Title: Practice Management Series 2004 2005
1Practice Management Series2004 - 2005
- Presented in Conjunction with
2Thomas R. Barr, MBALouisiana Oncology
SocietyMay 14, 2004
1. Oncology Moving Forward
2. Adapting to Changes in Medicare
3. Generating Practice Efficiencies
4. Organizing for Service Expansion
3Who should attend
- Physician Leader of the Practice
- President of the PA, Founder
- Practice Administrator
- CEO, Executive Director, COO
- Contracting Officer
- Contract Administrator, Director of Billing
- Clinical Manager
- Medical Director, Nursing Team Leader
4At the end of this session, you will
- Know why your practice needs to change
- Understand investment mentality and be able to
classify your practice in terms of investment
potential - List the common characteristics of effective
physician practice leaders - Understand the relationship between the physician
practice leader and the practice administrator - Be able to apply simple self assessment tools to
position your group to take advantage of market
changes today
5The Old DaysMedian Per FTE Medical
OncologistCompiled from MGMA Cost Survey through
2003 Report on 2002 Data. Second order polynomial
trend lines by OM
Why Change?
6Eroding MarginsPer Oncologist with projections
by Oncology Metrics
Why Change?
Now
Then
7Service Line Changes Five physician practice
2004 Compared to 2003
Why Change?
8Service Line Changes Five physician practice
2005 Compared to 2003
Why Change?
9Why Change
- Because we must change
- Population economics demand it
- GDP growth cant match Boomers march into SEER
cohorts - Other sectors or medicine have done it
- DRGs, ACPs, Cardiology, Radiology
- Market dynamics support it
- Everywhere the old order changes, and happy are
those who can change with it. Sir William Osler,
1895
Because it is wise to change
10Developing Investment Mentality
Rising Demand
Increasing Market Share
Problem Child
Rising Star
?
Mature Investment
Dog
Modified BCG Business Growth Matrix
11 Dog ?
Problem Child
- Practice sees a low of new cancer cases in
market - Overall market for cancer services is stagnant,
shrinking, or being consumed by competitors - Presently failing, either rapidly or slowly and
showing declining period-to-period revenue - Stagnation of capital investment
- Susceptible to sudden closings
- Smart dogs join up to form a dog pack
- Typical of a new practice or outreach clinic in a
new service area - operations need investment
- offer the potential of rapid growth
- always have high costs initially
- must be properly capitalized to keep from running
out of money just before they take off - shows real potential
- has a sustainable customer base
12 Mature Investment
Rising Star
- High market share
- Stable business with revenue growth driven by
existing customers and products. - Weak need or desire to innovate means low to no
capital needed - Profits are high and the contribution margin is
also high - Must maintain the strong market position as
competition wants to enter and claim margin
- Certain growth in demand for cancer services.
- Declining or stable number of providers able to
meet increasing demand - Significant barriers to entry for new competitors
- Financing mechanism for many service buyers
- Legacy of inefficient operations offer
significant process improvement opportunities - Promising new technology offering significant
opportunity for service line expansion
13Evaluating Product and Service Lines for
Additional Investment
Investment Mentality
- In-house pharmacy is a Product Line
- Research is a Product Line
- Chemo. Admin. is a Service Line
- Patient EM is a Service Line
- Laboratory is a Service Line
- RT is a Service Line
- CAT/PET is a Service Line
?
?
14To execute growth, you must have Management
- Physician Leader
- Seeing patients but on a reduced schedule
- About .5 FTE physician
- One of the founders or otherwise senior
- Active in hospital or community
- Can say I dont know, let me think about that
- Was (or is) the productivity leader
- Trusts the administrator
- Administrator
- Trained MBA, CPA, MHA
- Can read and write basic contracts
- Computer literate and analytically proficient
- Can say I dont know, let me think about that
- Trusts the physician leader
15To execute growth, you must have Patients
Investment Mentality
- Counting the number of new patients that are seen
in your practice is the starting point of most
feasibility studies. - New patients are the denominator across which to
leverage investment and costs. - 1,500 new patients/yr. can generally support a
CT and/or PET with reasonable margins
16New Patients / PhysicianAOHA/MGMA 2003 Report on
2002 Data
Investment Mentality
17Building New Patient FlowPhysician Practice
Leaders Role
- Promote and support the ability of the physician
team to build and maintain a powerful referral
system that will provide at least 400 new
patients/year/physician. - Design clinical staffing pattern sufficient to
support time for physicians to pay attention to
referral patterns.
18Building New Patient FlowPhysician Practice
Leaders Role
- Build partnership and pay policy that rewards
individual and group efforts to build patient
referrals. - Routinely measure and discuss referral patterns
- Support your administrator by not allowing staff
to circumvent or undermine your joint initiatives.
19Building New Patient FlowAdministrators Role
- Develop reliable ways to count new patients and
their referral source - Monitor and understand the insurance status of
incoming patients looking for patterns by
referral source - Reward front office staff for facilitating
incoming calls from referrals sources to a
physician - Support your physician leader by not allowing
staff to circumvent or undermine your joint
initiatives.
20To plan for growth, you must have Managerial
Measurement
Investment Mentality
- Not for tax purposes
- You get to make estimates and judgments.
- On an accrual basis
- Balance sheet shows what you own and what you
owe. - PL shows what you earned, (whether you have been
paid or not) and what you bought (whether you
have paid for it or not).
21Sample Balance Sheet
Investment Mentality
22Managerial measurements produce Financial
Indicators that are
- Important to the bottom line
- Easy and reliable
- Benchmarked on a FTE physician basis
- Tied to new patient accrual
23Sample PL Per Physician
24Steps to Managerial growth orientedService Line
Accounting
- Identify revenue centers from procedure
productivity report. This will also give you the
gross revenue (collections) for each center. - Allocate the direct cost to each revenue product
or service line as these are incurred in the
production of the product of service. - Allocate shared, or indirect, costs across
product and service lines in relation to the
gross profit from each product line. Collections
- direct costs gross profit. - Calculate net profit for each product line. Gross
revenue direct costs indirect cost net
profit.
25Managerial MeasurementPhysician Practice
Leaders Role
- Learn to read your basic financial statements
Balance Sheet, PL, Statement of Cash Flows - After you learn to read them, dont insist that
other physicians do the same - Understand how the basic financial statements
inform your managerial measurements
26Managerial Measurement Physician Practice
Leaders Role
- Be the one who reports managerial measures to the
physicians of your group - Only report the three managerial metrics you
think are most important for example - New patients/FTE physician ytd. vs. goal vs.
prior period - Revenue/FTE physician ytd. vs. goal vs. prior
period - Cost/FTE physician - ytd. vs. goal vs. prior
period - Support your administrator by not allowing staff
to circumvent or undermine your joint initiatives.
27Managerial Measurement Administrators Role
- Learn to read your basic financial statements
Balance Sheet, PL, Statement of Cash Flows - After you learn to read and understand them,
review these regularly with your physician
practice leader - Understand how the basic financial statements
inform your managerial measurements
28Managerial Measurement Administrators Role
- Be prepared to provide supporting details when
the physician leader reports managerial measures
to the physicians of your group - Double check the managerial measures to make sure
they agree with the basic financial statements
and are consistent with past reports. - Support your physician leader by not allowing
staff to circumvent or undermine your joint
initiatives.
29To execute growth, you must have Capital
- All business expansion requires capital
investment. - All business expansion that is properly executed
supports both the cost of capital and repayment
of capital. - ROI means Return on Investment
30To execute growth, you must have Capital
Investment Mentality
- IRR means Internal Rate of Return
- Retained Earnings are the source of most business
capital. - Debt is a tool of expansion.
31Capital ResourcesPhysician Practice Leaders
Role
- Understand the clinical drivers behind all
capital investments - Assure yourself that new patient referrals are
not threatened by capital projects - Talk to other physicians who have made similar
decisions and learn from them
32Capital ResourcesPhysician Practice Leaders
Role
- Be the financial spokesperson to your groups
physicians - Explain the need to create capital reserves and
retain earnings - Be willing to equitably shoulder capital risk
- Support your administrator by not allowing staff
to circumvent or undermine your joint
initiatives.
33Capital Resources Administrators Role
- Perform all analysis for new product line
development - Capital requirements, affect on referral
relationships, cash flow, and staffing needs - Development convincing managerial measurements
that inform capital decisions - Establish banking relationships and instruments
that cushion practice from capital shocks
34Capital Resources Administrators Role
- Plan a margin of safety into every capital
project - Establish an internal Hurdle ROI and only
recommend projects that are above that rate - Be willing to equitably shoulder capital risk
- Support your physician leader by not allowing
staff to circumvent or undermine your joint
initiatives.
35"Risk comes from not knowing what you're doing."
Why do all of this?
- Warren Edward Buffett  (1930- ), Reasonably
successful American financier, chairman of
Berkshire Hathaway Inc.
36Practice Management Series2004 - 2005
- Presented in Conjunction with
37Elaine TowleLouisiana Oncology SocietyMay 14,
2004
1. Oncology Moving Forward
2. Adapting to Changes in Medicare
3. Generating Practice Efficiencies
4. Organizing for Service Expansion
38Generating Practice Efficiencies
- Streamlining work flow
- Increasing patient flow per physician
- Maximizing charge capture
- Managing expensive inventories
- Lowering cost
39Who should attend
- Physician Leader of the Practice
- President of the PA, Founder
- Practice Administrator
- CEO, Executive Director, COO
- Contracting Officer
- Contract Administrator, Director of Billing
- Clinical Manager
- Medical Director, Nursing Team Leader
40At the end of this session, you will
- Be able to perform a simple assessment to
identify areas where cost savings may be found - Know how to plan to implement beneficial changes
in these areas - Believe that 2004 offers the time to prepare for
new realities of community oncology practice
41- Efficiency
- Ability to produce the desired effect with a
minimum of effort, expense or waste - Websters New Twentieth Century Dictionary,
Unabridged
42Why is efficiency important?
- The oncology world has changed.
- life as you know it is over
- Medicare Prescription Drug Improvement and
Modernization Act (MMA) 2003
43The Old DaysMedian Per FTE OncologistCompiled
from MGMA Cost Survey through 2003 Report on 2002
Data. Second order polynomial trend lines by OM
44The Old Days Per Median Oncologist Source
MGMA\AOHA Cost Survey
45MMA ImpactPer Oncologist with projections by
Oncology Metrics
Why Change?
Now
Then
46Practice EfficiencyFocus on Largest Expenses
First AOHA/MGMA 2003 Report on 2002 Data
47Practice Efficiency
- Drug Management
- Staffing
- Ensure that you are using all staff in the most
appropriate way for the size of your practice - Manage your overtime
- Task Analysis
- Who does it?
- Can anyone else do it?
- How do they do it?
- Can it be done better?
- Consider variations in small, larger practices
48Benchmarking
- Why?
- Benchmark your practice metrics to discover
potential work flow and/or staffing efficiencies - Lower the cost of practice operations
- Better inventory control
- Improved patient scheduling
- Streamlined work flow from clinic to billing
office
49Benchmarking
- How?
- Informal conversations, visits with colleagues,
oncology practice list serves - More formal use a standard such as MGMAs Cost
Survey for Hematology Oncology Practices - Most important to benchmark against yourself over
time
50COGS BenchmarkingUsing the MGMA AOHA
Hematology/Oncology Cost Survey 2003 Report
Based on 2002 Data
1 Cost
51COGS BenchmarkingUsing the MGMA AOHA
Hematology/Oncology Cost Survey 2003 Report
Based on 2002 Data
1 Cost
- Write down your COGS for 2003
- Multiply it by .87 to adjust for 13.4 increase
in COGS 2002 to 2003 (based on prior 2 years
increase) - Divide it by 1,053,518, the survey median COGS
per Physician in 2002 - Result is the number of physicians that your COGS
would support - Compare this to actual physicians and if it is
much higher or lower, keep asking why
52Drug Management
1 Cost
- Drug procurement and inventory management
processes must be tight - Contracting
- Ordering
- Inventory management
- Monthly reports - match inventory levels to
billed units - Who is managing this process for your practice?
53Drug Management
1 Cost
- Look at how you add new drugs to your practice
formulary to assure financial feasibility - Practice standardization, pharmaco-economics
review - Start simple - hydration, anti-emetics
- Then look at treatment protocols by disease, one
disease at a time - Knowledge is power, you cant control what you
dont measure
54Drug Management
1 Cost
- Pharmacy safety
- OSHA fines are expensive
- Nursing policies
- Errors are expensive charge capture errors,
chemo preparation errors - Who is mixing your drugs?
- Recent articles indicate 50 nurses, 50
pharmacists - Dependent on practice size, state regulations
55Physician Productivity Benchmarking Using the
MGMA AOHA Hematology/Oncology Cost Survey 2003
Report Based on 2002 Data
2 Cost
56Physician Productivity Benchmarking Using the
MGMA AOHA Hematology/Oncology Cost Survey 2003
Report Based on 2002 Data
2 Cost
- Write down the number of consultations and new
patients (99241-99255, 9920199205) in 2003 - Divide it by 231, the survey median of
consultations per physician in 2002 - Result is the number of physicians that your new
patient service volume would support - Are you above or below the actual number of
physicians in your practice? - Why?
57Relative Benchmarks
- 1. New Patients and COGS are both greater than
the actual number of physicians and yielding
about the same physician count - Indicates good physician utilization and pharmacy
control - 2. New Patients about right but COGS shows higher
number of physicians - Indicates potential savings at COGS management
58Increasing Patient FlowPhysicians Should
2 Cost
- Communicate with referring physicians this
drives practice growth - See new patients this drives practice growth
- Be seen at the hospital and participate in
medical staff life - See follow-up patients on a regular, clinically
appropriate basis - Delegate some follow-up visits to other providers
as appropriate PA, NP, RN - Ensure quality of care throughout practice
59Increasing Patient FlowPhysicians Should Not
2 Cost
- Routinely be late for clinic
- Spend time filling out forms (ex. disability,
tumor registry) - Routine patient education
- Return routine patient phone calls (prescription
refills, etc.) - Micro-manage staff
- Undermine authority of administrator
60Increasing Patient FlowAdministrators Should
2 Cost
- Assure that there are adequate exam rooms for
each physician - Provide appropriate patient scheduling,
individualized by physician if necessary - Use other staff, clinical and administrative, to
free up physician time whenever possible
61Increasing Patient FlowAdministrators Should Not
- Practice medicine or offer their clinical opinion
to anyone, ever! - Undermine the clinical authority of any of the
practice physicians - Undermine the business and leadership authority
of the physician leader
62Increasing Patient Flow Should you consider a
Non-Physician Practitioner?
2 Cost
- Also known as mid-level providers, includes PA,
NP, CNS - Increase patient volume at less expense than
adding a physician - Allow more flexibility in scheduling patient
visits, more consistent schedule than physicians - Generate revenue for practice even if physician
is out of office - Coverage for physician vacations better
continuity of care
63Increasing Patient Flow Non-physician
Practitioners Should
2 Cost
- Work as an adjunct to the physicians
- See routine follow-up patients, chemotherapy
visits, other routine visits - Allow physicians to see more new patients,
consultations - Serve as a resource for nurses, other staff
64Increasing Patient Flow Non-physician
Practitioners Should Not...
2 Cost
- See new patients
- Practice beyond their state scope of practice
65Practice EfficiencyNurses Should
3 Cost
- Administer chemotherapy patient assessment,
check doses, discuss side effects, prepare chemo
in some practices - Counsel patients symptom relief, social issues
- Phone triage - answer patients symptom-related
phone calls - Patient education
- Help with drug assistance programs and indigent
drug forms
66Practice EfficiencyNurses Should Not
3 Cost
- Handle pre-certs, pre-auth
- File
- Schedule appointments
67Practice EfficiencyChart flow
3 Cost
- Can you find a chart when you need it?
- How does it get from file to desk or file to exam
room? - Who gets it there?
- Do you have a policy on charts leaving the
office? - How long (and how many staff) does it take to
find a chart that is MIA?
68Practice EfficiencyPatient Flow
3 Cost
- How do your patients get from waiting room to
exam room? - Who checks vital signs, preps patients for their
visit? - Who assists the physician with exams?
- Who gives injections?
- Does it have to be a nurse?
69Other Efficiency Opportunities
- Billing is important
- Review your billing processes
- Charge capture
- Who selects the level of service?
- Chart reviews to find lost charges and injections
- Charge entry
- How quickly are your charges billed to insurance?
- Superbill
- Is it updated every year?
- Training
- Billers, nurses
- Coding updates
70Other Efficiency Opportunities
- Collecting is important too!
- Financial Counseling
- Identify patients with no insurance, poor
insurance - Identify patients with no 2nd insurance
- Refer patients to appropriate resources
- Inform the physician and nurse of insurance
issues as soon as they are identified
71Other Efficiency Opportunities
- Purchasing
- Chemotherapy Drugs shop wholesalers
- Medical supplies put out to aggressive bidding
process - Office supplies whos in charge? Dont let the
little things add up
72Other Efficiency Opportunities
- Information Systems
- Practice management system
- Network administration
- Software and hardware support
- Clinical Management Systems - LIS, EMR
73- Efficiency
- Ability to produce the desired effect with a
minimum of effort, expense or waste - Websters New Twentieth Century Dictionary,
Unabridged
74Practice Management Series2004 - 2005
- Presented in Conjunction with
75Elaine TowleLouisiana Oncology SocietyMay 14,
2004
1. Oncology Moving Forward
2. Adapting to Changes in Medicare
3. Generating Practice Efficiencies
4. Organizing for Service Expansion
76Adapting to Changes in Medicare
- Identifying and understanding the Medicare
changes in 2004 and their effect on your practice
77Who should attend
- Physician Leader of the Practice
- President of the PA, Founder
- Practice Administrator
- CEO, Executive Director, COO
- Contracting Officer
- Contract Administrator, Director of Billing
- Clinical Manager
- Medical Director, Nursing Team Leader
78At the end of this session, you will
- Be able to assess the degree to which your
practice has made the necessary changes to adapt
to new Medicare regulations - Understand the new regulations and be sensitive
to the threats and opportunities they embody - Be prepared to adapt to further changes as we
move to a very low margin on all chemotherapeutic
and supportive care products - Understand the role of the physician practice
leader and the administrator in adapting to these
changes
79Medicare Prescription Drug, Improvement, and
Modernization Act of 2003
- Average Wholesale Price decrease with most drugs
at 85 of AWP April 1, 2003 - Drugs without an AWP as of this date will be
reimbursed at 95 of AWP - As of April 1, 2004, 5 drugs repriced, on appeal,
by CMS - 2004 Conversion factor at 37.3374 (1.5 over
2003) - 0.17 RVUs added for chemotherapy administration
practice expense - 32 transitional add-on to the practice expense
component for 2004 only
80Relative Value Calculations
- Code 96410 (infusion, 1st hour)
81Relative Value Calculations
- Code 99214 (level 4 office visit)
82MMA ImpactPer Oncologist with projections by
Oncology Metrics
Why Change?
Now
Then
832005 - ASP
- Transitional 32 increase reduced to 3 for chemo
therapy administration codes - ASP 6 for drugs
- RVUs will be reviewed
842006 Competitive Bidding Option Added
- Physicians must choose between
- ASP 6 or Competitive Acquisition
- (bidding process has not yet
- been established)
85Billing Hotspots
- 99211 Minimal visit, physician presence not
required - As of 1/1/04 cannot be used the same day
chemotherapy is administered - Other EM services may be billed with a -25
modifier if medically necessary - Document all services
86Billing Hotspots
- 96408 Chemotherapy administration, intravenous
push technique - Prior to 1/1/04 only one push code was allowed by
Medicare - After 1/1/04 multiple push codes are allowed for
chemotherapy drugs when multiple chemotherapy
drugs are administered on the same day - It is not clear how commercial carriers will
address this change
87Billing Hotspots
- 96410 Chemotherapy administration,
- infusion technique, up to one hour
- Multiple infusion codes are still not allowed,
even when multiple chemotherapy drugs are
administered on the same day
88Drug Billing Units Changes
- Before 2004
- Oxaliplatin 50mg J3490 unlisted code
- Neulasta 1mg J3490 unlisted code
- Epirubicin 50mg J9178
- 2004
- Oxaliplatin 0.5mg J9263
- Neulasta 6mg J9205
- Epirubicin 2mg J9178
89Revenue Trends
Margin in the drugs we used
Margin on Services we Provide
Slopes are not equal. Overall combined margins
are declining
2004
2005
2006
2007
90Act Now
- Stop billing leaks
- Capture all service charges
- E M
- Chemotherapy administration
- Therapeutic Infusion
- Laboratory
- Documentation is critical
- Dont lose any drug charges!
- Chemotherapy
- Supportive care
91Act Now
- Understand rule changes
- Document and bill by the rules (CMS, AMA)
- Disseminate billing and coding information in
your practice - Update drug pricing/charges ASAP
- Update fee schedule, superbill at least yearly
- Dont miss any billing opportunities
92Act Now
- Financial consultation
- Know your patients insurance status BEFORE
treatment - Identify co-pay, co-insurance problems
- Have a plan for indigent care
- local/state resources
- pharmaceutical companies
- www.needymeds.com
93FAQ Multiple pushes of chemotherapy agents are
now allowed on the same day
- Q. Is it necessary to append a modifier to CPT
Code 96408 (CHEMOTX ADMIN IV, PUSH)? - A. No modifier should be necessary. The CMS-1500
form should include the HCPCS code for each drug
administered via push and CPT code 96408 with the
corresponding number of units.
94FAQ EM Service with Chemo Administration
- Q. Is a separate (non-chemotherapy, non-cancer
related) diagnosis required to bill a separately
identifiable evaluation and management service in
conjunction with chemotherapy administration? - A. No. There is no requirement that a separate
diagnosis must be reported to justify billing for
a separately identifiable EM service in
conjunction with chemotherapy administration.
95FAQ EM Service with Chemo Administration
- Q. What sort of documentation is required to
justify billing an EM visit in conjunction with
a chemotherapy administration code? - The documentation requirements have not changed.
Chart documentation for the EM service must
justify the level of visit being billed, in
accordance with either the 1995 or 1997 Medicare
documentation guidelines. -
- Bill for the EM service using the -25 modifier
along with the appropriate EM Code. - NOTE 99211 cannot be billed if chemotherapy is
administered the same day.
96FAQ EM Codes with non-chemotherapy infusion
- Q. Can CPT 99211 (established patient, may not
require physician presence) be billed with
non-chemotherapy drug infusion code (90780
-90781)? - ASCOs understanding of CMSs current payment
policy is that a 99211 should NOT be billed on
the same date of service as the nonchemotherapy
infusion. -
- If a higher level office visit occurs, the -25
modifier should be used with the EM code and
appropriate documentation should be provided.
97FAQ EM Codes with non-chemotherapy injection
- Q. Can CPT 99211 be billed with non-chemotherapy
drug injection codes (90782 90788)? - A. No. CMS has not changed its existing policy.
It is not permissible to bill for a
non-chemotherapy injection code on the same day
as another physician service. If a 99211 visit is
billed, 90782 should not be billed.
98FAQ Billing Units
- Q. Some billing software will not accept the 3
digit unit that is required to bill
Eloxatin/Oxaliplatin. The new HCPC code is for
only 0.5 mg. A typical dosage of 150 mg will
equal 300 units (3 digits). How should this be
billed? - HIPAA compliant electronic transactions should be
able to accommodate 3 digit billing fields so if
yours doesnt, think about an upgrade. In the
meantime, you should bill on separate lines with
no two lines having the same number of units.
For example, you would bill 300 units as
J9263 x 99 units - J9263 x 98 units
- J9263 x 97 units
- J9263 x 6 units.
99Role of the Physician Practice Leader
- Stay current on the moving target of Medicare
rules and regulations - Reinforce to your partners the importance of
Medicare compliance - A great resource is the CMS Carrier Advisory
website, and the CAC website - Work with your state society to establish
productive relationships with your Medicare
carrier and commercial payers - Support your Practice Administrator as they
implement policies to deal with these changes
100Role of the Administrator
- Update your coding books, reference materials,
fee schedule, superbill annually or as changes
occur - Ensure that your staff is knowledgeable about
reimbursement issues for all payers - Establish and implement policies to immediately
respond to changes as they occur - Enroll in Medicare list serves to stay up-to-the-
minute on changes - Work cooperatively with your physician leader in
providing leadership for your staff in this
challenging environment
101Know Your Medicare Carrier
- Carrier Website
- http//www.lamedicare.com/
- Carrier Medical Director
- Lynn Hickman, MD
- Carrier Contact Information
- Subscribe to your carriers listserv
- Circulate carrier bulletins to staff
102Know Medicare Nationally
103Know Medicare Nationally
104ASCO Resources
- Practical Tips for the Practicing Oncologist
2nd edition (3rd edition is coming soon!) - Ask a Coding Question
- Call 703-299-1050 or
- Email practice_at_asco.org
105ASCO Resources
- www.asco.org/MMA
- Look for the FAQs - updated as new information
available - www.asco.org/CAC
- A great resource for information on the Medicare
Carrier Advisory Committee process