Patient Access/Registration – Customer Service – Best ... · • Example of an Outcome Measure...

MACRA Update

Presented by: Richard T. (Terry) Lang, CPA, FHFMA and Timothy J. Stitt, CPA

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The material in this presentation, and presented during this webcast, is designed for, and intended to serve as an aid to, continuing professional education. Due to the certainty of continuous current developments in the healthcare industry, these materials are not appropriate to serve as the sole authority for any opinion or position relating to the subject matter. They must be supplemented with the authoritative source. Before making any decisions, or taking any action, you should consult the underlying authoritative guidance and if necessary, a qualified professional advisor.

The presenters and Fust Charles Chamber LLP shall not be held responsible for any loss sustained by any person who relies on this material or presentation made by the presenters.

Copyright is not claimed in any material secured from official US government sources.

Disclaimer

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How to get CPE

1. Throughout the webinar you will see 3 different letters, please make sure to type each letter into the chat box to ensure your participation.

2. Be sure to complete the survey (evaluation) at the end of the webinar.

*If there is an issue with your chat box or if your evaluation does not populate, please email Jackie Al-Nwiran @ [email protected] to receive credit.

CPE Certificates will be emailed out within the next few business days.

*Questions: There will be time allotted at the end of the presentation for a brief Q&A. You can type your questions throughout the presentation into the chat box and they will be answered in the order in which they were received.

* This presentation will be available in PDF format on our website @ www.fcc-cpa.com

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mailto:[email protected]

http://www.fcc-cpa.com/

Richard T. (Terry) Lang, CPA, FHFMA

Senior Manager, Fust Charles Chambers LLP

P: (315) [email protected]

Today’s Presenters

Tim specializes in Financial Consulting Services involving month-end closing, accounting control procedures, merger and acquisition assistance, benchmarking and service line analysis in both physician practice and acute care settings.

Tim is a member of the American Institute of Certified Public Accountants (AICPA), the New York State Society of Certified Public Accountants (NYSSCPA) and the Healthcare Financial Management Association (HFMA). Tim is a graduate of Syracuse University and resides in Liverpool, NY.

Terry has over 30 years of experience in healthcare in both hospital and long-term care organizations including holding the Chief Financial Officer position for three Central and Northern New York hospitals. He specializes and has significant experience in hospital financial operations including financial management, revenue cycle and third party reimbursement.

Terry is a member of the American Institute of Certified Public Accountants (AICPA) and the Central New York Chapter of HFMA. He is a graduate of SUNY Fredonia and resides in Fulton, NY.

Timothy J. Stitt, CPA

Senior Consultant, Fust Charles Chambers LLP

P: (315) [email protected]

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MACRA QUALITY PAYMENT PROGRAM UPDATE

• Historical Perspective• Changes Brought on by Bipartisan Budget Act of 2018• MIPS Program-Where the program stands today• MIPS Scoring Example• MedPAC Recommendations/Physician criticism• Changes to come?• Planning for the Future

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MACRA Quality Payment Program History

Medicare Access and CHIP Reauthorization Act of 2015• Legislation included as part of the Affordable Care Act (ACA)• Shifts the focus from “Fee-For-Service” to a “Value Based” reimbursement approach for delivering care• Replaced the Sustainable Growth Rate (SGR)formula that drove how clinicians were reimbursed for delivering care to Medicare

beneficiaries as part of the 1997 Balanced Budget Act• Combined the following legacy programs into a single improved reporting program for the submission of performance data starting

with the 2017 year:• PQRS (Physician Quality Reporting System)• VM (Value Modifier Program)• EHR Incentive Program (Meaningful Use)

The Quality Payment Program has Two Tracks for Clinicians• Merit Based Incentive Payment System (MIPS)• Advanced Alternative Payment Models (APMs) further defined as

• Advanced APM• MIPS APM

Bipartisan Budget Act of 2018 has brought some significant changes

Our focus today will be on the MIPS Program

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First Code Letter for CPE“T”

MACRA Quality Payment ProgramBIPARTISAN BUDGET ACT OF 2018 (BBA 2018) IMPACT ON MACRA

Background• Enacted by Congress and President Trump on February 9, 2018• Extends the transition years for the MIPS to include 2019,2020, and 2021

CMS originally designated 2017 and 2018 as the transition years

What does this mean?• By performance year 2022 the MIPS performance threshold must be the mean or median of national historical MIPS

scores• MIPS Cost category must be weighted at 30% by 2022

During the extended transition years 2019-2021, the Health and Human Services (HHS) Secretary will: Annually increase the MIPS performance threshold in a “gradual and incremental transition” towards the mandated weight of 30% in 2022

Set the MIPS Cost category weight to be between 10%-30%

• Changes the definition of Medicare Part B services Only “covered professional services” are now considered Medicare Part B services Eliminates Part B drugs and other supplies from the definition

Change impacts the MIPS financial incentives and penalties by reducing the dollar impact

Low-volume exclusion will also be impacted which will further reduce the number of clinicians who will be eligible to participate in MIPS

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MACRA Quality Payment ProgramMIPS Program

Clinicians are considered Eligible Clinicians (EC) if they • Bill more than $90,000 in “allowed charges”to Medicare Part B and• Provide care to more than 200 Medicare patients in a year and• Are not first year Medicare Part B participants• Allowed charges are “covered professional services“ only

EC’s include the following:• Physicians • Physician Assistants• Nurse Practitioner• Clinical Nurse Specialist• Certified Registered Nurse Anesthetists (CRNA)

Eligible clinicians can either report performance data as an individual clinician or as part of a group• Individual is defined as a single clinician that is identified by a single National Provider Identifier (NPI) Number tied to

a single Tax Identification Number (TIN)• Group is defined as a single TIN with 2 or more eligible clinicians (including at least one MIPS eligible clinician) as

identified by their NPI who have reassigned their Medicare billing rights to the TIN Non-Patient Facing Clinicians are eligible to participate in the MIPS program if they:

Bill 100 or fewer patient facing encounters (including Medicare telehealth services) Are not newly enrolled in Medicare Are not a Qualifying APM Participant (QP) or Partial QP that elects not to report to MIPS A GROUP is non-patient facing if >75% of NPI’s billing under the group’s TIN during a performance period are labeled as

non-patient facing

Participation Guidelines

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Critical Access Hospitals

• For eligible clinicians that practice in a Method I hospital, the MIPS payment adjustment will only apply to items and services billed by the eligible clinician to Medicare Part B.

• For eligible clinicians that practice in a Method II hospital and have not assigned their billing rights to the CAH the MIPS payment adjustment only applies to items and services billed by the eligible clinician to Medicare Part B.

• For eligible clinicians that practice in a Method II hospital and have assigned their billing rights to the CAH the MIPS payment adjustment will apply to the Method II CAH payments.

Rural Health Clinics (RHCs) and/or Federally Qualified Health Centers (FQHCs)

• Not subject to the MIPS payment adjustment for services reimbursed under the RHC or FQHC payment methodology

Ambulatory Surgical Centers (ASCs), Home Health Agencies (HHAs), Hospice, and Hospital Outpatient Departments (HOPDs)

• If the facility bills for the items and services provided by the eligible clinician under the all-inclusive payment or PPS methodology the MIPS payment adjustment does not apply.

• The MIPS payment adjustment will apply if the eligible clinician bills separately for items and services provided to the entity

These items and services contribute to the determination of the low-volume threshold

You can check MIPS participation for your clinician’s by going to the following website and entering the clinician’s NPI number.

• https://qpp.cms.gov/

• The website will indicate the level of participation for your clinician as designated by CMS.

Participation Guidelines

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https://qpp.cms.gov/


Performance Category 2017 2018

Quality 60% 50%

Cost 0% 10%

Improvement Activities 15% 15%

Advancing Care Information 25% 25%

Total 100% 100%

Performance Year Category Weights

Scores for each category can not exceed 100% before weighting. For example, the maximum score for Advancing Care Information is 165%.

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Final Score Payment Adjustment

> 70 Points • Positive Adjustment• Eligible for exceptional performance bonus-

minimum additional 0.5%

16-69 Points • Positive adjustment• Not eligible for exceptional performance bonus

15 Points • Neutral payment adjustment

Less than 15 points • Negative payment adjustment of -5%• 0 points=does not participate

Scoring of Performance Data To Determine Potential Bonus

Transition Year 2018 Performance Category Final Scoring

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Improvement scoring for Quality and Cost Performance Measures• Bonus points earned for demonstrating improvement as compared to your 2017 performance• For Quality the improvement will be measured at the performance category level

Up to 10 percentage points available• For Cost, improvement scoring will be based on statistically significant changes at the measure level

Up to 1 percentage point is available• CMS will only calculate an improvement score if there is sufficient data

MIPS eligible clinicians use the same identifier for two consecutive performance periods and is scored on the same cost measure for 2 consecutive performance periods

If improvement scoring can not be calculated due to insufficient data, you will be assigned an improvement score of 0.

Small practices will automatically be awarded 5 bonus points• MIPS eligible clinician or small practice (defined as 15 or fewer eligible clinicians) must submit data on a least 1

performance category in an applicable performance period Additional points for the treatment of complex patients

• Earn up to 5 additional bonus points• Based on a combination of Hierarchical Condition Categories (HCC) and number of dually eligible patients treated

You can find information on the Quality, Cost, Improvement Activities, and Advancing Care Information at https://qpp.cms.gov/

Bonus Information

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https://qpp.cms.gov/


6 quality measures • You choose the measures• One measure must be an Outcome Measure OR a High Priority Measure• Replaced PQRS reporting model• Example of an Outcome Measure and High Priority Measure is Adult Kidney Disease: Catheter Use at Initiation of Hemodialysis

Measurement Period is the full twelve months of the 2018 transition year

Weight to final score changes to 50% with the introduction of the Cost Measure in 2018.

Data completeness increases to 60% except for Web Interface and Consumer Assessment of Health Care Providers and Systems (CAHPS)• Measures that don’t meet the data completeness threshold will earn 1 point except for a measure submitted by a small practice which will earn 3 points• What is data completeness?

• You must report that at least 60% of your total patients meet the measure's denominator criteria, regardless of payer (Medicare and Non-Medicare), except for Claims for which only Medicare Part B beneficiaries count.

• Each data submission mechanism required a minimum amount of data• QCDR, Qualified Registry, and EHR requires at least 60% of all-payor patients or visits qualifying for the denominator of each measure to be reported• Claims reporting required at least 60% of Medicare patient or visits• CMS Web Interface requires at least 248 Medicare patients randomly selected by CMS to be reported on for each measure

Special provisions for “Topped-out measures.”• Defined as a measure where the performance is consistently high across providers that meaningful distinctions and improvement in performance can no longer be made• Topped-out measures generally report at our near 100% for those eligible clinicians reporting the measure• Measures that have been topped-out for will earn up to 7 points• There are 6 capped out measures for 2018

Scoring• 3-point floor for measures scored against a benchmark as long as data completeness is met• 3-points for measures that don’t have a benchmark or don’t meet case minimum requirements (20 cases) as long as data completeness is met• Bonus for additional high priority measures up to 10% of denominator for performance category• Maximum 10 points can be earned per measure• Bonus for end-to-end electronic reporting up to 10% of denominator for performance category

Quality Performance Measures

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Included in Performance Measures for 2018• Weight for 2018 is 10%• Quality Performance Measure weight decreases from 60% in 2017 to 50% in 2018• Measurement Period calendar year 2018

Performance score will be calculated by CMS utilizing claims data

Includes the Medicare Spending per Beneficiary (MSPB) and total per capita cost measures

Episode-based cost measures are on hold

Performance is compared with the performance of other MIPS eligible clinicians or groups during the performance period

The full weight of 30% will become effective for the 2022 performance year and beyond.• As directed by the BiPartisan Budget Act of 2018, the weight will gradually increase for the performance

years 2019 through 2021 at the direction of the HHS Secretary

Cost Performance Measure

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Second Code Letter for CPE“I”


Attest to no more than 4 activities

• Example of an Improvement Activity is Care Transition Standard Operational Improvements

Attestation period a minimum of 90 days

Clinicians in an NCQA Recognized PCMH/PCSP receive full credit and are not required to report to CMS

Groups with fewer than 15 participants or in a rural or health physician shortage area (HPSA) only need to report on 2 activities for a period of 90 days

• Only need to report on 2 activities (2 medium or 1 high-weighted activity)

“Recognized” means the same as “certified” for PCMH/PCSP

• Clinicians in an NCQA Recognized PCMH/PCSP receive full credit and are not required to report to CMS

Number of practice sites within a TIN that need to be patient-centered medical homes has been finalized at 50%

• TIN will receive full credit for meeting this threshold

Group participation requires 1 MIPS eligible clinician in a TIN to perform the Improvement Activity for the TIN to get full credit

Some activities also qualify for an Advancing Care Information bonus

• Examples include Care Coordination and Population Management

• Bonus is 10% for use of CEHRT to complete at least 1 of the specified Improvement Activities

Simple attestation is allowed (yes/no)

Improvement Activities

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Name changed to “Promoting Interoperability” in 2018

Report on 4 or 5 Base Measures depending on the Measure Set selected• Advancing Care Information Objectives and Measures (2015 EHR Certified Edition)

• 5 Measures as follows:• Security Risk Analysis• E-Prescribing*• Provide Patient Access• Send a Summary of Care*• Request/Accept Summary of Care

• 2018 Advancing Care Information Transition Objectives and Measures (2014 or 2015 EHR Certified Editions)• 4 Measures as follows:

• Security Risk Analysis• E-Prescribing*• Provide Patient Access• Health Information Exchange*

• Exclusions have been added for those base measures with marked with a * • If the EC qualifies for exclusion, they will report 0 in the numerator/denominator for the applicable measure and will claim the exclusion through attestation or EHR reporting

• You can report on additional measures for both

Base score requirements • You will receive a base score of 50% for attesting to each base measure

• Submit a “yes” for the security risk analysis measure and at least 1 in the numerator/denominator for the remaining measures• If you can’t successfully attested to each Advancing Care measure you will receive a 0 for the Advancing Care Information category

For the performance score, an EC or group will earn 10% for reporting to any single public health agency or clinical data registry

A 5% bonus is available for submitting to an additional public health agency or clinical data registry not already reported under the performance score

Use of 2014 or 2015 Edition CEHRT is permitted• 10% bonus is available if you use the 2015 Edition Certified Electronic Health Record Technology

You can apply for a Hardship Exception if you do not have CEHRT.

Advancing Care Information

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Based on authority from the 21st Century Cures Act

Must be approved by CMS unless considered a “Special Status” clinician

Special Status Clinicians are defined as:• Hospital-based MIPS-eligible clinicians

Furnishes 75% or more of their covered professional services at locations identified by Place of Service (POS) codes 19 and 21-23. Includes covered professional services furnished in an off-campus outpatient hospital

• Physician assistants• Nurse practitioners• Clinical nurse specialist• Certified registered nurse anesthetists• Non-patient facing clinicians• Ambulatory Surgical Center (ASC) based MIPS eligible clinicians

MIPS-eligible clinicians can apply for the Hardship Exception if they have:• Insufficient Internet Connectivity• Extreme and Uncontrollable Circumstances including a disaster, practice or hospital closure, severe financial distress, or CEHRT issues such as decertification of EHR software• Lack of Control over the availability of Certified Electronic Health Record Technology

MIPS eligible clinicians in small practices (15 or fewer clinicians can also apply)

5-year limit on a significant hardship exception will not be applied• Example is use of EHR software creates a significant hardship for practice

Advancing Care Information performance category will be reweighted to 0% of the final score The performance category weight of 25% will be reallocated to the Quality Performance category

For the 2018 performance year the reweighting policy has been extended to include Quality, Cost, and Improvement Activities

Advancing Care Information Hardship Exception

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MIPS eligible clinicians who are considered “Special Status” will automatically be reweighted and do not need to apply for a hardship exception.For MIPS-eligible clinicians within a group that do not quality for

automatic reweighting or do not submit an application and receive a hardship exception, the group will not qualify for an automatic reweighting and will be required to report on the Advancing Care Information Performance CategoryDeadline for submission of application is December 31 of each

performance yearDoes not apply to APMs

Advancing Care Information Hardship Exception (cont..’)

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Have been added as a way to participate in 2018

Is a combination of two or more TINs assigned to one or more solo practitioners or to one or more groups consisting of 10 or fewer clinicians (including at least 1 MIPS eligible clinician), or both, that elect to form a virtual group for a performance period for a year

• A group is considered to be an entire single TIN that elects to participate in MIPS as a virtual group• Does not matter what the specialty or locality is of the group

A solo practitioner is defined as• MIPS eligible clinician• Exceeds the low-volume threshold• Is not newly Medicare enrolled MIPS eligible clinician• Qualifying APM Participant (QP) or a Partial QP choosing not to participate in MIPS

A group is defined as• 10 or fewer clinicians • Exceeds the low-volume threshold • TIN size is based on

Number of NPIs billing under a TIN including MIPs eligible clinician-must have a least ONE Clinicians who don’t meet the definition of a MIPS eligible clinician and/or are excluded from MIPs participation

A solo practitioner or group can only participate in 1 virtual group during a performance period Virtual Groups are required to aggregate their data across all TINs within the virtual group for all four performance categories Each member of the virtual group will have their performance assessed and scored at the virtual group level for all 4 performance categories

Only MIPS eligible clinicians would receive the MIPS payment adjustment

MIPS eligible clinician participating in a virtual group and also participating in a MIPS APM or Advanced APM will not earn a MIPS payment adjustment• Would earn a payment adjustment based on the APM scoring standard

Virtual Groups

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MACRA Quality Payment Program MIPS Program

Virtual Groups have the same definition as a Non-Patient facing group.• Must have greater than 75% of NPI’s billing under the Virtual Group’s TIN• Virtual groups determined to be non-patient facing will have their Advancing Care Information performance category

automatically reweighted to 0 Rural Area and HPSA

• Will be designated if more than 75% of NPIs billed under the virtual group’s TINs are designated in a ZIP code as a rural area or HPSA

Small Practice• 15 or fewer eligible clinicians• Based on the collective entity as a whole and not based on the small practice status of each TIN within the virtual group.• If virtual group has more has 16 or more clinicians it would not receive small practice status

Solo practitioners and groups who want to form a virtual group must go through an “election process” with CMS prior to the start of the performance period.

• For 2018 performance period the virtual group election process was from October 11, 2017 through December 31, 2017.• Each group must have a formal written agreement between each solo practitioner and group that composes a virtual group.

These agreement are not submitted to CMS.• An official representative, appointed by the group, will send an election notification to CMS via email

MIPS [email protected]. If CMS approves the request, they will assign a unique virtual group identifier made up of the following:

Virtual group identifier established by CMS TIN NPI

Virtual Groups (cont.’)

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Performance Category**

Quality

Cost

Advancing Care Information (renamed Promoting Interoperability)

Improvement Activities

Individual

QCDR(Qualified Clinical Data Registry)Qualified RegistryEHRClaims

No submission required

AttestationQCDRQualified RegistryEHR

AttestationQCDRQualified RegistryEHR

Groups (Including Virtual Groups)

QCDR(Qualified Clinical Data Registry)Qualified RegistryEHR*CMS Web Interface (groups of 25 or more)*CAHPS ( Consumer Assessment of Healthcare Providers and Systems) for MIPS Survey

No submission required

AttestationQCDRQualified RegistryEHRCMS Web Interface (groups of 25 or more)

AttestationQCDRQualified RegistryEHR*must have registered with CMS portal at https://portal.cms.gov/between April 1-June 30,2018(**only 1 data submission option per performance category is permitted

Data Submission Options:

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https://portal.cms.gov/

MIPS Scoring

4 MIPS scoring categories for 2018: Quality, Advancing Care Information, Cost, and Improvement Activities

There is a two-year gap between the performance year and the payment adjustment year • 2018 MIPS performance is used to assess the 2020 payment adjustment

Quality50%

ACI25%

Improvement Activites15%

Cost10%

2018 Category Weight

Quality ACI Improvement Activites Cost


Scoring Example

Independent Family Practice participation in MIPS 2018Quality Measures: 45/60 Points

• Breast Cancer Screening – 57% performance, 7 points• Controlling High Blood Pressure (outcome measure) –78% performance, 8 Points• Diabetes A1C – 32% performance, 6 points• Urinary Incontinence – 88% performance, 7 points• Documentation of Current Medication in the Medical Record (Topped Out Measure) – 99.99%

performance, 7 points• Preventive Care and Screening: Influenza Immunization – 92% performance, 10 points

Improvement Activities – 2 Medium-Weighted Activities, 15/40 Points• Documented use of Telehealth Services • Registered in the Prescription Drug Monitoring Program


Scoring Example

Advancing Care Information Measures (2014 Certified EHR): 64/100 Points• Required Measures for 50% Base Score

• Security Risk Analysis • e-Prescribing • Provide Patient Access • Health Information Exchange

• Performance Measures:• Secure Messaging - 8 Points• View Download or Transmit - 6 Points

Cost Based Measures 12.6/20 Points• TPCC Measure 7.2• MSPB Measure 5.4


Scoring Example

MIPS final score will be calculated as follows: (quality score * 50%)(100) + (improvement activities score * 15%)(100) +(ACI score * 25%)(100) + (Cost*.10)(100) + small practice bonus (if applicable) + complex patient bonus (if applicable) = 2018 MIPS final score

(75%* 50%)(100) + (37.5%* 15%)(100) +(64%* 25%)(100) + (63%*10%)(100) + 5 small practice bonus + complex patient bonus (if applicable) = 2018 MIPS final score

37.5+5.6+16+6.3+5= 70.4

With a final score of 70.4 points, the practice will receive a positive payment adjustment for the 2020 Medicare Part B FFS Claims and be eligible for an additional positive payment adjustment for exceptional performance with a score over 70 points.



So what happens if a clinician, who is deemed eligible (EC) to participate in MIPS in 2018, has done nothing so far this year?

According to the CMS Quality Payment Program, reaching the 15 point threshold is still possible. Here are some of their recommendations:

• Report all required Improvement Activities

• Meet the Advancing Care Information base score and submit 1 quality measure that meets data completeness

• Meet the Advancing Care Information base score and submit 1 medium weighted Improvement Activity

• Submit 6 Quality Measures that meet the data completeness criteria

Doing nothing will result in the clinician being assessed a 5% penalty on Medicare Part B payments in payment year 2020 (2018 performance year).

• The penalty increases to 7% for payment year 2021 (performance year 2019) and 9% for payment year 2022 and beyond (performance years 2020 and beyond).

Acute care hospitals are not exempt from the payment adjustment. • Hospitals that employ clinicians can receive a significant portion of their net patient revenue from the

outpatient services provided by these clinicians which can include services covered under Medicare Part B.

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MedPac Recommendations• In March MedPAC released its biannual report to Congress which included its recommendation to eliminate MIPS • The vote finalized the Commission’s decision to replace MIPS with a Voluntary Value Program (VVP) that MedPAC

believes would better achieve the goals put forth in MACRA• The VVP would be phased in over time and the clinicians would be allowed to self-organize into groups where

they would be evaluated collectively. • The VVP would measure all clinicians on the same set of measures: clinical quality, patient experience, and

value• The goal of the VVP would be to get clinicians to feel more comfortable with the measurement structure of

A-APMs. Members of the American College of Physicians found that just 37% of the quality measures in the Merit-based Incentive Payment System would actually improve the standard of care a patient received

Physician Criticism• U.S. physician practices are spending $15.4 billion each year (about $40,000 per physician) to report on performance

measures• Practices could end up spending as much as $50,000 to extract their data from one system to another that complies

with MACRA requirements• Implementing a system from scratch could cost $163,765 for a single provider practice and $233,298 for a

practice of five• It is unclear how much more can be done to save costs, making the prospect of missed saving goals unsettling

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• The American Medical Group Association (AMGA) has asked to overturn scale back CMS exemptions which allowed thousand of Physicians to opt out of MACRA

• They argue that the lack of participation will defeat the purpose of MACRA, to help move Medicare from a fee-for-service to a value-based system

• With the alternative payment models and the small practice exemptions, only 39% of the 1.5 million Physicians now billing under Medicare are eligible to report under MIPS

• As more Physicians do not participate in MIPS, the incentive payment bonus pool is shrinking, which was initially $833 million under MIPS in 2019 and now is down to $118 million in 2020, an 85% decrease

• Some feel that these cuts make the pool inadequate to help practices recoup hundreds of thousands of dollars spent on staffing, care model planning, and population health software to implement MIPS

More Changes to Come

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Third and Final Code Letter for CPE“M”


Determine whether you are eligible to participate in MIPS• Check eligibility on the CMS website

Assess your financial risk of not participating• Cost/benefit of participation• How much Medicare Part B covered professional services

reimbursement do you receive annually?• Can you afford the negative consequences of not participating?

If the answer is “yes” to being eligible to participate and “no” to can not affording the negative consequences of non-participation, how do you proceed?

Evaluate whether you have the internal resources to implement the measuresIf not, consider outside resources

Solutions

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Thank You!Questions? Please reach out to Terry Lang or Tim Stitt

with any questions you have on this topic.

Visit our website to learn more about Fust Charles Chambers and our Healthcare Consulting Service Lines

www.fcc-cpa.com

CPE Certificates will be emailed out within the next few business days.

P: (315) [email protected]@fcc-cpa.com

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http://www.fcc-cpa.com/



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