W-2 Compliance and Credentialing - HCCA Official Site

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Copyright © 2011 Verisys Corporation All Rights Reserved. Confidential and proprietary.Confidential and Proprietary. Not for Distribution.

Verisys Corporation888.837.4797 (888.VERISYS)www.verisys.com

Wednesday, April 13th, 8 – 9:30 a.m.

W-2 Compliance and Credentialing

2Notice and Disclaimer

The presenters prepared these materials for informational purposes only. These materials are not a substitute for, and should not be construed as, legal advice. The presenters do not warrant any statements in these materials.

Employers or any company entering into any employment or contractual relationship should direct questions about federal and state laws regulating the credentialing and/or screening process to experienced legal counsel.

The materials provided herein are not inclusive of every administrative code, regulation, statute or law in any specific jurisdiction within the United States, its Commonwealths, Districts or Territories. Again, please consult experienced legal counsel for the specifics within your jurisdiction(s).

Copyright © 2011 Verisys Corporation. All Rights Reserved.

Confidential and Proprietary. Not for Distribution.

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3Agenda

� Nomenclature

� Credentialing Processes

� Application

� Screening

� In-house Administrative and Clinical

� Monitoring

� Compliance Intersect

� Benefits



4Nomenclature

� Authentication: the process of confirming identity.

� E-Verify and I-9s

� Passports or Perm. Res. Card (List A docs, a single doc that establishes both identity and employment authorization)

� Driver’s license + SSA card or Birth Certificate or (List B docs, two documents, one for identity and one for employment authorization)

� Validation: a declaratory assertion of truth or a period of time something is in a defined state

� Verification: primary source confirmation of the assertion of truth

� Credential: a privilege granted by an authority which presumes competence

� Primary Source: original source or approved agent

� Action Triggers: event based or focus based



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5Credentialing Definition:

� Credentials must be consistent with practice and documented capabilities

� Credentialing and privileging are key checkpoints on the road to quality improvement

� Joint Commission standards incorporate the six core competencies to be addressed in the credentialing process

1. Patient Care: compassionate, appropriate, effective

2. Medical Knowledge: biomedical, clinical, cognate sciences

3. Practice Based Learning and Improvement

4. Interpersonal and Communication Skills: effective information exchange, teaming with patients and families

5. Professionalism: carrying out professional responsibilities, ethics, sensitivity

6. System Based Practice: awareness and responsiveness to larger context and system of health care, use of system resources



6Credentialing Process - Application

� Application Process

� Application

� Attestations

� Authorization(s) for the Release of Records

� Attachments:

1. Copy of the Licenses, Registrations and Certificates2. Curriculum Vitae (CV)3. Explanation of Gaps4. Narcotics Waiver5. State Controlled Substance Certificate6. Reference Letters7. Visa Status (if applicable)

� Screening Process

� Clinical Evaluation

� Monitoring

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7Credentialing Process - Screening

�Application Process

�Screening Process

� Achieving assurance of clinical competence from a “paper”

perspective

�Clinical Evaluation

�Monitoring



8Data



Authentication Data (Name, Address, Social Security Number (SSN) and Date of Birth (DOB))Address HistoryAffiliationsAMA Physician Profile (also available for Physician Assistants)American Board of Medical Specialties (ABMS) (represents 24 member boards)Appointments (academic)Appointments (hospital)Board Certifications, non-ABMSBusiness LicensesCommercial/Business Press ReleasesCorporate FilingsDBAs (“Doing Business As”)DEA – Controlled Substance Act (CSA) Registration +State Controlled Substance Registrations (CSR)ECFMGEducation VerificationEmployment VerificationE-VerifyFederal Civil and Criminal Courts, Including BankruptcyFederation of State Medical Boards (FSMB)Government Press ReleasesJudgments and Liens, including UCC

Malpractice Claim HistoryMedicare/Medicaid Opt-OutMilitary ServiceMotor Vehicle Driving HistoryMotor Vehicle RecordNBME/USMLE (National Board of Medical Examiners)NewsNPDB/HIPDBNPI - National Provider IdentifierOffice of Foreign Assets Control (OFAC), Specially Designated Nationals ListOIG/GSA SanctionsProfessional LicensesSex OffenderState Abuse Registries (patient, elder, nurse, aide, facility)State Civil Court RecordsState Contractor DisqualificationState Criminal Court RecordsState Licensing or Disciplinary Board/Agency SanctionsState Medicaid Exclusions or Office of Medical AssistanceTeaching Title VerificationSSA Death Master FileTraining, Internship, ResidencyUPIN - Unique Physician Identification Number (obsolete, historical)Web Check

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9Credentialing Process - Clinical� Application Process


� Clinical, Big Picture

Primary Goals:

� Clinical competence: well-qualified to perform a specific role based on standards and combined with skill s and behaviors designed to maintain and improve performance.

� Quality health care delivery� Quality outcomes� Compliance with standards for accreditation and certification, usually:

Internal, The Joint Commission, NCQA and URAC

“Determining the competency of practitioners to provide high quality, safe patient care is one of the most difficult decisions an organization can make. The credentialing and privileging process collects, verifies and evaluates data relevant to a practitioner’s performance. These activities serve as the foundation for objective, evidence-based decisions regarding appointment to the medical staff and the granting of privileges.” (The Joint Commission)

� Monitoring



10Credentialing Process – Administrative



� Administrative Clinical (not all-inclusive)� ACLS� Bylaws� Cardiac Life Support (ACLS)� Code of Conduct Policy� Corporate Compliance Policy� HIPAA Acknowledgments (signed)and Privacy and Security Training� Infection Control� Intravenous Conscious Sedation (IVCS)� Medicare Attestations� National Patient Safety Goals� OSHA Regulations� Orientation Form� Orientation Manual� Provider Impairment Course� Point of Care Course� Quality Improvement (QI)� Patient Care Assessment (PCA)� Substance Abuse Testing� Tbc Test

� Monitoring



� Academic recognition of excellence or complaints� Attendance/participation in dept. conferences� Appropriateness analysis (unnecessary surgery, imaging)� Communication assessment � Co-worker or peer recognition of excellence or complaints� Department chairman assessment� Malpractice Claim History (in-facility)� Member Complaints from Health Plans� Multisource (360) evaluation� Observation assessment of a “standardized patient”� Observation of a case and presentation to experts� Outcomes analysis (deaths, complications, readmissions)� Participation, observation and assessment in high fidelity simulation� Patient Appreciation and Complaint Data� Patient/Family recognition of excellence or complaints� Peer review record (e.g. ABIM tool)� Portfolio analysis of outcome data and 360 reviewsfor performance improvement� Process indicators (core measures)� Professional society recognition of excellence or complaints� Reports to Risk Management� Retrospective record review

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11Credentialing Processes – Internal



� In-house Administrative and Clinical� The Joint Commission Credentialing and Privileging Standards MS.4.00-

MS.5.10� The hospital collects information regarding each practitioner’s current

license status, training, experience, competence and ability to perform the requested privilege (MS.4.10).

� The decision to grant or deny privileges or to renew them is an objective, evidence-based process (MS.4.15).

� The medical staff defines the circumstances requiring monitoring and evaluation of a practitioner’s professional practice (MS.4.30).

� The medical staff provides the oversight for the quality of care, treatment and services by recommending members for appointment to the medical staff (MS. 4.60).

� Monitoring



12Credentialing Processes - Monitoring



� In-house Administrative and Clinical

� Monitoring (and re-credentialing)

� Re-credentialing: avoid it at the data level, monitor, instead . . . � Depending on the provider type there are some data sets that are very

easy to monitor1. License

2. DEA/CSR3. Sanctions, Exclusions, Debarments and Discipline

� The not so easy and expensive1. Criminal2. MVR

� Good clinical outcomes analysis programs may obviate the need for re-credentialing in the absence of an “event”.

� Documentation



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13The intersection of compliance:What are some key compliance activities?

� Effective credentials verification

� Employee sanction and license screening and monitoring

� Vendor/supplier/contractor sanction and license screening and

monitoring

� Associate, privileged and admitting provider sanction and license

screening and monitoring

� Referral or contract facility sanction and license screening and

monitoring

� CIA and CCA compliance obligations relative to ineligible persons

or entities

� Contract and enrolment obligations (e.g. ACA 6401 or, for instance, NY or MN provider contacts require monthly checks)



14Why is it critical to protect proactively?

� The government can exclude organizations from participation in all federal and state health care programs (often described as a “death penalty” for participating health care businesses)

� Medicare enrollment and participation requires participating health care business to perform an effective certification screen to avoid “false certification”*

� If a claim is submitted in connection with an ineligible party, the submitting entity may be subject to a Civil Monetary Penalty of $10,000 for each item or service

� An inappropriate claim or a false certification can lead to liability under the False Claims Act carrying penalties as much as $11,000 per claim, plus treble damages

� Employee whistleblowers can be generously compensated in a successful qui tam action

� A false claim or statement can carry criminal penalties, fines and jail time

� All state Medicaid directors need to conduct their own search for ineligible parties, both in- and out-of-state providers monthly, to capture exclusions and reinstatements that have occurred since the last search

http://www.ahcancal.org/advocacy/Letters/CMSStateMedicaidDirectorLetter.pdf



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15What does compliance mean in the health care field?

As a corporate entity, compliance can mean:

� acting in conformity with a set of internal standards set by an entity’s management or corporate governance body; and/or,

� acting in conformity with standards established by a standards setting body (for example, The Joint Commission, NCQA, URAC, ISO); and/or,

� acting in conformity with official guidance or advice as government entities often issue advisory opinions and guidance rather than regulate or legislate (creating a regulation, administrative code, statute or law); and/or,

� acting in conformity with a legal or statutory framework set forth by a governmental authority with the power of enforcement.

Ultimately, compliance is a good faith duty or duty of care to meet standards, guidance, legal and statutory responsibilities and/or adherence to standards of behavior owed to a broad constituency of stakeholders in a given environment or system. In health care, that means everyone from patients to employees to investors to those who provide oversight of our industry.



16Compliance, why all the attention?

Scandal, scandal and more scandal. An egregious lack of corporate responsibility often drives a regulatory initiative. When organizations fail to manage themselves and do not act in a fully transparent manner they elicit an “oversight response.”Examples of scandals that have resulted in a regulatory response (recent to early):� Scandals: Tyco/Enron/Global Crossing/WorldCom - Accounting “Irregularities”

Regulation: Sarbanes-Oxley Act of 2002� Scandal: Caremark – Defrauding Federal Health Care Programs, Home Infusion Medicare

Kickbacks (liability for a lack of compliance program)Legal Standard: See In re: Caremark Intl. Inc. Derivative Litig., 698 A.2d 959 (Del. Ch. Ct. 1996), Establishes a Duty Care for Corporate Compliance

� Scandal: Self-referrals for Clinical Laboratory Services under MedicareRegulation: Stark I (1989)/Stark II (1993) (anti-kickback/self-referral)

� Scandals: $1.8B Medicaid Fraud (early-mid 70’s)Regulation: Health, Education and Welfare Inspector General Act of 1976

Health care is a highly regulated industry and has inherent compliance responsibilities, primarily because:� 1. health care is a trust-based industry where the lives of individuals are at risk; and,� 2. there is a tremendous amount of money involved (17.5% of GDP or $2.6 Trillion in 2010 (est.)):

private spending is approx. 55% and state and federal dollars are 45%.



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17Compliance: what is a duty of care?

Care in decision-making and exercising good due diligence means:

� acting in good faith,

� employing the level of care a prudent person would employ under the same or similar circumstances, and

� doing so while acting in the best interest of the organization.

Obligations are twofold:

� employ good decision-making skills and judgments and

� create oversight ability.

The bottom-line is you may be liable for non-compliance if:

� if you knew something is wrong, but failed to act, or

� if you had suspicions, but did not investigate, or

� if you should have known, but didn’t.

Deliberate ignorance is not a viable defense in the compliance arena.



18What does good compliance look like at thecompany level?

1. There is a defined compliance program in place as part as an overall risk management strategy.

2. The compliance program sets forth clear guidelines, policies and procedures and requires training across the entire organization.

3. The program creates layers of internal accountabilities including a primary officer responsible for compliance as well as a compliance committee.

4. The company provides independence and authority to the compliance function.

5. The company provides adequate resources to the compliance function to perform its duties (next slide).

6. The company provides communication lines, such as “hotlines”, and protects “whistleblowers”.

7. The company discloses and reports violations.

8. The company responds to violations and corrects and modifies controls to prevent future violations.

9. There is ongoing monitoring and assessment of the success of the compliance program.

10. The creation of a corporate culture of compliance.



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19What does good compliance look like as a compliance professional?

1. Develop and execute a code of conduct and policies and procedures to adhere to standards, guidelines and the law.

2 Train and educate others on compliance polices and procedures.

3. Develop and implement controls and monitoring to prevent compliance violations.

4. Develop reporting structures to surface potential compliance violations.

5. Investigates suspected violations.

6. Respond to violations and enforce standards.

7. Report internally and disclose to the appropriate governmental body any violations.



20Are there legal obligations relative to acompliance plan?

Under Medicaid: technically there are no laws requiring a compliance plan.

NEW: Under ACA: under section 6401(a), which established a new section1866(j)(8) of the Act, aprovider of medical or other items or services or a supplier shall, as a condition of enrollment inMedicare, Medicaid or CHIP, establish a compliance program that contains certain ‘‘core elements.’’

But there is also plenty of guidance: OIG “Compliance Program Guidances (CPGs)”

� For hospitals: Initial guidance was issued in 1998 and a supplemental issued in 2005.

� For Individual and Small Group Physician Practices: Issued in 2000.

From the supplemental guidance for Hospitals:

Under the Section of “III. Hospital Compliance Program Effectiveness”, sub-section B. 7. the DHHA OIG clearly states, “Are employees, contractors and medical and clinical staff members checked routinely (e.g., at least annually) against government sanctions lists, including the OIG’s List of Excluded Individuals/Entities (LEIE) and the General Services Administration’s Excluded Parties Listing System.”

From the guidance for Individual and Small Groups:

“Another suggestion is for physician practices to conduct checks to make sure all current and potential practice employees are not listed on the OIG or GSA lists of individuals excluded from participation in Federal health care or Government procurement programs.”



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21What does good compliance look like at thecompany level?

• The development and distribution of written policies, procedures and standards of conduct to prevent and detect inappropriate behavior;

• The designation of a chief compliance officer and other appropriate bodies (for example a corporate compliance committee) charged with the responsibility of operating and monitoring the compliance program and who report directly to high-level personnel and the governing body;

• The use of reasonable efforts not to include any individual in the substantial authority personnel whom the organization knew, or should have known, has engaged in illegal activities or other conduct inconsistent with an effective compliance and ethics Program;

• The development and implementation of regular, effective education and training programs for the governing body, all employees, including high-level personnel, and, as appropriate, the organization’s agents;

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• The maintenance of a process, such as a hotline, to receive complaints and the adoption of procedures to protect the anonymity of complainants and to protect whistleblowers from retaliation;

• The development of a system to respond to allegations of improper conduct and the enforcement of appropriate disciplinary action against employees who have violated internal compliance policies, applicable statutes, regulations or Federal health care program requirements;

• The use of audits and/or other evaluation techniques to monitor compliance and assist in the reduction of identified problem areas; and

• The investigation and remediation of identified systemic problems including making any necessary modifications to the organization’s compliance and ethics program.

Federal Register / Vol. 76, No. 22 /

Wednesday, February 2, 2011 / Rules and

Regulations

22Are there legal obligations relative to a compliance plan and does that include sanctions checking?



� Under Medicaid, YES, per the Deficit Reduction Act of 2005 (“DRA”), as of 1/1/2007: compliance plans are effectively mandated for all entities that receive $5 million or more in Medicaid payments per year.

� DRA Section 6032, entitled “Employee Education About False Claims Recovery,” mandates that each state Medicaid plan require and establish certain written policies for all of their employees, contractors, and agents.

� The states must include, as part of their written policies, detailed provisions regarding the entity’s policies and procedures for detecting and preventing fraud, waste, and abuse.

� Is sanctions checking part of a compliance program? The OIG has published Compliance Program Guidance (CPG) that states payment of a sanctioned provider is a violation of the Civil Monetary Penalties Law.

� In 1981, Congress enacted the civil monetary penalty (CMP) statute, section 1128A of the Social Security Act (the Act) (42 U.S.C. 1320a–7a), as one of several administrative remedies to combat increases in health care fraud and abuse.

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23ACA: New Mandatory Compliance Program and other Provider/Supplier Enrollment Provisions (1)



Effective March 25, 2011§§§§§§§§424.57 – 424.570 and§§§§§§§§455.23 – 455.470

CMS is making additional efforts to prevent and detect fraud with its publication of thefinal rule addressing program integrity changes mandated by the Patient Protection andAffordable Care Act (PPACA), as amended by the Health Care and EducationReconciliation Act of 2010 (collectively known as the “Affordable Care Act,” or the “ACA”).

The final rule enhances background screening procedures for providers and suppliersparticipating or enrolling in the Medicare and Medicaid programs as well as the Children'sHealth Insurance Program (CHIP).

The ACA requires the HHS secretary (“the Secretary”), in consultation with the OIG, todetermine the level of screening based on the risk of fraud, waste, and abuse posed byeach type of provider or supplier.

Screening must still include:

1. a licensure check and also involves a fingerprint-based criminal history report check of the FBI database (closed for comment on 4/4/2011),

2. unscheduled or unannounced site visits, which may occur pre-enrollment,

2. multi-state database checks; and,

3. other screening measures deemed appropriate.

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ACA: New Mandatory Compliance Program and other Provider/Supplier Enrollment Provisions (2)

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Physicians and Non-physician practitioners (Final Rule excludes physical therapists and physical therapist groups and instead classifies them as moderate risk)Medical clinics and Group practicesAmbulatory surgical centersEnd-state renal disease facilitiesFederally qualified health centersHistocompatibility laboratoriesHospitals and Critical access hospitalsHealth programs operated by an Indian Health ProgramMammography screening centersOrgan procurement organizationsMass immunization roster billersReligious on-medical health care institutionsRural health clinicsRadiation therapy centersPublic or government-owned or affiliated ambulatory services suppliersSkilled nursing facilitiesCompetitive Acquisition Program/Part B Vendors Pharmacies that are newly enrolling or revalidating via the CMS-855BOccupational therapy providersSpeech pathology

Risk Category: LIMITED




Community mental health centersComprehensive outpatient rehabilitation facilitiesHospice organizationsIndependent diagnostic testing facilitiesPortable X-ray suppliers (moved from Limited to Moderate)Independent clinical laboratoriesNonpublic, nongovernment owned or affiliated ambulance services suppliersCurrently enrolled (revalidating) home health agenciesCurrently enrolled (revalidating) suppliers of DMEPOSPhysical therapistsPhysical therapist groupsAll ambulance suppliers (regardless of public or government affiliation)

Risk Category: MODERATE

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Prospectively (newly enrolling) home health agencies and suppliers of DMEPOS

Risk Category: HIGH




The “other” provisions:

- Imposes an application fee on institutional providers and suppliers,

- Sets out temporary moratoria that may be imposed if necessary to

prevent or combat fraud, waste, and abuse under the Medicare,

Medicaid programs, and CHIP programs,

- Provides guidance for states regarding termination of providers from

Medicaid and CHIP if terminated by Medicare or another Medicaid

State plan or CHIP, as well as provider and supplier terminations from

Medicare when those providers are terminated by a Medicaid state

agency (required under the ACA); and,

- Specifies requirements for suspension of payments pending

credible allegations of fraud in the Medicare and Medicaid programs.

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29What are CMPs?

42 U.S.C. 1320a–7a: Any person (includes organizations) that:

� Knowingly presents . . . a claim [state or federal level] that the government determines . . .

� (4) in the case of a person who is not an organization, agency, or other entity, is excluded from participating in a program . . . or a State health care program . . . retains a direct or indirect ownership or control interest in an entity that is participating in a program under subchapter XVIII of this chapter [Medicare] or a State health care program, and who knows or should know of the action constituting the basis for the exclusion; or (B) is an officer or managing employee of such an entity . . .

� (6) arranges or contracts (by employment or otherwise) with an individual or entity that the person knows or should know is excluded from participation in a Federal health care program, for the provision of items or services for which payment may be made under such a program . . . shall be subject, in addition to any other penalties that may be prescribed by law, to:

� a civil monetary penalty of not more than $10,000 for each item or service

� in cases under paragraph (4), $10,000 for each day the prohibited relationship occurs

� [In] addition, such a person shall be subject to an assessment of not more than 3 times the amount claimed for each such item or service in lieu of damages sustained by the United States or a State agency because of such claim.

� In addition the Secretary may make a determination in the same proceeding to exclude the person from participation in the Federal health care programs and to direct the appropriate State agency to exclude the person from participation in any State health care program.



30What does federally funded mean and how doesthat apply to an organization?



� In September 1999, the Department of Health and Human Services, Office of the

Inspector General (DHHS-OIG) released a Special Advisory Bulletin concerning “The Effect of Exclusion from Participation in Federal Health Care Programs.” This document provided a detailed explanation of when services rendered by an excluded provider are not reimbursable.

� Within the Bulletin, it was made clear that not only were federal funds not to be used for individuals and entities (vendors) directly involved with patient care, but that Civil Monetary Penalties (CMPs) could be imposed for using federal funds for excluded providers that were indirectly involved in patient care. In addition it stated that,

� "No federal program payment may be made to cover an excluded individual's salary, expenses or fringe benefits, regardless of whether they provide direct patient care."

� If your organization receives any federal funds, you have potential CMP exposure if any person, professional or organization you employ or contract with is a sanctioned individual or entity.

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31Enforcement:

The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services’ final rule broadened the scope of its administrative sanction authority with strong exclusion and civil monetary penalty (CMP) provisions: � CMPs for Employing Excluded Individuals

� CMPs for Reimbursing Excluded Individuals

� CMPs for Contracting with Excluded Individuals or Entities

CMPs can be very expensive: Up to $10,000 per instance for each item or service improperly claimed and, in addition, up to three (3X) times of the total amount improperly claimed. Example:

OIG Audit reveals 100 transactions from an excluded entity that was submitted for reimbursement and subsequently reimbursed at $100 per transaction.

100x$10,000= $1million plus $100x100x3= $30,000, Total Potential Exposure = $1,030,000

The OIG issued tens of millions in CMPs last year (2010).

Impact: OIG has expansive administrative sanctioning authority which potentially increases an entity’s exposure to Medicare/Medicaid CMPs and sanctions if an entity fails to take a proactive role in investigating and monitoring the eligibility of persons or entities where any Federal health care dollars or programs are involved.



32Are there other obligations or requirementsfor sanctions checking?



� The Joint Commission requires an event based approach, an event can be a license expiration or a patient complaint.

� The Joint Commission, has indicated that ongoing monitoring is likely to soon be a requirement as well: John Herringer, Associate Director, Standards Interpretation Group, the Joint Commission said,

“At this point, the idea is that it’s supposed to be an ongoing review. We’re not telling you it’s going to be monthly or three months, six months, nine months. I personally think if you only looked at something every 12 months that’s more of a period review than ongoing.”

� The National Committee for Quality Assurance and URAC have a 36-month review cycle requirement under its accreditation standards. However, if data is older than 120 days and, again, there is a “transaction” to rely on that data, the data must be re-run. For URAC it is 180 days.

� Some state laws mandate sanctions checking for hospital staff or for managed care organizations, usually every two (2) years. This, however varies from state-to-state and it is advised that you check with your legal counsel about your states’ requirements.

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33Summary:



� Credentialing and Compliance programs demonstrate a good faith effort to stay with the bounds of the law and are effective in managing risk if implemented well.

� You and your organization may be at risk if you do not engage in effective due diligence, Credentialing and Compliance activities are both forms of due diligence.

� Due diligence includes credentialing, re-credentialing (event, not time-based) and monitoring of key data sets.

� Penalties and/or legal risk for not performing some types of checks are very high (sanctions, sex offender, criminal).

� Failing to do due diligence can also be used against a company in a negligence or vicarious liability lawsuit.

� Failing to engage in due diligence can result in harm to you and your organizations reputation.

� What if one only does the bare minimum? If you read the law carefully, the bare minimum is to check what can be checked at both the state and federal level.

34The benefits of a best practices combined credentialing and compliance effort

� Manage and Avoid Risk: liability resulting from medical malpractice,

negligent credentialing and/or privileging, vicarious liability, corporate

negligence suits and whistleblower actions

� Advance the Quality of Health Care Outcomes: identifying high risk and

“never” event providers

� Assure Regulatory Compliance: OIG Guidance, Medicare/Medicaid

laws, regulations and CMS instructions and State Anti-Fraud Compliance

� Actively Protects Your VALUABLE Reputation: protecting against risky

health care transactions and costly loss of reputation

Health care is trust-based at the patient level,violating that trust is costly in many ways.



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Copyright © 2011 Verisys Corporation All Rights Reserved. Confidential and proprietary.Confidential and Proprietary. Not for Distribution.

Verisys Corporation888.837.4797 (888.VERISYS)www.verisys.com

Thank you for your time and attention.

W-2 Compliance and Credentialing - HCCA Official Site

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