1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS,...

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1 Safeguarding Your Medicare Progra Safeguarding Your Medicare Progra Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting Manager Plante & Moran, PLLC

Transcript of 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS,...

Page 1: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Safeguarding Your Medicare ProgramSafeguarding Your Medicare ProgramSession F-1

October 7, 20072:00 – 4:00 PM

Jane C. Belt, MS, RN, Consulting ManagerBetsy V. Rust, CPA, Consulting Manager

Plante & Moran, PLLC

Page 2: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Session ObjectivesSession Objectives Identify MDS assessment issues affecting

length of stay and RUG determination Review documentation requirements and

guidance in responding to Fiscal Intermediary (FI) Additional Documentation Requests (ADR)

Learn tools and metrics that can assist in evaluating your facility’s Medicare operations

Identify strategies for improving Medicare financial results

Considerations in ancillary service contracting and provider liability for consolidated billing

Page 3: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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The Compelling Case for The Compelling Case for Medicare….Medicare….

Medicare operations typically generate per diem revenue in excess of operating expense

Higher operating margins than other payors and decreased reliance on Medicaid

Greater flexibility than other payors Census building opportunity (attract

private pay)

Page 4: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Average Financial Results – Average Financial Results – Medicare OperationsMedicare Operations

Ohio Average *

Part A Revenue $346

Expense $286

Profit (Loss) $ 60

* Based on 366 Ohio Cost Reports from 2004 and 2005

Results in other Midwest States range from$50 to $75 per patient day

Page 5: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Medicare UtilizationMedicare Utilization

Ohio 14% Indiana 13% Illinois 12% Kentucky 13% Michigan 15%

Ohio Rehab 87% National Rehab 83%

Page 6: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Pre-AdmissionsAdmissions

ResidentAssessments

Care PlanningDelivery, and

OutcomesDocumentation

AncillaryUtilization and

Efficiency

Cost Control

Marketing

Medicare Operations

Elements of a Strong Medicare ProgramElements of a Strong Medicare ProgramMetrics for Evaluation

Metrics forEvaluation

Metrics forEvaluation

Page 7: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Marketing is CriticalMarketing is Critical Target Audiences

Hospitals and Discharge Planners Physician Specialty Groups Consumers and their families

Marketing Strategies Facility Open House Print collateral materials Internet Other multimedia

Post Discharge Follow-up

Page 8: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Pre-Admission and AdmissionsPre-Admission and Admissions Admission Staff are critical to

establishing and cultivating referral relationships

Utilize technology where possible Accept admissions 24 hours a day

and 7 days a week Utilize a pre-admission screening

tool to identify coverage, skilling services, probable RUG group, length of stay, cost issues

Page 9: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Metrics for Evaluating AdmissionsMetrics for Evaluating Admissions Number of admission inquiries Number of admissions

By referral source By payor type

Number of patients declined Census by payor type Average length of stay Competitor utilization

Page 10: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Resident AssessmentsResident Assessments Minimum Data Set (MDS) is the most

important cog in the Medicare wheel Drives resident care planning Influences regulatory process and oversight Determines revenue rate (RUG) for care

delivered It is essential that all members of the

interdisciplinary team have adequate training and expertise in the MDS process

Page 11: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Medicare – Pre PPSMedicare – Pre PPS

Financial Silo Regulatory Silo

Little integration between Clinical and Financial Operations

Page 12: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Financial Success Under Medicare Financial Success Under Medicare – The Olden Days– The Olden Days

• Maintain distinct part• Accountant utilizes cost

allocation methodology to maximize reimbursement.

• Spend up to limits on routine

The Controller is the Man!

Page 13: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Financial Success Under Medicare Financial Success Under Medicare – PPS Environment– PPS Environment

• Accurately capture assistance with ADLS, mood, services

• Monitor ancillary utilization and efficiency

• Selection of Assessment Reference Date

Nurses Rule – Accountants Drool!

Page 14: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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The facility ADLscore has reallyimproved!

The averageMedicarerate has increased!

The team must be talking the same language

Creating a Winning Medicare ProgramCreating a Winning Medicare Program

MDS MDS

Page 15: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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The MDS Language of The MDS Language of Medicare OperationsMedicare Operations

Assessment Reference Date

Nursing case mix index

Activities of Daily Living (ADL)

Therapy services (rehabilitation) index

Therapy efficiency

Page 16: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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NursinNursing Case g Case

MixMix

NursinNursing Case g Case

MixMix

Rehab Rehab Case Case MixMix

Rehab Rehab Case Case MixMix

Primary

Diagnosis

Primary

Diagnosis ADL

Score

ADL Score

Extensive

Services prior 7 or 14 Days

Extensive

Services prior 7 or 14 Days

Therapy Minutes

Estimated or

Delivered

Therapy Minutes

Estimated or

Delivered

Selection of Selection of Assessment Assessment

Reference DateReference Date

Selection of Selection of Assessment Assessment

Reference DateReference Date

Mood and

Behavior

Mood and

Behavior

Factors Influencing RUG RateFactors Influencing RUG Rate

Page 17: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

FEDERAL CASE MIX INDICES - TOP 35 CATEGORIES

January 2006Rehab Nursing

RUG III RUG III Case Mix Case MixCategory Code Index ADLS Index

RUX 2.25 16-18 1.90 RUL 2.25 7-15 1.40

ULTRA RUC 2.25 16-18 1.28RUB 2.25 9-15 0.99RUA 2.25 4-8 0.84RVX 1.41 16-18 1.54 RVL 1.41 7-15 1.33

VERY HIGH RVC 1.41 16-18 1.23RVB 1.41 9-15 1.09RVA 1.41 4-8 0.82RHX 0.94 13-18 1.42 RHL 0.94 7-12 1.37

HIGH RHC 0.94 13-18 1.22RHB 0.94 8-12 1.11RHA 0.94 4-7 0.94RMX 0.77 15-18 1.93 RML 0.77 7-14 1.68

MEDIUM RMC 0.77 15-18 1.15RMB 0.77 8-14 1.09RMA 0.77 4-7 1.04RLX 0.43 7-18 1.31

LOW RLB 0.43 14-18 1.14RLA 0.43 4-13 0.85

EXTENSIVE SE3 0.00 1.86CARE SE2 0.00 1.49

SE1 0.00 1.26SPECIAL SSC 0.00 1.23CARE SSB 0.00 1.13

SSA 0.00 1.10CC2 0.00 1.22CC1 0.00 1.06

CLINICALLY CB2 0.00 0.98COMPLEX CB1 0.00 0.91

CA2 0.00 0.90CA1 0.00 0.80

What’s casemix index?

Separateindex for

Nursing andRehab

Page 18: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

FEDERAL CASE MIX INDICES - Bottom 18 CategoriesJanuary 2006

Rehab NursingRUG III RUG III Case Mix Case MixCategory Code Index ADLS Index

IB2 0.00 0.74IMPAIRED IB1 0.00 0.72COGNITION IA2 0.00 0.61

IA1 0.00 0.56BB2 0.00 0.73

BEHAVIOR BB1 0.00 0.69PROBLEMS BA2 0.00 0.60

BA1 0.00 0.52PE2 0.00 0.85PE1 0.00 0.82

PHYSICAL PD2 0.00 0.78REDUCED PD1 0.00 0.76FUNCTIONS PC2 0.00 0.71

PC1 0.00 0.69PB2 0.00 0.55PB1 0.00 0.54PA2 0.00 0.53PA1 0.00 0.50Default 0.00

No Rehabindex fornon therapycategories

Low NursingCase Mix

Page 19: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

IndexPatient Days

Product of Index and

DaysRUX 2.25 125 281.25RUL 2.25 62 139.50RUC 2.25 250 562.50RUB 2.25 36 81.00RUA 2.25 123 276.75RVX 1.41 500 705.00RVL 1.41 85 119.85RVC 1.41 251 353.91RVB 1.41 0 0.00RVA 1.41 55 77.55RHX 0.94 1005 944.70RHL 0.94 213 200.22RHC 0.94 158 148.52RHB 0.94 697 655.18RHA 0.94 521 489.74RMX 0.77 66 50.82RML 0.77 85 65.45RMC 0.77 125 96.25RMB 0.77 150 115.50RMA 0.77 98 75.46RLX 0.43 479 205.97RLB 0.43 15 6.45RLA 0.43 30 12.90

5129 5664.471.10

Calculation of Therapy Services IndexCalculation of Therapy Services Index

Allows you tomeasure rehab

volume with one metric

Calculateusing

therapydays only

Index of 1.10Mostly High

Monitor facility trend and comparison to State andNational averages

Page 20: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

Calculation of Nursing Case Mix IndexCalculation of Nursing Case Mix IndexCase Mix

Patient Days

Product of Index and Days

RUX 1.90 125 237.50RUL 1.40 62 86.80RVX 1.54 250 385.00RVL 1.33 36 47.88RHX 1.42 123 174.66RHL 1.37 500 685.00RMX 1.93 85 164.05RML 1.68 251 421.68RLX 1.31 0 0.00RUC 1.28 55 70.40RUB 0.99 1005 994.95RUA 0.84 213 178.92RVC 1.23 158 194.34RVB 1.09 697 759.73RVA 0.82 521 427.22RHC 1.22 66 80.52RHB 1.11 85 94.35RHA 0.94 125 117.50RMC 1.15 150 172.50RMB 1.09 98 106.82RMA 1.04 479 498.16RLB 1.14 15 17.10RLA 0.85 30 25.50SE3 1.86 500 930.00SE2 1.49 262 390.38SE1 1.26 310 390.60SSC 1.23 55 67.65SSB 1.13 46 51.98SSA 1.10 11 12.10CC2 1.22 22 26.84CC1 1.06 113 119.78CB2 0.98 2 1.96CB1 0.91 264 240.24CA2 0.90 0 0.00CA1 0.80 0 0.00IB2 0.74 0.00IB1 0.72 0.00IA2 0.61 0.00IA1 0.56 0.00BB2 0.73 35 25.55BB1 0.69 0.00BA2 0.60 0.00BA1 0.52 0.00PE2 0.85 0.00PE1 0.82 0.00PD2 0.78 10 7.80PD1 0.76 0.00PC2 0.71 0.00PC1 0.69 0.00PB2 0.55 0.00PB1 0.54 0.00PA2 0.53 0.00PA1 0.50 0.00

6759.00 8205.461.21

Allows facility tomeasure nursing acuity with one metric

Calculatewith all

days

MonitorTrends

Page 21: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Nursing Case Mix IndexNursing Case Mix Index Monitor trends in the index

Are the trends consistent with resident population?

Do they indicate a need for modification to staffing levels or education?

How does the trend in the index compare to trends in operating costs?

National Average – 1.28

Page 22: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Therapy Case Mix IndexTherapy Case Mix Index

Monitor trends in the index Are trends consistent with resident

population? Why the increase or decrease in services? Does the index trend compare to the trend

in operating costs? How does the trend in therapy CMI

compare to the trend in therapy efficiency? National Average 1.27

Page 23: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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What is an ADL Score?What is an ADL Score? I have no idea but I hopeIt’s a big number. I hear that the higher the ADL, the more the RUG rate….

Measures maximum assistance given by nursing staff over the last 7 days across all shifts.

My staff are experts in capturing this….

Page 24: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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ADL Score and Impact on ADL Score and Impact on Reimbursement - Less is NOT MoreReimbursement - Less is NOT More

The ADL score can be as low as 4 and as high as 18

The lower the score the less assistance the resident needs from staff, the higher the score, the more dependent the resident is on staff and the more Medicare will reimburse the facility for the care and services rendered

Page 25: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

ADL Score and Impact on ADL Score and Impact on Reimbursement - Less is NOT MoreReimbursement - Less is NOT More ADL score is 30% of

each RUG rate The ADL score is the

sum of: Bed mobility Transfer Eating Toilet use

These ADLs are items in section G of the MDS

Page 26: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Know the ADL DefinitionsKnow the ADL Definitions (MDS)(MDS) INDEPENDENT (0) = no help from staff SUPERVISION (1) = staff uses eye and mouth

– no hands LIMITED ASSISTANCE (2) = staff uses hands

to guide, but not bearing any weight of the resident

EXTENSIVE ASSISTANCE (3) = staff uses hands and IS bearing some/any of resident’s weight OR staff fully performed some part of the task

TOTAL DEPENDENCE (4) = staff performs entire task each and every time

Page 27: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Know the ADL DefinitionsKnow the ADL Definitions

MDS Therapy

Independent Independent

Supervision Stand By Assist

Limited Assistance Contact Guard

Extensive Assistance

Min Mod Max

Assist

Total Dependence Dependent

Page 28: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

RUGs III ADL IndexRUGs III ADL IndexSum the scores for four ADL variables

(index ranges from 4 to 18)

Self-Performance for BED MOBILITY, TOILET USE, TRANSFERS

SCORE

Independent (MDS = 0) or

Supervision (MDS = 1)1

Limited Assistance (MDS = 2) 3Extensive Assistance (MDS = 3), Total Dependence (MDS = 4) or Activity Did Not Occur (MDS = 8)

Support: 1 person assist or less (MDS = 2) 4Support: 2 person assist or more or activity did not occur (MDS = 3)

5

Page 29: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

RUGs III ADL IndexRUGs III ADL IndexEATING SCORE

Independent (MDS = 0) or

Supervision (MDS = 1)1

Limited Assistance (MDS = 2) 2

Extensive Assistance (MDS = 3),

Total Dependence (MDS = 4) or

Activity did not occur (MDS = 8)

3

Includes Feeding Tubes/Parental Feeding with 51% calories or 26% calories and 501 cc per day of fluid

Page 30: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

ALLEY, KIRSTIALLEY, KIRSTISection G.1 Self-

PerformanceSupport Score

a Bed Mobility

2 2 3

b Transfer 2 2 +3

i Toilet Use

2 2 +3

h Eating 0 1 +1

Total ADL Score 10

Page 31: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

HARTMAN, LISAHARTMAN, LISASection G.1 Self-

PerformanceSupport Score

a Bed Mobility

4 3 5

b Transfer 3 3 +5

i Toilet Use

4 2 +4

h Eating 3 2 +3

Total ADL Score 17

Page 32: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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ADL ScoresADL ScoresBed mobility, transfer, toilet use and eatingBed mobility, transfer, toilet use and eating

Medicare average? Goal = 13.24

Medicaid average? Goal = 12

What percent independent (4-6 ADL score)? Goal = < 20% Medicaid

< 10% Medicare Establish your benchmarks and monitor

changes to identify need for staff education and training

Page 33: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Impact of Understating of ADLsImpact of Understating of ADLsWhat Is One Point Worth?What Is One Point Worth?

$605.49

$531.74

$73.75 x 14 days = $1,032.50

RUX 16 - 18

RUL 7 - 15

Medicare Rates for Urban (Columbus, OH) – 10/1/07

Page 34: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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How Much is 1 ADL Point Worth?How Much is 1 ADL Point Worth?

Ext + Very High Rehab

ADL Index = 7

RUG Category = RVL

Rate = $428.09

However, if someone under codes bed mobility by 1 point (2 instead of 3), then:

ADL Index = 6

RUG Category = RVA

Rate - $352.87

Difference = $75.22 per day ($1,053.08 - 14)

Page 35: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Monitoring ADL ScoresMonitoring ADL Scores Trend for facility Comparison to statewide and

national averages – 13.24 Scrutiny of residents within one ADL

point of next category to ensure accuracy

Scrutiny of residents with ADL scores <7 Inability to capture new RUGs

groups High level of independence

Page 36: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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ABC Nursing Home

Page 37: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Monitoring ADLsMonitoring ADLs• 1 NA watches for

transfer – staff NWB• 1 NA touches for

toilet use – staff NWB• Part of toilet use is

transfer• Needs >500 min of

PT and OT

1 NA for bed mobility

2 NAs for transfer

Page 38: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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ARD Selection (A3 on MDS)ARD Selection (A3 on MDS) Assessment Reference Date

Determines the observation period – the look-back date for answering all items on the MDS

MDS sections have a 7, 14, 30 or 90 day “look-back” period or “window”

Determines RUG classification

Page 39: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Accuracy is EssentialAccuracy is Essential

Who sets ARD?

Administrator, DON, ADON, Business Office Manager, SSD, MDS, Director of Rehab, Activities, Dietary

Page 40: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Why is the ARD so Important?Why is the ARD so Important?Rate Variance ExampleRate Variance Example High acuity resident meets the criteria of

several RUG III categories: Rehab, Extensive Services, Special Care, Clinically Complex

Rehab orders: day 1 evaluation; treatment begins on day 2 (<65 minutes)

Day 3 begins schedule that allows for 500 minutes

ADL index is 13

Page 41: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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All Dates are NOT Created EqualAll Dates are NOT Created Equal

Same resident, same care, same rehab, same cost of care BUT…very different reimbursement based on accurate ADL,

clinical indicators, and ARD$19.48 per day x 14 days = $272.72

ARD = Day 2 ARD = Day 3 ARD = Day 7

Cat CMI Rate Cat CMI Rate Cat CMI Rate

RML 44 $408.61 RML 44 $408.61 RVL 46 $428.09

RMB 35 $321.60 RMC 36 $330.44 RVB 43 $392.70

SE3 40 $364.24 SE3 40 $364.24 SE2 31 $309.67

Page 42: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Therapy ServicesTherapy Services

720 = Ultra High500 = Very High325 = High150 = Medium 45 = Low

Revenuerate based

on ranges of minutesusing thresholds

Cost based on method to deliver

direct care andindirect cost

Page 43: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Therapy ServicesTherapy ServicesIf the World were Perfect….If the World were Perfect….

Resident would always need therapy exactly at threshold

Facility would get paid RUG rate for exact amount of therapy services rendered

Facility would pay contractor or staff for exact amount of therapy services

Page 44: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Therapy RealityTherapy Reality

Resident needs vary Therapy services can be

provided to residents under arrangement or by employees

Providers need to monitor revenue and expense implications of resident care decisions

Page 45: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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In House Employee

% of Therapy

RUG

Hourly

Rate

Incentive for Over Utilization

Maybe No Yes

Incentive for Under Utilization

Maybe Yes No

Need Mechanism to Monitor

Yes Yes Yes

Therapy Service OptionsTherapy Service Options

Page 46: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Monitoring Therapy ServicesMonitoring Therapy Services What is the volume of services rendered

to residents in general?

How many minutes over threshold are we treating in the facility? Trends?

Are we treating many residents at threshold? Trends?

Page 47: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Monitoring Therapy ServicesMonitoring Therapy Services Are we treating significantly over

threshold?

Are we close to the next category based on minutes or days?

Are we accurately capturing residents that meet the requirements for the combination categories?

Page 48: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Monitoring Therapy EfficiencyMonitoring Therapy Efficiency

Overall looks good

But many MDSs with significant treatment over threshold and

many that were close to the next

category

Page 49: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

Monitoring Therapy Utilization by ResidentMonitoring Therapy Utilization by Resident

Page 50: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Monitoring Therapy Utilization by Monitoring Therapy Utilization by ResidentResident

Page 51: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Medicare Resident Profile Medicare Resident Profile ComparisonComparison

Page 52: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Medicare Rehab ProfileMedicare Rehab Profile

Page 53: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Concentration of RUGs GroupsConcentration of RUGs Groups

Page 54: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Integrity of DocumentationIntegrity of Documentation

Documentation

Level of Care

UB-04

Clinical notes and documentation

support the need for skilled level of care in SNF which supports the “bill” to Medicare

All three components must agree!

Page 55: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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CMS Medicare Medical Review CMS Medicare Medical Review Safeguard ProgramSafeguard Program

Payment Safeguard Review Transmittal A-00-08 (3/2000) Random Post Pay – purpose is to obtain a

cross sectional overview of trends in beneficiary care and utilization under PPS – ADRs (Additional Documentation Requests)

Focused Medical Review – for identified aberrant providers – must be done on post payment basis

Page 56: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Payment Safeguard ReviewPayment Safeguard Review

Bill Review Process Request records Make a coverage determination

Level of Care requirement must be met

Services are not statutorily excluded Services are reasonable and

necessary

Page 57: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Payment Safeguard ReviewPayment Safeguard Review

Bill Review Outcomes

Beneficiary falls to non-skilled level of care – deny coverage effective date skilled coverage criteria no longer met

Services furnished not reasonable and necessary and/or no skilled care needed or provided – deny in full

Page 58: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Responding to an ADRResponding to an ADR Begin collecting information immediately

Follow Fiscal Intermediary checklist Nurse’s Notes Physician Progress Notes/Consultation

Reports Labs/Diagnostic Reports Physician Orders Therapy evals and progress notes MDSs History and Physical Other relevant documentation to

demonstrate skilled services (i.e., MARs, TARs, Dietary, Social Services)

Page 59: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Responding to an ADRResponding to an ADR Send only documentation to support claim

identified in ADR May need to include prior

documentation to support MDS coding

May need to include prior documentation to support resident’s clinical needs (History & Physical, Discharge Summary)

Page 60: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Responding to an ADRResponding to an ADR Review medical record prior to sending to FI

Is all requested information included? MDS coded accurately? MDS supportive documentation included? Documentation supports daily skilled

services? Certs/Recerts completed? Or

documentation contains required information?

Orders signed/dated? Claim billed correctly?

Page 61: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Medicare Operations Medicare Operations Measuring Success Measuring Success Resident Resident CareCare Patient/resident satisfaction surveys Resident functional improvements Clinical Quality Indicators/Measures Survey outcomes Discharge dispositions for residents Readmission rates to acute care

Page 62: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Analyzing the Cost of Medicare Analyzing the Cost of Medicare OperationsOperations

Focus on Big Ticket ItemsFocus on Big Ticket Items

Dietary

Ancillary Capital

Therapy Pharmacy OtherStaffing

Routine

Page 63: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

Medicare Part A Cost Per Day AnalysisMedicare Part A Cost Per Day Analysis

Page 64: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

Analysis Analysis (continued)(continued)

Page 65: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Linking Cost and Clinical DataLinking Cost and Clinical Data Track and trend to help identify

opportunities for cost reduction Staffing hours ppd and case mix

index and ADL score Pharmacy cost ppd and QI/QM for

“Nine or More Meds” Diagnostics, supplies and percentage

of residents in non-rehab categories

Page 66: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Consolidated Billing IssuesConsolidated Billing Issues Coverage:

What is the SNF responsible for?

Contracts: Is your SNF protected through contracts

with ancillary providers?

Claims: How should your SNF review claims from

ancillary providers?

Page 67: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Objectives of Consolidated BillingObjectives of Consolidated Billing

Bundle Part A Services into one all inclusive payment rate

Enact upon SNF full responsibility for supervision of care to all outside vendors

Prevent duplicate payments to providers

Decrease out-of-pocket beneficiary coinsurance and deductible liability

Page 68: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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SNF Responsibilities….SNF Responsibilities…. For any Part A or Part B service subject to

SNF consolidated billing:

SNF must either furnish the service directly with its own resources or obtain the service from an outside entity “under arrangement”

If services provided “under arrangement,” the SNF must reimburse the outside entity for the services subject to consolidated billing

Page 69: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Determining Coverage Determining Coverage General GuidelinesGeneral Guidelines It’s Included unless it’s Excluded!

Exclusions identified by HCPCS codes that should be billed by line item date of service and can be identified in Common Working File (CWF)

Be careful with services that cross midnight and with services that have a professional and technical component

In theory, CB should exclude sophisticated services that are beyond the scope of traditional and customary services of a SNF

Page 70: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Page 71: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

Contract ConsiderationsContract Considerations Initiate contracts with commonly-used providers

like hospitals and labs

Contract Terms should include

Exclusivity, or not

Term and termination

Compensation to provider

Billing and Payment Timeframes and terms

Control of Medicare appeals, if any

Miscellaneous – missed appointments, immediacy

Page 72: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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So You are Liable....How Much to PaySo You are Liable....How Much to Pay??

Charges or Discounts

Medicare’s Fee Screens

Page 73: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Negotiating Payment with ProvidersNegotiating Payment with Providers Consider the value and importance of the

relationship with the provider (is it a significant referring hospital?)

Consider the timeliness of the claim submission to your SNF by the provider

Consider the amount of the claim Don’t be afraid to offer a reasonable

settlement value Identify the appropriate provider

representative with which to offer settlements

Page 74: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Researching Claims…..Researching Claims….. Appoint facility staff to

“champion” process and maintain expertise in researching claims

Analyze each claim on a line item basis

Utilize spreadsheets to facilitate organization and minimize time

Page 75: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

The Devil is in the Detail.......The Devil is in the Detail.......Scrutinize Line Item ChargesScrutinize Line Item ChargesHCPC SNF Help

FileCharge MPFS Payment

BasisQ0081 Inclusion $48.00 Unlisted Contract / Charge

Medical Supplies

Inclusion $247.00 Not DeterminedRequested LIDOS

per Company Policy

86850 Inclusion $34.00 $12.52 MPFS

85065 Exclusion $39.00 Denied

P9016 Inclusion $526.00 Unlisted Contract / Charge

Pharmacy Inclusion $10.00 Not Determined Contract / Charge

99218 Exclusion $540.00 $73.65 Denied

36489 COM $1,106.00 $264.94 $264.94

36430 Inclusion $1,022.00 Unlisted for 2004 Contract / Charge

Detroit Claim from 2005

Page 76: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Consolidated BillingConsolidated BillingMitigating RiskMitigating Risk Educate residents and family

Explain non-coverage of PPS services obtained outside of SNF’s arrangement

Explain SNF’s prerogative to limit and control provision of PPS services, regardless of resident preferences

CMS approves ability of SNF to direct PPS services under proper contractual arrangement

Page 77: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Consolidated BillingConsolidated BillingMitigating Risk ……Mitigating Risk …… Be proactive with ancillary providers

Send cautionary information with residents who go off-site describing CB and preliminary assessment of liability

Respond to payment demands with informational materials on CB

Propose reasonable payment for services rendered

Page 78: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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In Summary……..In Summary……..Safeguarding Medicare OperationsSafeguarding Medicare Operations

Strong marketing and admissions programs

Expertise in MDS assessments at all levels in all disciplines

Continuous monitoring of critical MDS information related to both quality and financial indicators

Page 79: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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In Summary……..In Summary……..Safeguarding Medicare OperationsSafeguarding Medicare Operations

Accurate and compliant documentation of resident care planning and delivery

Diligent cost containment strategies that focus on clinical factors, best practices and operating efficiency

Integrated team approach with continuous training and education for all staff

Page 80: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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For Additional InformationFor Additional Information

Jane Belt, [email protected]

Betsy Rust, [email protected] 248-223-3437

Page 81: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Page 82: 1 Safeguarding Your Medicare Program Session F-1 October 7, 2007 2:00 – 4:00 PM Jane C. Belt, MS, RN, Consulting Manager Betsy V. Rust, CPA, Consulting.

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Thanks for attending today!Enjoy the rest of the convention

Come see us in Booth 733Come see us in Booth 733

Health Information/Technology HallHealth Information/Technology Hall