”
 National Quality Forum “Never Events”
– 6 of the 10 Hospital-acquired conditions are now on the list
Pressure ulcers Stage III & IV
Blood incompatibility
Air embolism
Hospital acquired Injuries from falls [death or serious injury],
electric shock [death or serious disability], or burns [death or
serious disability]
Retained objects [unintentional]
Hypoglycemia [death or serious disability]
49
Risk Mitigation
 Prevent HAC including infections
 Quantify and understand the impact of these and future changes
 Develop tools such as preadmission and admitting
screening/testing guidelines and protocols
 Educate staff to POA coding requirements
 Report to others in the organization adverse events
 Understand and comply with jurisdictional requirements for
reporting
 Stress the importance of appropriate documentation
50
X
 Unfortunately, even with all the efforts by CMS, The Medicare
Trust - Part A is still predicted to be exhausted by 2017
51
Resources
 CMS Websites:
NGHP User Guide Published March 16, 2009 – Available at:
http://www.cms.hhs.gov/MandatoryInsRep/Downloads/NGHPUserGuide0316
09.pdf
– ALERT for Liability Insurance (Including Self-Insurance), No-Fault Insurance, and
Workers’ Compensation Published March 20, 2009 Available at:
[http://www.cms.hhs.gov/MandatoryInsRep/Downloads/Allert_UserGuideSup
p_NGHP.pdf]
– ALERT for Reporting Multiple Total Payment Obligation to the Claimant (TPOC)
Amounts for Liability Insurance (Including Self-Insurance), No-Fault Insurance,
and Workers’ Compensation Published April 7, 2009 Available at:
[http://www.cms.hhs.gov/MandatoryInsRep/Downloads/NGHPAlertTPOC.pdf]
– ALERT for extending reporting, testing and reporting times
http://www.cms.hhs.gov/MandatoryInsRep/Downloads/NGHPV10UserGuide0
51109.pdf
–
52
Resources
 The statutory provisions for MSP can be found at 42 U.S.C. 1395y(b); the
applicable regulations can be found at 42 C.F.R. Part 411. Supplemental
guidance regarding the MSP provisions can be found at:
– [www.cms.hhs.gov/COBGeneralInformation]
– [www.msprc.info]
– [www.cms.hhs.gov/WorkersCompAgencyServices].
 Part II. Department of Health and Human Services - Centers for Medicare &
Medicaid Services 42 CFR Parts 411, 412, 413, and 489 Medicare Program;
Changes to the Hospital Inpatient Prospective Payment Systems and Fiscal
Year 2008 Rates; Final Rule Federal Register Vol. 72/No. 162/ Wednesday,
August 22, 2007 [http://edocket.access.gpo.gov/2007/pdf/07-3820.pdf]
 Department of Health & Human Services. Centers for Medicare & Medicaid
Services. 42 CFR Parts 411, 412, 413, 422, and 489. Medicare Program:
Changes to Hospital Inpatient Prospective Payment System and Fiscal Year
2009 Rates. Final Rules. Federal Register / Vol. 73 No. 161 / Tuesday,
August 19, 2008 / Rules & Regulations [
53
Questions?
54
Contact information
Roberta Carroll
Senior Vice President
Aon Healthcare
Tampa, Fl. 33556
Phone: (813) 926-8069
Fax: (813) 926-8084
E-Mail: ([email protected])
55