Washington Report –February, 2011

Bill Finerfrock, David Connolly, Leigh Perica and Zhaneta Mansaku

Government Shutdown or Showdown?2012 Budget and SGR FixEHR Incentive Payments Are Now AvailableHHS Imposes $4.3 Million CMP For Violations Of HIPAA Privacy Rule5010 Is Coming, Are You ReadyDon, We Hardly Knew Ya…Wave If You Got a WaiverRepeal, Replace or LitigateWho Are These People – a Series1099 Repeal on the Horizon?CMS Transmittals

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Government Shutdown or Showdown?

If the government shuts down and no one notices, did it really shut down? The answer to that question may get answered in the not too distant future if the two Houses of Congress and the President are unable to reach an agreement on government spending to cover the remainder of the current Fiscal Year.

When the 111th Congress adjourned in December 2010, it failed to not only pass a budget for the first time in more than 30 years, it also failed to pass a single appropriations bill for the first time in our nation’s history. Consequently, the federal government has been operating on what is known as a “Continuing Resolution” since October 1, 2010.

A Continuing Resolution (CR) is a piece of legislation that effectively extends the Fiscal Year beyond its normal end of September 30th. And while enactment of CRs is fairly commonplace, most are for short periods of time or only cover a few agencies or programs, not the entire government. When a

CR is in place, government agencies covered by the CR are authorized to continue spending money on programs approved under the previous appropriation bill but no new programs or initiatives can be undertaken. In effect, it freezes federal spending at the previous years level.

If Congress and the President are unable to reach agreement on a new spending bill by March 18 th many people have wondered what actions will/could be taken to close the government and what will/could remain open.

The last time we faced a similar situation was 1995. In that year, the Republican Congress and President Clinton were unable to reach agreement on spending bills for a number of federal agencies. For 21 days spanning late 1995

and early 1996, “non-essential” federal employees for several Departments were furloughed and a partial government shut-down ensued.

Employees of each agency deemed “essential” would still be required to report to work. Essential employees are determined by each agency in a plan submitted to the Office of Management and Budget (OMB) in case of a shutdown. The definition of an essential employee is one who performs “duties vital to national defense, public health and safety, or other crucial operations.” Federally funded healthcare (Medicare and Medicaid) was continued during the 1995 shutdown, and evidence suggests that it would be automatically continued if a future shutdown occurred. During the 1995 shutdown, essential employees under public health and related crucial operations included employees in the Healthcare Financing Administration (now known as CMS) who handled Medicare claims administration (including contractors). Evidence suggesting that these services will continue in the current environment is also based on a White House memo that states that programs with indefinite appropriations are not affected by annual appropriations legislation. The statement in context follows:

“Not all government functions are funded with annual appropriations. Some operate under multi-year appropriations and others operate under indefinite appropriations provisions that do not require passage of annual appropriations legislation. Social security is a prominent example of a program that operates under an indefinite appropriation. In such cases, benefit checks continue to be honored by the treasury, because there is no lapse in the relevant appropriation.”

As with Social Security, Medicare and Medicaid operate under “indefinite appropriations” and CMS employees (and contractors) responsible for ensuring payment of claims would, therefore, be deemed essential.

Ideally, the Congress and the President will be able to work out a compromise that is able to garner support from a majority in the House of Representatives and a majority in the Senate. Unfortunately, if past is prologue – and in these cases it usually is – a compromise won’t be reached until the last minute.

HBMA will continue to monitor this process and encourage Congress and the President to resolve their budget differences.

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2012 Budget and SGR Fix

On Monday, February 14, 2011, President Obama submitted his Fiscal Year 2012 budget to Congress.

According to Administration officials, President Obama’s budget would trim the deficit by $1.1 trillion over 10 years, with two-thirds of the savings coming from proposed spending cuts and one-third from proposed tax increases.

The President’s budget proposes a $663 million increase in CMS’s discretionary budget which reflects money needed to implement the health care reform law enacted last year. Republicans in both the House and Senate are seeking to eliminate these funds in order to “starve” the implementation of the Patient Protection and Affordable Care Act.

President Obama’s budget proposes a 2 year SGR fix. In essence, he is proposing a 2 year freeze of physician payments covering CY 2012 and CY 2013. His budget then assumes that Congress will find a permanent fix for the SGR problem beginning in 2014. The short-term impact of freezing the Conversion Factor for two years would be an additional $62 Billion in Medicare expenditures relative to what would have been spent if the SGR related cuts go into effect. The President proposes to "pay for" this freeze by eliminating fraudulent or wasteful spending in the Medicare program, making various

changes in the Medicaid program that would reduce federal outlays, impose a financial penalty on providers who do not update their Medicare enrollment information, and other activities aimed at reducing costs. According to the President’s budget, the long-term cost of fixing the SGR problem is estimated at $315 Billion over 10 years. The President's budget assumes that this will occur and that Congress will find the money to pay for this fix. However, no specific long-term proposals for how to fix the SGR problem are put forward by the Obama Administration nor is there any proposal for how to pay for the unspecified fix. With regard to the SGR problem, the President’s budget documents say the following:

"The Administration is committed to working with Congress to achieve permanent, fiscally responsible reform and to give physicians incentives to improve quality and efficiency, while providing them with predictable payments for the care they furnish to Medicare beneficiaries."

Below is a chart that highlights various key proposed funding levels for CMS. The line-item identified as “Program Operations” funds such activities as claims processing, provider enrollment and other administrative activities carried out by Medicare’s contractors. We would also direct your attention to the line-item for the Recovery Audit Contractor program. The Obama Administration proposes to more than double the amount of money available for RAC audits, dramatically expanding this program in 2012.

Dollars are in Millions

2010 Actual 2011 Continuing Resolution (CR)

2012 estimate

Program operations $2,404 $2,689 $3,245Federal administration 697 767 925State survey & certification 366 469 417Research, demonstrations 39 602 90High-risk pool grants 55 55 44ARRA Medicare/Medicaid HIT 88 191 201Consumer Assistance Grants 1 29 0Recovery audit contractors 26 259 500CLIA 54 43 43Data Sales 8 2 2Coordination of Benefits 42 52 59

It is important to note that the President’s budget is a proposal. It has no binding authority on Congress or the agencies. The House and Senate will each adopt their own budget documents sometime this spring and attempt to reconcile the differences between the two versions. Unlike actual spending bills, the budget passed by Congress does not go to the President for signature or approval.

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EHR Incentive Payments Are Now Available

According to a press release issued by the Centers for Medicare and Medicaid Services (CMS), the initial response to the EHR incentive program has been very positive. CMS has announced that more than 21,000 providers “initiated registration for the Medicare” EHR meaningful use incentive program and four states have reported initial Medicaid incentive payments totaling more than $20 Million.

The Office of the National Coordinator for Health Information Technology (ONC) also announced that as of Feb. 11, 2011, “more than 45,000 providers requested information or registration help from 62 Regional Extension Centers (RECs).”

CMS and ONC interprets this early interest in the Medicare and Medicaid EHR programs to be reflective of “strong support for these programs that will advance health care through improvements in patient safety, quality of care, and patient involvement in treatment options.”

CMS has asked that we remind eligible professionals that they must register in order to participate in the Medicare and Medicaid EHR incentive programs. Registration opened on Jan. 3, 2011, at http://www.cms.gov/EHRIncentivePrograms/20_RegistrationandAttestation.asp.

For the Medicaid EHR Incentive Program, providers will follow a similar process using their state’s attestation system. Check here to see states’ scheduled launch dates for their Medicaid EHR Incentive Programs: http://www.cms.gov/apps/files/medicaid-HIT-sites/.

For more information on the Medicare and Medicaid EHR Incentive Programs, visit http://www.cms.gov/ehrincentiveprograms/.

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HHS Imposes $4.3 Million CMP For Violations Of HIPAA Privacy Rule

The U.S. Department of Health and Human Services’ (HHS) has concluded that Cignet Health of Prince George’s County, Md., (Cignet) violated the HIPAA Privacy Rule and therefore, the agency “has imposed a civil money penalty (CMP) of $4.3 million for the violations.” This represents the Civil Monetary Penalty (CMP) issued by the Department for a covered entity’s violations of the Privacy Rule.

In making the announcement, HHS Secretary Kathleen Sebelius said, “Ensuring that Americans’ health information privacy is protected is vital to our health care system and a priority of this Administration. The U.S. Department of Health and Human Services is serious about enforcing individual rights guaranteed by the HIPAA Privacy Rule.”

HHS found that Cignet violated 41 patients’ rights by denying them access to their medical records when requested between September 2008 and October 2009. These patients individually filed complaints, initiating investigations of each complaint. The HIPAA Privacy Rule requires that a covered entity provide a patient with a copy of their medical records within 30 (and no later than 60) days of the patient’s request.

According to public information available about the case, Cignet officials refused to respond to demands by the Office of Civil Rights (OCR) that they produce the records. In addition, Cignet officials failed to cooperate with OCR’s investigations of the complaints and produce the records in response to a subpoena.

Finally, OCR found that Cignet failed to cooperate with OCR’s investigations on a continuing daily basis from March 17, 2009, to April 7, 2010, and that the failure to cooperate was due to Cignet’s willful neglect to comply with the Privacy Rule. Covered entities are required under law to cooperate with the Department’s investigations.

The total amount of the CMP for all of these findings was $4.3 Million dollars.

Covered entities and business associates must uphold their responsibility to provide patients with access to their medical records, and adhere to all of HIPAA’s requirements. HHS officials stated that they “…will continue to investigate and take action against those organizations that knowingly disregard their obligations under these rules.”

To read more about this case, go to http://www.hhs.gov/ocr/privacy/hipaa/news/cignetnews.html.

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5010 Is Coming, Are You Ready

Effective January 1, 2012, all covered entities must be able to engage in electronic transactions using the 5010 standards. During 2011, trading partners should be testing with one another to ensure readiness by the 2012 deadline.

During the transition to Versions 5010 and D.0, CMS will periodically remind you of important items and dates that may be of specific interest to Medicare fee-for-service (FFS) providers and suppliers. CMS has developed the following chart as a reminder. Please see below to learn about current, upcoming or past events that have taken place during the implementation process

Everyone affected by the Version 5010 and ICD-10 transitions – health care providers, payers, software vendors, and clearinghouses/third-party billers – need to prepare to meet the following timetable to ensure compliance.

Date Compliance Step

January 1, 2010 Payers and providers should begin internal testing of Version 5010 standards for electronic claims

December 31, 2010 Internal testing of Version 5010 must be complete to achieve Level I Version 5010 compliance

January 1, 2011

• Payers and providers should begin external testing of Version 5010 for electronic claims

• CMS begins accepting Version 5010 claims

• Version 4010 claims continue to be accepted

December 31, 2011 External testing of Version 5010 for electronic claims must be completed to achieve Level II Version 5010 compliance

January 1, 2012

• All electronic claims must use Version 5010

• Version 4010 claims are no longer accepted

October 1, 2013

• Claims for services provided on or after this date must use ICD-10 codes for medical diagnosis and inpatient procedures

• CPT codes will continue to be used for outpatient services

According to CMS, if providers do not conduct electronic health transactions using Version 5010 as of January 1, 2012, delays in claim reimbursement may result.

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Don, We Hardly Knew Ya…

As you may recall, the CMS Administrator position has not had a Congressionally confirmed Administrator since Dr. Mark McClellan resigned from the position in 2006. It appears that it may be some time before that string is broken.

Last Spring, President Obama announced that he intended to nominate Dr. Donald Berwick to be Administrator of the Centers for Medicare and Medicaid. Dr. Berwick’s nomination quickly became controversial because of some statements he had made praising the British single-payer healthcare system and his seeming endorsement of the rationing of healthcare. Although the most vocal critics of Dr. Berwick were Republican Senators, the dearth of Democratic Senators rushing to his defense raised more than a few eyebrows.

The President, sensing that there might be trouble with the nomination, announced in July 2010 that he was making a “recess” appointment of Dr. Berwick to the CMS Administrator position. He would not be “acting” as had his predecessors since McClellan, but his appointment would not be “at the pleasure of the President” either.

Recess appointments are not unusual and have been used by Presidents from both parties.

However, they often come at a steep political price.

The U.S. Senate is very protective of its constitutionally established power of “Advice and Consent” on Presidential Appointments. This is true whether it is a Supreme Court Justice, Cabinet Official or the Administrator of CMS. The Senate generally does not react well when a President circumvents the confirmation process, even when the Senate is controlled by members of the President’s party.

Under the Constitution, the President can temporarily appoint someone to a position requiring Senate confirmation if the Senate is adjourned at the time the President makes the appointment. The person appointed to the position can serve, unconfirmed, until the end of the next session of Congress. Given that the Berwick appointment occurred in July 2010 (i.e. the 2nd session of the 111th Congress), this means that Dr. Berwick can

serve until the end of the 1st Session of the 112th Congress. If Dr. Berwick is not confirmed by the end of this Session of Congress (likely to occur sometime around Thanksgiving or early December 2011), then he must vacate the Administrator position.

It now appears very likely that Dr. Berwick will be unable to secure sufficient votes to be confirmed by the U.S. Senate. In fact, the Chairman of the Senate Finance Committee, Senator Max Baucus (D-MT), has announced that does not even plan to hold a confirmation hearing on the Berwick nomination. In a recent statement released by his office, Senator Baucus said, the “votes aren’t there” to confirm Berwick as Medicare Administrator.

While Baucus could have easily blamed the impasse on the threat by 42 GOP Senators to filibuster the Berwick nomination, the fact that he won’t even hold hearings (which are not subject to a filibuster) suggests that Berwick may not even have the votes to get out of Committee.

All indications are that Dr. Berwick will serve as long as he is legally allowed to occupy the CMS Administrator position. It is possible that upon vacating the Administrator’s office, the President could appoint Dr. Berwick to a position in his Administration that does not require Senate confirmation.

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Wave If You Got a Waiver

The Patient Protection and Affordable Care Act allows employers and Unions to apply for a waiver from some of the new mandates imposed by the new law. For example, the legislation imposes new limits on “lifetime limit” in insurance policies.

According to the HHS website, the number of schools, businesses and unions that have applied for and received a waiver is approaching 1,000. Although some reports have put the number at more than 1,000 waivers requested and issued, we have only been able to confirm 740 waivers.

The Patient Protection and Affordable Care Act imposes new annual coverage limits on all insurance policies. These new limits began on January 1, 2011. For 2011, most plans can impose an annual limit of no less than $750,000. Many employers and unions realized that in order to meet this new limit, huge increases in premiums would have had to occur resulting in many people dropping their health insurance coverage.

Rather than see press reports indicating that people were actually losing health insurance coverage as a result of enactment of the PPACA, the Administration has taken to issuing hundreds and hundreds of waivers. According to the HHS website, these waivers apply to insurance policies covering more than 2 million people. As might be expected, GOP lawmakers have seized on the waivers as prima fascia evidence that the PPACA is flawed and must be repealed. The President and other supporters of the PPACA have rejected this conclusion. Although the Administration has approved most of the waiver requests, some have been rejected because the applicant failed to demonstrate that compliance with the minimum annual limit requirement would significantly increase premiums or decrease access to benefits. Return To Top

Repeal, Replace or Litigate

As has been previously reported, the GOP controlled House has voted to repeal the Patient Protection and Affordable Care Act and the Democratic controlled Senate rejected that legislation.

Subsequent to those votes, the House also included language in an appropriations bill, H.R. 1, that would eliminate all federal funding to carry out the federal requirements included in the Patient Protection and Affordable Care Act. This vote was largely a straight party-line vote although some Democrats did vote in favor of the amendment when it was considered on the House floor.

As expected, the Senate rejected this PPACA defunding initiative along with billions of dollars in other spending cuts approved by the House (see story above).

In February, the Justice Department sought clarification of a decision by Federal District Court Judge Roger Vinson of his ruling that the PPACA was unconstitutional – the entire law.

There appeared to be some question as to the immediate impact of Judge Vinson’s ruling. Did it require the suspension of all activities associated with the law or could the Administration proceed ahead with the writing of rules and regulations pending appeal?

District Court rulings are only binding on the parties involved in the suit. In this particular case, 26 states joined Florida in bringing suit meaning that Judge Vinson’s ruling was applicable in those 27 states. Presumably the law –

at least until there’s a ruling from the Supreme Court, is constitution in the other 23 states and the District of Columbia.

The Justice Department wanted to know if HHS could proceed ahead with the writing of rules regulations and standards, etc. or must it cease and cease and desist all actions until the case was resolved by the Supreme Court? The fact that the Administration had not yet filed an appeal of Judge Vinson’s ruling was partially responsible for the confusion.

In early March, Judge Vinson “clarified” his ruling stating that despite his finding that the law was unconstitutional, it did not prevent the Obama Administration from writing rules. He effectively granted the Administration a “stay” of enforcement. However, in a significant addition to the ruling, the Judge said that his “stay” would only be granted IF the Administration asked the Appellate court for expedited review of its appeal.

As noted above, the Administration had yet to file an appeal challenging Judge Vinson’s ruling and there was some speculation that the Administration was dragging its feet in order to delay the case going to the Supreme Court.

Within a week of Judge Vinson’s ruling, the Obama Administration did in fact request that the Appeals Court in Atlanta expedite its review of the Vinson ruling. Although this does not assure a prompt court review of the case, it can significantly decrease the amount of time it will take to get this case before the Supreme Court where, all parties agree, this will ultimately be resolved.

In the meantime, Congress will continue to review the new law and the GOP lead House will hold numerous oversight hearings looking into the Administrations actions implementing the new law.

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Who Are These People – a Series

After a while, we get to know their names and faces. People who six months before we’ve never heard of, suddenly are on the Sunday talk show circuit telling us what they think might happen in Congress. And even when we don’t know their names or their faces, we know they must be important because they have a title under their names that means they are more than just a Senator or more than just a Representative.

They’re called, Mr. Speaker or the Majority Leader or the House Whip. But thinking back to your days in High School civics, do you even remember what their role is in the legislative process and just why they are important?

Over the next few months, I will include a short piece on the roles and responsibilities of the various Congressional Leadership positions. What’s ceremonial and who has the real power. What does it mean to be President Pro Tempore or “Dean” of the House. Is the Whip’s job anything like what it sounds?

The Speaker

The Speaker of the House is the presiding officer in the House of Representatives. He or She stands 2nd in line to the Presidency after the Vice President. Although the Constitution does not require the Speaker to be a Member in the House of Representatives, we’ve never had a non-Member elected as Speaker. Technically the Speaker is expected to transcend party politics but practically speaking the Speaker is the leader of his/her party in the House.

The Speaker is the only leadership position voted upon by the entire body. Anyone can be nominated for Speaker but typically each of the Parties (Democrat and Republican) nominates a candidate for the position. The election of the individual nominated by the Majority Party is virtually assured of election as Speaker but there have been instances of individual Members of Congress casting protest votes against their party’s nominee. When an individual votes against his or her party’s nominee for Speaker (or simply votes “present’) there are often political consequences to such actions.

The Speaker largely controls committee assignments for the majority party and typically determines who will be the Committee Chairs during the ensuing Congress. Therefore, failure to support your party’s nominee for Speaker can (and often does) result in loss of a coveted Committee assignment or being passed over for appointment as a Committee of Subcommittee Chair or Ranking Minority Member.

In recent history, Speakers have often refrained from voting on legislation before the House, and the Speaker does not serve on any House Committees. It is also uncommon for the Speaker to debate legislation on the floor although for major pieces of legislation, the Speaker will often have the closing word on the debate just prior to a vote. But, the Speaker controls the House agenda and no legislation comes before the House without the Speaker’s approval.

Rarely does the Speaker actually preside over the House. So even though Members direct their remarks to the Speaker, the actual person in the Speaker’s chair is someone the Speaker has designated as “Speaker Pro Tem”. The Speaker (or his/her surrogate) controls the flow of debate in the House and rules on various parliamentary questions that may arise during debate.

In our nation’s more than 200 year history, we have had 61 House Speakers. The Party breakdown is as follows:

25 Democrats17 Republicans 9 Democrat/Republicans (they couldn’t make up their minds) 7 Other (Whigs, Know Nothings, Pro-Administration, Anti-Administration and Federalist)

Next Up: Majority Leader – House and Senate

1099 Repeal on the Horizon?

Both the House and Senate have taken steps to repeal the 1099 reporting requirement included in the Patient Protection and Affordable Care Act. Unfortunately, they have not included the legislation in the same bill. The House overwhelmingly adopted a stand-alone bill to repeal the 1099 reporting provision. The Senate overwhelmingly passed similar language but rather than simply passing the House passed bill so it could go immediately to the President for his signature, the Senate included the repeal language on an unrelated bill dealing with the reauthorization of the Federal Aviation Administration.

The House appears unlikely to consider the FAA reauthorization bill anytime soon so the repeal effort has stalled. If visions of Nero fiddling with Rome burning in the background are dancing in your head as you read this article, do not panic, you are perfectly normal. The people who are responsible for this impasse, however, are another matter.

The business community remains confident that Congress will repeal the 1099 reporting provision. When exactly that will occur and the vehicle by which that will occur are not clear, but there is widespread support for repealing the 1099 reporting requirement.

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CMS Transmittals

CMS uses transmittals to communicate new or changed policies or procedures that will be incorporated into the CMS Online Manual System. The following Transmittals have been issued within the last 30 days.

Transmittal #: Subject: Effective Date:

R369PIAdvanced Diagnostic Imaging Accreditation Enrollment Procedures 6/12/2011

R2172CPApril 2011 Integrated Outpatient Code Editor (I/OCE) Specifications Version 12.1 4/4/2011

R3SBI Summary Accounting Statement - Exhibit 1/1/2011

R868OTNJuly Common Edits and Enhancements Module (CEM) and Receipt, Control, and Balancing Updates 7/5/2011

R132NCD

Magnetic Resonance Imaging (MRI) in Medicare Beneficiaries with Implanted Permanent Pacemakers (PMs) or Implantable Cardioverter Defibrillators (ICDs) 4/4/2011

R2171CP

Magnetic Resonance Imaging (MRI) in Medicare Beneficiaries with Implanted Permanent Pacemakers (PMs) or Implantable Cardioverter Defibrillators (ICDs) 4/4/2011

R866OTNReporting of Recoupment for Overpayment on the Remittance Advice (RA) N/A

R867OTN

Analyze, Design, Maintain and Provide Implementation Instructions for a Modification of the Part A and Part B Common Edits and Enhancement Modules (CEMs), to allow 277C Edits to be Turned On/Off by the Encounter Data Front-End System (EDFES) Contractor Only 7/5/2011

R185FMModify CROWD Form K to allow for the submission of additional Medicare Secondary Payer (MSP) savings information. 10/3/2011

R865OTN

Guidance on Implementing System Edits for Certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) N/A

R2169CP

Incentive Payment Program for Primary Care Services, Section 5501(a) of the Patient Protection and Afforable Care Act (the ACA), Payment to a CAH Paid Under the Optional Method 4/4/2011

R141BPNew Hospice Certification Requirements and Revised Conditions of Participation (CoPs) 3/23/2011

R864OTN

Waiver of Coinsurance and Deductible for Preventive Services, Section 4104 of the Patient Protection and Affordable Health Care Act (the Affordable Care Act), Removal of Barriers to Preventive Services in Medicare 1/3/2011

R140BP Expansion of Medicare Telehealth Services for CY 2011 N/A

R2168CP Expansion of Medicare Telehealth Services for CY 2011 N/A

R23P236

This transmittal updates Chapter 36, Hospital and Hospital Health Care Complex Cost Report, (Form CMS-2552-96). Reflects further clarification to existing instructions and incorporates select Federal Register provisions. N/A

R2166CPClarification to CR 6686 - Outpatient Mental Health Treatment Limitation 3/25/2011

R2167CPApril Update to the CY 2011 Medicare Physician Fee Schedule Database (MPFSDB) 4/4/2011

R2164CP Healthcare Provider Taxonomy Codes (HPTC) Update April 2011 7/5/2011

R367PIUse of Claims History Information in Claim Payment Determinations 3/25/2011

R2165CPUpdate for Pub. 100-04, Medicare Claims Processing Manual, Chapter 31 3/25/2011

R2161CPIncentive Payment Program for Primary Care Services, Section 5501(a) of the ACA N/A

R184FM Recovery Audit Program Underpayments Instruction Alteration 3/28/2011

R2163CP Screening for the Human Immunodeficiency Virus (HIV) Infection 7/6/2010

R131NCD Screening for the Human Immunodeficiency Virus (HIV) Infection 7/6/2010

R2162CP

Updates to the Internet Only Manual Pub. 100-04, Chapter 1 - General Billing Requirements, Chapter 15 - Ambulance, and Chapter 26 - Completing and Processing Form CMS-1500 Data Set 3/21/2011

R2160CP Correction to Manual References in Chapter 5, Section 20.2 5/19/2011

R863OTN

Integrated Data Repository (IDR) Claims Sourcing from Shared System Implementation Based on Further Conference Calls and Further Research 4/4/2011

R79MSPUpdates to the Electronic Correspondence Referral System (ECRS) Web User Guide v1.0 and Quick Reference Card v1.0 3/1/2011

R862OTNAnalysis and Design for Additional Fields for Additional Documentation Request (ADR) Letters for CR7254 7/5/2011

R861OTNCommon Working File (CWF) Requires More Space for the Health Insurance Master Record (HIMR) Auxiliary File Menu 7/5/2011

R139BPClarifications for Home Health Face-to-Face Encounter Provisions 3/10/2011

R2159CPAnnual Wellness Visit (AWV), Including Personalized Prevention Plan Services (PPPS) 4/4/2011

R138BPAnnual Wellness Visit (AWV), Including Personalized Prevention Plan Services (PPPS) 4/4/2011