Medicare as a Second Language Policy

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Medicare as a Second Language Policy Payment
Issues for CRNAsPamela K. Blackwell,
JDAssociate Director Federal Regulatory
Payment Policy
0909/08
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Medicare as a Second Language

• What makes it like a Second Language?
• Acronyms (CMS, SGR, MEI, GPCI)
• Formulas
• Legal Language
• Process
• PATIENCE PRACTICE

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Who sets practice payment policies for CRNAs?

• AANA
• CMS (Medicare) - Centers for Medicare/Medicaid
  Services, FDA, DEA, other federal agencies (e.g.
  payment rules)
• Congress
• State Government (e.g. licensure, certification)
• Joint Commission
• Healthcare Facilities Hospitals, Ambulatory
  Surgical Centers (ASCs), Community Access
  Hospitals (CAHs) (e.g. privileges)

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Where do CRNAs Practice

• Medicare CRNAs
• CRNAs predominate where there are more Medicare
  beneficiaries. (GAO Rpt. 2007)
• CRNAs predominate where the gap between Medicare
  and private pays is less. (GAO Rpt. 2007)
• CRNAs are sole anesthesia providers in most rural
  hospitals.
• CRNAs ensure rural hospitals can provide OB,
  surgical, trauma stabilization and pain
  management services.
• CRNAs predominate in Veterans Hospitals and U.S.
  Armed Forces. (440 CRNAs, Dept. of Veterans
  Affairs)

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Medicare Facts for CRNAs

• CRNAs are recognized Medicare Part B
  providers,1989
• Can bill Medicare directly for 100 of the
  physician fee schedule amount, just as can
  anesthesiologists
• Medicare reimburses anesthesia professionals 2.4
  billion/year, most of which is for anesthesia
• 1.7 billion for anesthesiology
• 657 million for nurse anesthesia
• Up 25 from 2005 level of 1.9 million
• CMS, PFS Final Rule, 11/01/06
• Federal Funding, Education
• 3 million for nurse anesthesia education
  programs
• Billions for GME
• Congress considering cutting GME funding, so
  CRNAs self-financing their education could be a
  long-term advantage for the profession.

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Medicare Latte Factor
Have you had your latte today?
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Source CMS Actuary, National Healthcare
Expenditures Projections 2005-2015
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Medicare Latte Factor cont.

• Total US Healthcare Spent/year
  2.17 trillion, 16 of GDP
• Medicare Budget
• 19 of U.S. Budget
• 420 billion/year
• Total US Population 300 million
• 12 oz Starbucks Tall Latte 2.70/cup

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On average, every person in US contributes
1373/year to Medicare!
every person buying 508 lattes/year!
every person buying 1.3 lattes/day/everyday!
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Medicare Medicaid
Medicare and Medicaid


Every person spends 6.70 /day/everyday!
2458/year! 2004 5/day, 1725/year 733
more/year!
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Medicare Paperwork The Basics

• Enrollment of CRNAs as Medicare
• 855B Group - 65 pages
• 855I Individual - 29 pages
• CMS 1500 Form - 33 Total Elements
• CPT Procedure and Diagnosis Coding
• Who Does Your Coding? Degreed/Certified

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The Layers of Medicare

• Carriers/MACs (Medicare Administrative
  Contractor) A private company that has a contract
  with Medicare to pay your Medicare Part B claims,
  4 MACs
• Blue Cross Blue Shield of Florida
• Contractor - An entity that has an agreement with
  CMS to perform a project.
• Noridian Administrative Services
• Regional Offices - 10 - work closely with
  Medicare contractors in their assigned
  geographical areas.
• CMS Centers for Medicare and Medicaid -
  Baltimore, MD

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Medicare Part A vs. Part B

• Medicare Part A - Conditions of Participation
• MD supervision of CRNAs
• Medicare Part B - Conditions of Payment
• Medical direction, payment rules
• Teaching payment rules

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Medicare Part A

• Requirements for hospitals to participate in
  Medicare program.
• CRNAs (42 CFR 482.52)
• Qualified anesthesia provider
• Must be supervised by an operating practitioner
  or anesthesiologist who is immediately available
  if needed
• State Opt-out of MD supervision
• Can conduct pre-, intra-, and post-operative
  anesthesia reports

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Medicare Part A cont.

• Qualified anesthesia providers MD/DO,
  anesthesiologists, dentists, oral surgeons,
  podiatrists, CRNAs, AAs
• Immediately available physical presence
  requirement
• In the operative suite or labor delivery unit
• Ability to immediately conduct hands-on
  intervention

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Medicare Part A cont.

• Immediately available does NOT mean
• X MD has to have specific anesthesia training
• X MD has to be specifically privileged to
  supervise CRNAs
• X Supervising practitioner has to be an
  anesthesiologist
• X Does not impose liability on surgeons who are
  the supervising MD
• MD/DO, dentist, oral surgeon, podiatrist can be
  supervising practitioner.

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Medicare Part A cont.

• State Supervision Opt-out
• Governor sends letter to CMS stating it wants to
  opt-out
• Opting-out consistent w/ State law
• Confirms w/ State Boards of Medicine Nursing
• Opt-out effective once sent, Postcard
• 14 Opt-out states - Alaska, Idaho, Iowa, Kansas,
  Minnesota, Montana, Nebraska, New Hampshire, New
  Mexico, North Dakota, Oregon, South Dakota,
  Washington, Wisconsin

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Medicare Part A cont.

• Medicare Interpretive Guidelines
• Interpret Medicare Part A, Cond of Participation
• Surveyors (Medicare, JCAHO, State Health Depts.)
  use to accredit healthcare facilities
• Clarify immediately available supervision
  language
• Physical presence req. problematic in rural
  hospitals, esp. for OB services (epidurals)
• AANA working to ensure guidelines consistent
• w/ Patient Access to quality care
• CRNA practice

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Medicare Part B

• Requirements to be paid for services.
• CRNAs are recognized - they or their employers
  should bill Medicare Part-B directly. (41 CFR
  414.60)
• CRNAs are a REVENUE SOURCE Failure to Bill
  Medicare Part B reimbursement LOSSES
• Medicare Q modifiers - (QX, QZ) who provided
  service

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Medicare Part B Anesthesia Payment Formula
(The Relative Value Anesthesia Charge Structure)
Three Primary Components

• Base Weight or Value of the procedure is
  expressed in Units
• Time Value is expressed in 15 Minute Units
• Anesthesia Conversion Factor (Jan-June08 CF
  19.96)

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Anesthesia Payment Formula cont.

• Anesthesia Conversion Factor
• Anesthesia CF - Converts the value of provider
  services into a dollar amount. Determines
  Medicare payment for provider service in an area.
• Jan-June 2008 19.96 (national average)

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Anesthesia Payment Formula

• Anesthesia Payment Formula
• Total units (Base/Value units Time units)
• X Conversion Factor (19.96)
• Medicare payment in
• Example
• QZ (Non-medically directed) anesthesia service
• 10 total units X 19.96 199.60
• QX (Medically directed)
• 10 total units X 9.98 99.80

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Medical Direction - QX

• Medical Direction When an anesthesiologist
  fulfills the following criteria for each of up to
  a maximum of 4 cases, Medical Direction of a CRNA
  takes place.
• These are payment requirements
• NOT quality of care standards. (63 FR 58843,
  11/02/98)
• Medically Directed - QX (QK, QY)
• CRNAs entitled to 50 of fee schedule for each
  case.
• Anesthesiologist entitled to 50 of fee schedule
  for each case (42 CFR 415.110)

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Medical Direction Criteria

• (42 CFR 415.110)
• For each patient, to receive payment for medical
  direction the physician must
• (i) Perform a pre-anesthetic examination and
  evaluation
• (ii) Prescribe the anesthesia plan
• (iii) Personally participate in the most
  demanding aspects of the anesthesia plan
  including, if applicable, induction and
  emergence

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Medical Direction Criteria

• (iv) Ensure that any procedures in the anesthesia
  plan that he or she does not perform are
  performed by a qualified individual as defined in
  operating instructions
• (v) Monitor the course of anesthesia
  administration at frequent intervals
• (vi) Remain physically present and available for
  immediate diagnosis and treatment of emergencies
  and
• (vii) Provide indicated post-anesthesia care.

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Medical Direction Documentation Requirements

• Condition of Payment
• The anesthesiologist must document in the
  patients medical record that he/she has met all
  7 medical direction steps. (42 CFR 415.110)
• Some insurers are moving away from paying for
  medical direction, could be good for CRNAs.
• Additional paperwork requirements
• Easier, and same cost to pay for a non-medically
  directed or personally performed service

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Medical Direction Diagrams
11 Ratio -QY
21 Ratio -QK
MD
MD
50
50
50
50
50
50
50
50
50
50
CRNA
CRNA
CRNA
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Medical Direction Diagram
41 Ratio -QK
MD
50
50
50
50
50
50
CRNA
CRNA
50
50
CRNA
CRNA
4 cases 400
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Non-Medically Directed - QZ

• CRNA entitled to 100 of the fee schedule

CRNA
CRNA
CRNA
CRNA
MD
100
100
100
100
100
5 cases 500
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Supervision vs. Medical Direction
Supervision
Medical Direction

• Part B
• Individual practitioner payment
• Rules of payment
• NOT safety rules
• CRNAs do NOT have to be medically directed
  to bill for services

• Part A
• Hospital participation
• MD supervision required
• Unless, state has opted-out

CRNAs in all states can bill as NON-medically
directed.
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Billing for Anesthesiologist Assistants (AAs)

• AAs cannot practice independently.
• To bill for an AAs services the AA must work
  under the direct supervision of an
  anesthesiologist. (42 CFR 410.69)

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CRNA Medicare Billing Requirements

• Only a Certified nurse anesthetist can bill
  Medicare directly. (140.1.2 of the Medicare
  Claims Manual)
• What does Medicare require to bill for services?
• Certification
• Recertification - Req. by AANA, assumed complete
  by CMS
• NPI (National Provider Identifier) Used to be
  UPIN

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NPI

• Fall 2007 Medicare accepts only NPI
• NPI Benefits
• Each CRNA gets own NPI, linked to you forever
• Where CRNA practices, (facility, geographic
  region) wont matter
• Before Needed a different UPIN for every
  facility, region where you practice, slows
  reimbursement
• Speeds up payment

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Graduate/Student Nurse Anesthetists

• Graduates/students nurse anesthetists are not
  assets to employers until they can generate
  revenue.
• Graduate/student nurse anesthetists cannot bill
  for his/her services.
• Employers of graduate/student nurse anesthetists
  cannot bill the graduate/students services.
• Students/graduates should take certification exam
  ASAP!

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Graduate/student billing cont.

• CRNA is eligible to bill upon the date of
  certification. (Medicare Claims Manual, Ch. 12)
• CRNAs can bill for services from official
  certification date to receipt of NPI.
• Check w/ carrier if can hold claims and file
  claims when CRNA receives NPI or within one-year
  prior to being certified.
• For non-Medicare claims, payment rules may vary.

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Teaching Rules
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Rules for Teaching CRNAs

• A non-medically directed CRNA can bill Medicare
  for teaching a SRNA.
• If a non-medically directed CRNA is teaching one
  SRNA  The CRNA can bill for 100 of the service
  if the CRNA remains continuously present for the
  entire procedure.

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Rules for Teaching CRNAs cont.

• 2. If the non-medically directed CRNA is
  teaching a SRNA in each of two rooms
• The CRNA can bill for each of the two rooms.
• Payment formula Base units discontinuous time
  multiplied by 19.96 (CF-anesthesia conversion
  factor). 
• Discontinuous time (DCT) time in which the
  CRNA was present with the SRNA in the room or
  face to face with the patient.
• CRNA can bill only for the time in the room
• CRNA must be present in each room for pre- and
  post- anesthesia care.

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Rules for Teaching CRNAs cont.

• 3. If the CRNA is medically directed, and is
  teaching an SRNA in each of two rooms, the
  anesthesiologist receives 50 and the CRNA
  receives 50 of the total fee (medical
  direction).

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Teaching Rules Diagrams
Base Discont. Time (CF) /each case
1.1 Ratio
2.1 Ratio
CRNA
CRNA
50 or 100
DCT
DCT
0
0
0
SRNA
SRNA
SRNA
CRNAs are non-medically directed.
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Teaching Rules cont. Medical Direction
111 Ratio
421 Ratio
MD
MD
50
50
50
CRNA
CRNA
CRNA
50
50
50
SRNA
SRNA
SRNA
SRNA
SRNA
0
0
0
0
0
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Teaching Rules for Anesthesiologists

• If an anesthesiologist is teaching one resident
  or one SRNA 
• The anesthesiologist can bill for 100 of the
  service if he/she remains continuously personally
  present for the entire procedure.
• If anesthesiologist is not personally present w/
  SRNA Anesthesiologist can bill for only 50 of
  service.

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Teaching rules cont.

• 2. If anesthesiologist is teaching a SRNA in each
  of two rooms
• Anesthesiologist can bill 50 of each service
  provided in each room
• 3. If anesthesiologist teaching a SRNA in one
  room and is supervising or medically directing a
  resident, intern or CRNA in a second room
• Anesthesiologist can bill 50 for SRNA service

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Teaching rules cont.

• 4. If the anesthesiologist is teaching a
  resident in each of two rooms
• Can bill for each of the two rooms.
• Payment formula Base units discontinuous time
  multiplied by 19.96 (CF-anesthesia conversion
  factor). 
• Discontinuous time (DCT) time in which
  anesthesiologist was present with resident in the
  room or face to face with the patient.
• Anesthesiologist can bill only for the time in
  the room
• Anesthesiologist must be present in each room for
  pre- and post- anesthesia care.

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Teaching Rules Diagrams cont.
1.1 Ratio
21 Ratio
MD
MD
50 or 100
50
50
0
0
0
SRNA
SRNA
SRNA
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Teaching Rules Diagrams cont.
21 Ratio
MD
50
50
0
0
50
OR
SRNA
Res.
CRNA
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Teaching Rules Diagrams cont.
Base Discont. Time (CF) /each case
1.1 Ratio
21 Ratio
MD
MD
50 or 100
DCT
DCT
0
0
0
Res.
Res.
Res.
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Teaching Rules Legislation

• H.R. 6331/Medicare Improvements for Patients
  Providers Act of 2008 (MIPPA)
• Reformed anesthesiologist teaching rules can
  bill 100 of PFS when concurrently teaching 2
  anesthesiology residents.
• Reformed CRNA teaching rules Req. CMS to
  establish teaching rules for CRNAs that are the
  same as anesthesiologist rules.
• Next Steps
• New Rules effective January 2010.
• AANA with active CRNA support must work with CMS
  to establish equitable rules for CRNAs.
• We Need Your Support!

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06/25/07
Anesthesia Teaching Rules Diagrams - CURRENT
DCT
DCT
Medical Direction
DCT
DCT
CRNA
MD
MD
NON-medically directed CRNA
50
CRNA
SNA
SNA
Res.
Res.
50
Discontinuous time (DCT) time w/ SNA (student
nurse anesthetist)/Res.(resident) or w/ the
patient, and is 50 payment.
SNA
SNA
100
100
MD
ASA Proposal
MD
50
50
Res.
Res.
SNA
SNA
50
06/25/07
Anesthesia Teaching Rules Diagrams AANA PROPOSAL
Medical Direction
100
100
100
100
CRNA
MD
MD
NON-medically directed CRNA
50
50
CRNA
SNA
SNA
Res.
Res.
50
50
SNA
SNA
MD
100
100
SNA
SNA
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Inserting Lines

• Will Medicare pay CRNAs and anesthesiologists for
  teaching SRNAs how to insert lines and provide
  other medical and surgical services?
• Other services may include insertion of Swan
  Ganz catheters, central venous pressure lines,
  pain management, emergency intubation, etc.
• Answer It depends on the carrier.
• CMS said that there is no prohibition to being
  paid to teach these services. HOWEVER, whether to
  pay or not is up to your Medicare carrier.

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Iron Rules of Medicare

• Just because it has a code, doesn't mean it's
  covered.
•  
• Just because it's covered, doesn't mean you can
  bill for it.
•  
• Just because you can bill for it, doesn't mean
  you'll get paid.
•  
• Just because you've been paid, doesn't mean you
  get to keep the money.
•  
•  

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Iron Rules of Medicare cont.

• There's always someone who gets the message and
  ignores it.
• Just because you been paid once, doesn't mean
  you'll get paid again.
•  
• Just because you get paid in one state doesn't
  mean you'll get paid in another
•  
• You'll never know all the rules.
•  
• Not knowing the rules can land you in the
  slammer.

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Why Congress the SGR are like aBride her
Wedding Budget
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Sustainable Growth Rate (SGR)

• Target Budget - Formula that sets a target for
  federal healthcare spending
• Updated every year to account for increase in
  cost of healthcare goods services
• Set by Congress, enforced by Medicare
• Every year, Congress goes over budget

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Increasing Costs to Medicare

• Medicare costs are increasing exponentially each
  year
• Sustainable Growth Rate (SGR) problem
• Does not accurately reflect cost of healthcare
  services
• Flat payment system - Does not reward for quality
  or efficiency
• SGR Cliff
• Each year Congress overrides SGR, smaller cut,
  AANA others support
• 18 month fix costs 9.4 billion
• Jan. 2010 Payment rates return to SGR rate,
  minus amount spent SGR fr 2004-2009
• Result 10.6 Cut in Part B payments each year
  for 10 years to make up for overspending in
  2004-2009
• MedPAC, determined that Medicare provider
  payments are adequate, appropriate access for
  Medicare beneficiaries

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Re-Valuing of Anesthesia

• Some relief for anesthesia providers
• 2005 Medicare paid anesthesia 34 of private
  payments/67 below private
• CMS Nov. 27, 2007 Final Rule
• Successfully won 34 increase in value of
  anesthesia 25 boost in the anesthesia CF
• Medicare paying 20 more for anesthesia in 2008
  than in 2007 though still less than private
  payers.

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Presidential Congressional Elections

• Impact on National Healthcare System
• June 2008 - Congress and Administration delayed
  fully addressing the SGR issue.
• Prediction - Democrats retain Congress, not
  enough in Senate to create working majority
  needed to push legislation through.
• Republicans Healthcare should be market driven.
• Provided by private insurance plans.
• Government should have only a peripheral role so
  that market competition drives rates, quality and
  efficiency improvements.
• Democrats Expand healthcare coverage to more or
  all Americans.
• Struggle with how to make healthcare affordable
  and accountable.
• Concerned with cherry-picking of healthier
  patients in a private payer driven market.

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Election impact cont.

• A reformed system must have incentives or
  requirements for everyone to purchase coverage to
  spread the risk pool.
• Not everyone has to pay the same for coverage.
• Medicare does a good job of spreading the risk,
  but is a poor price setter.
• Any system-wide changes in the healthcare system
  will not happen quickly and are likely to be
  incremental in approach.
• (Source Michael Hash, Tom
  Scully, JD, Sara Rosenbaum, JD)

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Fab 5 Changes to Expect in Healthcare

• Digitize healthcare system to increase
  efficiency, decrease redundancy and errors.
• Requires nation-wide IT infrastructure.
• Create value-based purchasing incentives for
  hospitals and providers (e.g. Physician Quality
  Reporting Initiative PQRI)
• The reward for performance may not be more money
  - the reward could be not having your payments
  cut.
• Addressing chronic care management and
  end-of-life costs, account for most healthcare
  dollars.
• Source Michael Hash, Principal, Health Policy
  Alternatives Inc. (Fmr HCFA/CMS Secretary)

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Fab 5 cont.

• Conduct Comparative Effective Analysis
• More evidence-based medicine to better determine
  who gets what services and payment amounts,
• Best outcomes for the same or less cost.
• Move away from fee-for-service to bundled
  payments to reduce cost. (CRNAs could risk losing
  identity and negotiating leverage.)
• Who pays for healthcare services and costs?
  Taxpayers, government, insurers, patients,
  providers, hospitals...etc.

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Success for CRNAs

• Reduce Cost. Add Value.

CRNAs should be aware of policy and practice
management issues so they can apply the rules and
influence payment policies in their favor at
local/state/federal level.
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Part B Link to Medicare Premiums

• Payment formula links physician payment to
  Medicare premiums.
• If Medicare pays providers more, then Medicare
  beneficiaries pay more.
• 2005 Premium Cost 78/month
• 2006 Premium Cost 125/month
• Basic coverage (89) Drug benefit (36)
• 1500/year/Medicare beneficiary

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Pay for Performance

• Pay for Performance (P4P) Medicare Part B
  payment based on quality of provider services.
• 4 measures to evaluate provider performance
  quality.
• Process, Structural, Patient Experience Outcome
• Process practitioner providing care known to
  improve outcomes. Specific steps providers take
  to improve quality, steps well-trusted, based on
  research.

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Pay for Performance measures cont.

• Structural - ensure providers are capable of
  delivering quality care. Ex. Certification,
  recertification, continuing education.

• Outcomes - how provider care actually affected
  the patient. Capture info
• on clinical effectiveness,
• safety.

• Patient experience care met goals of patient,
  ensure patients involved in care and understand
  their role.

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P4P measures cont.

• CMS P4P Programs
• Improve quality and efficiency, test Health IT
  systems, get hospitals and individual
  practitioners involved
• Premier Hospital Quality Incentive Demonstration
• 8.85 million in awards to hospitals that showed
  improvement just by reporting measures alone
• Physician Quality Reporting Initiative (PQRI)
• Makes reporting measures mandatory
• Expands list of measures to report

67
Physician Quality Reporting Initiative (PQRI)

• Providers who report measures 2009-2010 are
  eligible for a 2.0 increase in payments.
• CRNAs eligible to report
• 2009 PQRI CRNA-related Measures
• Timing, administration of antibiotic prophylaxis
  in surgical patient
• Prevention of Catheter Related Bloodstream
  Infection (CRBSI) Catheter Insertion Protocol/Ma
  ximum Sterile Barrier technique is followed
• Preventive care and screening Body Mass Index
  (BMI)
• Documentation and verification of current
  medications in the medical record
• Patient co-development of treatment plan/plan of
  care

68
P4P measures cont.

• What if patient should not have antibiotic? Do
  you get paid if you dont give the antibiotic?
• Answer Yes, so long as you report.
• Binary reporting allows practitioner to decide
  if antibiotic appropriate for each patient.
• YES - you gave the antibiotic
• NO - you didnt give antibiotic, cite why not
  appropriate in that case
• Who determines anesthesia measures?
• CMS, AMA Consortium, National Quality Forum
  (NQF), CDC, Private entities, AANA, ASA

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P4P Role of CRNAs AANA

• Participate in the development of anesthesia
  measures that improve patient safety and quality
  and that allow CRNAs to practice within their
  full scope of practice.
• Build relationships with CMS and other decision
  makers
• Participate in workgroups that develop measures
• Member - AMA Consortium, Anesthesiology Work
  Group
• Identify key AANA members, SRNAs/Education
  programs to contribute expertise and research
• Educate members on P4P initiatives

70
Conditions of Participation - Updates
AANA Public Comments to CMS Practice
Improvements for CRNAs.

• Authentication of Verbal Orders
• Proposed rule CMS said verbal orders must be
  authenticated by prescribing practitioners.
• AANA Comment CRNAs give verbal orders, but do
  not need prescriptive authority to give verbal
  orders. CMS proposed rule would exclude CRNAs
  from giving, authenticating verbal orders.
  Authentication crucial for patient safety and
  provider accountability.
• CMS Response CMS agreed w/ AANA. CMS changed
  language so verbal orders must be authenticated
  by the ordering practitioner. CRNAs now
  included.
• (71 Fed.Reg. 68672, Nov. 27, 2006)

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CoP Updates cont.

• Securing Medications
• Proposed rule Controlled and Non-controlled
  substances must be locked at all times.
• AANA Comment Agreed that drugs should not be
  accessible to those who would tamper, abuse or
  distribute drugs, but locking non-controlled
  substances at all times could jeopardize patient
  safety. (i.e. preparation of anesthesia carts)
• CMS Response Agreed w/ AANA.
• All drugs must be kept in a secure area, and
  locked when appropriate.
• Controlled substances locked at all times. Area
  where actively providing patient care or
  setting-up for patient considered a secure
  area.

72
CoP Updates cont.

• Post-Anesthesia Record
• Proposed Rule Post-anesthesia can be completed
  by an individual qualified to administer
  anesthesia w/in 48 hrs. after surgery. Does not
  have to be the same person who provided
  anesthesia.
• AANA Comment AANA agreed with proposed rule.
  Allows hospitals and anesthesia staff more
  flexibility in completing patients records and is
  consistent with rules for completing the
  pre-anesthesia record.
• CMS Response Agreed w/ AANA. Any individual
  qualified to administer anesthesia can complete
  the post-anesthesia record.
• NOTE CRNAs and anesthesiologists as qualified
  providers must play a real and active role in
  completing entire anesthesia record/evaluation.
  Students should not be completing record on their
  own, students are not qualified providers.

73
Where to go for HELP

• AANA DC- http//www.aana.com/
• Federal Medicare Legislative Regulatory Issues
• Member section, Government Relations, Federal
  Issues
• NEW! Medicare FAQs Answers to your most
  frequently asked Medicare payment questions.
• http//www.aana.com/federalfaqs.aspx
• Memos put complex rules in context
• Include diagrams links to official Medicare
  documents
• For use by you to advocate for your profession
  with your hospital administrators, other
  providers, insurers etc.
• Email specific questions to info_at_aanadc.com
• CMS/ Medicare Website
• http//www.cms.hhs.gov/
• Carrier info, NPI, P4P programs, Forms, Physician
  Fee Schedule, Payment rules

74
- Thank You -

• AANA
• Pamela K. Blackwell, JD
• Associate Director
• Federal Regulatory Payment Policy
• Washington, DC