new jersey chapter - HFMA NJ · 2013. 4. 18. · Highmark Medicare Services. Thanks to the Regulatory & Reimbursement Committee, led by Mike Sabo, Chair, and Scott Besler, Co-Chair,

new jersey chapter

September/October 2010 • vol 57 • num 2

• HealthInformationTechnologyCan TransformHealthCare see page 7

• LifestyleChangesSizzlewithFlavor HospitalsandSeniorLivingFacilities EmbracingHealthierMenus see page 41

Focus 1

September/October 2 0 1 0

focus•advertisers• focus•features•

focus•points• focus•cover•

ARMDS

Besler

CBIZ KA Consulting

Fox Rothschild LLP

McBee Associates, Inc.

NJ Smart Start Buildings

Norris, McLaughin & Marcus, P.A.

Panacea Healthcare Solutions

ParenteBeard, LLC

William H. Connolly & Assoc.

WithumSmith+Brown

Health Information Technology Can TransformHealth Care by Poonam Alaigh, MD, MSHCPM, FACP ………………………………………………… 7Recent Developments Concerning Implementation of theNew Jersey Compassionate Use Medical Marijuana Act by Nicole DiMaria, Esq. ………………………………………………………………… 9

Uncovering Pharmacy Department Risks and OpportunitiesProactive Measures to Reduce Exposure and Increase Net Revenue by Gary R. Fong, Pharm.D., Randy Wiitala, BS, MT, and Frederick Stodolak ………………… 11

Seven Elements of a Hospital’s Corporate Compliance Program:Time for an Internal Check-Up by Marc Stein, MBA …………………………………………………………………… 17

ACOs – Health Reform’s Latest Approach to Costs and Quality by William H. Maruca …………………………………………………………………… 19

Childhood Obesity – The Challenge for Our Generation by Paige Litten ………………………………………………………………………… 23

Charity Care Matters for Hospital EHR Incentive Payments by Stacey Bigos ………………………………………………………………………… 26

The Implications of Losing “Grandfathered Plan” Status by Theresa Borzelli, Harvey M. Katz, Sarah K. Ivy and Daniel N. Kuperstein …………………… 33

CFO Spotlight:Kevin Lenahan, FHFMA, Atlantic Health ………………………………… 35

Member Spotlight:Eileen Smith, CHAM ……………………………………………………………… 37

Lifestyle Changes Sizzle with FlavorHospitals and Senior Living Facilities Embracing Healthier Menus by Mary Welch ………………………………………………………………………… 41

2010 NJ HFMA Chapter Holds 8th SuccessfulLeadership Retreat by Laura A.Hess, FHFMA, and David Wiessel ……………………………………………… 44

Who’s Who in the Chapter ………… 2The President’s View by Mary T. Taylor, MBA, FHFMA ……… 3From the Editor by Elizabeth G. Litten, Esq. …………… 4Focus on Ethics ………………… 29New Members …………………… 30Focus on Finance ……………… 31

Meet A New Member …………… 32Certification Corner ……………… 38Job Bank Summary …………… 39Mark Your Calendar ……………… 39 Who’s Who in NJ Chapter Committees ………… 40Advertiser Focus ………………… 48

Celebrity Chef Cary Neff, a culinary talent whom Oprah Winfrey says does “amazing things with nutritious food,” is helping the healthcare and senior living industries embrace healthier menus. Here he demonstrates Flavors 450 - his newest concept to offer nutri-tionally balanced meals bursting with flavor and under 450 calories. Photo courtesy of Martha Davidson


2 Focus

focus/hfmaWho’s Who in the Chapter 2009-2010Chapter Website …………………………………..www.hfmanj.org

Communications CommitteeAnthony F. Consoli, Director ......................................................................Marsh USA, Inc.Elizabeth G. Litten, Esq., Chair ........................................................... Fox Rothschild LLPAl Rottkamp, MBA, Vice Chair .............................................................................. CrothallSteve Aaron ....................................................................................ARC Group AssociatesJim Beutel...........................................................................................Kadent CorporationMark P. Dougherty ........................................................................ Johnson Controls, Inc.Laura Hess, FHFMA ............................................................................................ NJHFMAJohn Manzi ................................................................ Panacea Healthcare Solutions, LLCRhonda Maraziti ............................................................................ WithumSmith + BrownNicole K. Martin, MPH, Esq. ..................................................................... Wolff & SamsonWilliam McCann ...........................................................................................Healthfirst NYDavid A. Mills ...................................................................................... Deloitte ConsultingAmina Razanica .............................................................New Jersey Hospital AssociationJames A. Robertson, Esq. ........................................................................Kalison McBrideRoger D. Sarao, CHFP ................................................... New Jersey Hospital Association

NJ HFMA Chapter OfficersPresident, Mary T. Taylor, MBA, FHFMA ......................... Southern Ocean County HospitalPresident-Elect, Michael Alwell, FHFMA ........................................................ UnaffiliatedSecretary, David J. Wiessel, CPA ......................................................... Ernst & Young, LLPTreasurer, John Brault, FHFMA ................................................ Somerset Medical Center

NJ HFMA Board MembersAnthony F. Consoli …………………………………………………… Marsh USA, Inc.Mary M. Cronin, FHFMA …………………………………………… Besler ConsultingTracy Davison-DiCanto, CHFP, MBA …………………… Princeton Healthcare SystemLaurie Grey …………………………………………… Princeton Healthcare SystemSean J. Hopkins – Ex-Officio ………………………… New Jersey Hospital AssociationMichael Ruiz De Somocurcio – Associate Board Member ……………… AmerihealthThomas Shanahan, FHFMA, CPA ………………………… Raritan Bay Medical CenterDebrah E. Shapiro, MBA………………………………………………… WFS ServicesEileen Smith – Associate Board Member …………………… Meridian Health SystemJoanne Vaul ……………………………………………………… CBIZ KA ConsultingHeather Weber ………………………………………………………… ParenteBeardDan Willis …………………………………………… Children’s Specialized Hospital

Caitlin C. Zulla, CHFP ………………………………………………………Med Assets

NJ HFMA Advisory CouncilBrian P. Sherin, MBA, FHFMA ……………………………………… Besler Consulting

Joseph J. Dobosh, Jr., MBA ………………………… Children’s Specialized Hospital

Cheryl H. Cohen, FHFMA ……………………………………………Pantheon Capital

Dorothy Lindstrom ………………………………………… Somerset Medical Center

Advertising Policy/Annual RatesThe Garden State “FOCUS” reaches over 1,000 healthcare professionals in various fields. If you have a product or service you would like the healthcare financial industry to know

about, please take advantage of this great opportunity!Contact Laura Hess at 888-652-4362 to place your ad or receive a copy of the Chapter’s advertising policy. The Publications Committee reserves the right to refuse any ad not consistent

with the overall mission of the Chapter. Inclusion of an ad in this Newsmagazine does not infer endorsement of the product or service by the Healthcare Financial Management Association or the Publications Committee. Neither the Healthcare Financial Management Association nor the Publications Committee shall be responsible for slight variations in production quality of published advertisements. Effective July 2006 Rates for 6 bi-monthly issues are as follows:

Display Full Page Half Page Quarter PageBack Cover – Full Page Color $4,600 NA NAInside Back & Front Covers – Full Page, Color $4,350 NA NAFirst Inside Ad – Full Page, Color $4,250 NA NAFirst Inside Ad – Full Page, Black & White $3,450 NA NAInside Ad – Color $3,450 $2,600 NAInside Ad – Black & White $2,150 $1,450 $875Center Spread – 2 Full Pages, Color $5,900 NA NACenter Spread – 2 Full Pages, Black & White $3,800 NA NANEW! Web Ads are available to our FOCUS advertisers – $250 for 3 months

Ads should be submitted as print ready (CMYK) PDF files along with hard copy. Payment must accompany the ad. Deadline dates are published for the Newsmagazine. Checks must be payable to the New Jersey Chapter - Healthcare Financial Management Association.

DEADLINE FOR SUBMISSION OF MATERIAL Issue Date Submission Deadline January/February December 15 March/ April February 15 May/June April 15 July/August June 15 September/October August 15 November/December October 15

IDENTIFICATION STATEMENTGarden State “FOCUS” (ISSN#1078-7038; USPS #003-208) is published bimonthly by the New Jersey

Chapter of the Healthcare Financial Management Association, c/o Elizabeth G. Litten, Esq., Fox Rothschild, LLP, 997 Lenox Drive, Building 3, Lawrenceville, NJ 08648-2311

Periodical postage paid at Trenton, NJ 08650. POSTMASTER: Send address change to Garden State “FOCUS” c/o Laura A. Hess, FHFMA, Chapter Administrator, Healthcare Financial Management Association, NJ Chapter, P.O. Box 6422, Bridgewater, NJ 08807

OBJECTIVEOur objective is to provide members with information regarding Chapter and national activities,

with current and useful news of both national and local significance to healthcare financial profes-sionals and as to serve as a forum for the exchange of ideas and information.

EDITORIAL POLICY Opinions expressed in articles or features are those of the author(s) and do not necessarily reflectthe view of the New Jersey Chapter of the Healthcare Financial Management Association, or the Communications Committee. Questions regarding articles or features should be addressed to the author(s). The Healthcare Financial Management Association and Communications Committee assume no responsibility for the accuracy or content of any articles or features published in the Newsmagazine. The Communications Committee reserves the right to accept or reject contributions whether solicited or not. All correspondence is assumed to be a release for publication unless otherwise indi- cated. All article submissions must be typed, double-spaced, and submitted as a Microsoft Word document. Please email your submission to:Elizabeth G. Litten, Esq. [email protected]

REPRINT POLICY The New Jersey Chapter of the HFMA will not reprint articles published in Garden State FOCUS Newsmagazine. Individuals wishing to obtain reprint authorization must obtain it directly from the author(s) of the article. The cover of the FOCUS may not be used in the reprint; however, the reprint may note that the article was published in a specific issue. The reprint may not imply endorsement by the HFMA, directly or indirectly.

The President’s View . . .I’m sure this summer has certainly been very busy for everyone, and now it’s time to

get back to work and education! In June, our Board of Directors and all the Committee Chairs and Co-Chairs met for our annual Leadership Training Conference at Ocean Place Resort. Our main focus was to plan this coming year’s activities and goals. We chose four main categories to focus on: Certification & Education Programs, Future Leaders & Social Networking, Vendor Events and Member Recognition. Since then our committees have been working diligently to create education programs and member recognition events. The Board also created a sub-committee, led by Mike Ruiz De Somocurcio from Amerihealth, to address vendor issues/events, thank you Mike for Stepping Up! See our website at www.hfmanj.org for more details.

Our Education Committee, led by Tracy Davison-DiCanto as Board Program Chair, Lisa Hartman, Chair, with Matt Glass as Co-Chair, are working with the committee members to create education events, including several webinars. Lindsay Colombo has taken the lead in creating a six-week “certification series”. This is a brand new course for individuals who are interested in becoming a Certified Healthcare Financial Professionals. The individual sessions are appropriate for people in budget, reimbursement and financial analysis, patient accounting and revenue cycle, non-financial healthcare professionals such as patient access services, hospital clinical administrators, and staff employees of insurers who require an understanding of healthcare financial issues. They will also have the opportunity to take a “mock exam” to prepare them for the National Certification Exam. Check the website for dates and details www.hfmanj.org.

Our education program on September 16th, at the Woodbridge Hilton, was packed full of valuable information regarding “The Future of Healthcare in America”, Healthcare Delivery Systems from a provider and physician perspective, as well as the regulatory and coding changes coming our way, the new role of Government Relations Specialists, and an update from CMS Highmark Medicare Services. Thanks to the Regulatory & Reimbursement Committee, led by Mike Sabo, Chair, and Scott Besler, Co-Chair, and all the committee members for a great program!

Don’t forget to mark your calendars for our 34th Annual Institute, joint with Metro-Philly, on October 20-22, 2010 at the Borgata Hotel and Casino in Atlantic City. This is a two and a half day event, which provides high quality education and workshops plus great networking opportunities. Our Keynote speakers include Debora Kuchka-Craig, FHFMA, National Chair of HFMA and Elizabeth A. Ryan, Esq., president and CEO of NJHA giving us state and national perspectives on health care reform. Other keynote speakers are Yosef D. Dlugacz Ph.D., Sr. VP & Chief of Clinical Quality, Education & Research for KQMI, Bruce Weinstein, Ph.D., “The Ethics Guy” and Dr. Brad Nieder a specialist in “Healthy Humor”. We also have four education tracks with sessions on Audit/Compliance, Finance, Reimbursement and PFS. Ending the session on Friday will be a CFO panel with top executives from Philadelphia and New Jersey. There is still time to sponsor an event, or reserve a booth to show your product lines! The charity this year is Habitat for Humanity, Camden office, rebuilding the Camden County area of Southern New Jersey, including areas surrounding Cooper Hospital and Our Lady of Lourdes Medical Center. Our theme Wednesday evening for fund raising will be based on the new HBO series “Boardwalk Empire”, with Lapis Luna bringing music from the 1930’s, 40s & 50s. There will also be games and a photo booth, so join us for our annual education & networking event. I hope to see you there!

And don’t forget to mark your calendars for January 11, 2011 and our PFS and Patient Access Quarterly Education Session at the Woodbridge Hilton.

I strongly encourage all of you to StepUp and join a committee, get involved, network, share ideas, learn and have fun! Visit our website for information on education events, hot topics and committee listings showing contacts and meeting minutes.

Respectfully,

Mary T. Taylor, MBA, FHFMA

Mary T. Taylor


Focus 3

From The Editor . . .

Elizabeth G. Litten

Dear Readers:

September is one of my favorite months, despite the onslaught of back-to-school activities. There are days when navigating complex legal issues seems peaceful in comparison with navigating my kids’ schedules, school webpages looking for mandatory parent forms that had to be signed last week, and aisles of picked-through school supplies in search of the “I forgot/we just found out I need” item. Yet even as my kids enter the 8th and 12th grades and I shake my head in bewilderment that I’m old enough to have a daughter nearly finished with high school, I find myself pleasantly surprised to be enjoying the chaos of early fall. I’m secretly delighted that my children look forward to their school supply shopping trips just as eagerly as they did in elementary school, and even see the silver lining in the “I need the form signed today” panic (what they lack in advance planning is made up for in a sense of responsibility, I tell myself ).

I am also very proud that the Communications Committee agreed to include my daughter’s article on childhood obesity in this issue. We thought the article would fit nicely with the article on healthy institutional cooking, and I know Paige worked hard on researching the article (written in her English class last spring; many thanks to her incredible teacher, Elizabeth McDowell, for challenging and inspiring the class, and for connecting so well with the kids). I encourage readers to submit articles that may be slightly different, in terms of the topic or author, than what you usually read in this magazine. Many of the topics we cover are variations or expansions upon, or updates to, topics covered in past issues, but publishing a variety of healthcare-related articles written from a variety of perspectives helps us kept the magazine fresh and relevant.

Please be sure to read the article by the New Jersey Commissioner of Health. You may be surprised to learn what New Jersey has accomplished and where we are headed in terms of health information technology.

Happy reading!

Elizabeth G. LittenEditor


4 Focus

$NJ SmartStart Buildings® is a registered trademark. Use of the trademark without permission of the NJ Board of Public Utilities is prohibited.

To get your share, visit NJCleanEnergy.com/BIZor call 866-NJSMART to speak to a representative.

Energy efficiency upgrades don’t need to break your budget.

In fact, they may barely make a dent.

New Jersey’s Clean Energy Program™ offers an extensive

array of comprehensive plans that make energy

efficiency more accessible than ever. You’ll save up front

through sizeable financial incentives and down the line

with considerably reduced utility bills.

FINANCIAL INCENTIVES AVAILABLE

GET PAIDTO UPGRADEYOUR BUSINESS

10-T1-186 Garden State Focus 7.3215x9.5625.indd 1 8/30/10 3:00 PM

Focus 6

With health care reform now law, you may be wondering

what's next for the health care industry. What will health

care look like in America in 5 years? 10 years? 20 years?

We don't have a crystal ball, but we can help you

determine what areas of your business are most impacted

by reform, what practices may require change to be in

compliance and what your operations need to maintain

their cutting edge now and in the months and years ahead

as various provisions of the law go into effect.

After all, we're not your ordinary health law attorneys.

Visit www.foxrothschild.com for more information on how

our Health Law Practice and Health Care Reform Working

Group can help you move ahead.

THE WORLD OF HEALTH CARE IS CHANGING.PROCEED WITH CAUTION.

www.foxrothschild.com

LET OUR EXPERIENCE BE YOUR GUIDE®

CALIFORNIA CONNECTICUT DELAWARE FLORIDA NEVADA NEW JERSEY NEW YORK PENNSYLVANIA

A Pennsylvania Limited Liability Partnership

Elizabeth G. Litten, Esq. | 609.895.3320 | [email protected] Pike Corporate Center | 997 Lenox Drive, Building 3 | Lawrenceville, NJ 08648-2311

The forces of change are growing in the health care industry and New Jersey has an opportunity to transform our health care delivery system from a model focused on acute care needs to a more comprehensive, preventive and chronic care approach–using health information technology and care coordination.

Although enormous advancements in medicine have been made in the past two decades, the nation and the state of New Jersey are lagging in the adoption of Health Informa-tion Technology (HIT). None of the other technologies and advancements can be used efficiently and effectively unless we treat not simply the disease, but the person as a whole. No matter how fast we apply new medical technologies and inno-vation, nothing will truly change until health care profession-als have real time electronic data available at their fingertips.

One of my top priorities is to champion the adoption of health information technology in our state that will result in the improvement of clinical outcomes. I believe the proper use of this technology is key to real health reform.

In order to truly capture the value of using health informa-tion technology, we must think about the process as a whole. It’s not just about implementing a computer system, it’s about ‘process re-engineering,’ it’s about tailoring systems to improve outcomes, and it’s about ensuring that systems are utilized to actually further the physician’s ability to better treat the patient. Simply making Electronic Health Records available to providers without planning the ‘how’ and the ‘why’ is inef-fective and barely improves outcomes.

As a practicing physician who worked in a Veterans Af-fairs hospital for more than five years, I can attest that Elec- tronic Health Records (HER) can make a meaningful difference. The VA’s home-grown ‘VistA’ system has for 25 years permitted doctors at VA hospitals around the nation to track patients, view critical information about them, and employ that information in diagnosing and treating patients–a process that is surprisingly rare in health care. I have constantly relied on this system to yield key information on my patients such as medications or radiology results. This data is vital to filling in the gaps between the sometimes-spotty verbal communication that most patients provide about their own health histories.

Now as Commissioner of the Department of Health and Senior Services, I intend to help the state’s providers make sig-nificant progress in using health information technology to im-prove patient care. We already have several initiatives in place.

The New Jersey Health IT Commission is in the process of making recommendations about privacy and security in the context of health information ex-change, and about the necessary elements for any EHR imple-mentation outreach and training program that exists in the state. The Commission last year spearheaded the development of a state Health IT Plan that serves as a great roadmap for all stakeholders. Most recently, the Commission, along with the Office for eHIT Development, submitted their joint Interim Report on Health Information Technology. Both documents are available at http://www.nj.gov/health/bc/hitc.shtml.

New Jersey recently received the downpayment on an $11.4 million federal Recovery Act grant to facilitate four regional Health Information Exchanges around the State, which will drive improvement in outcomes by allowing phy-sicians, in real time, to see patient data that is stored in other facilities. This year we will have implementation plans in place to create a statewide Health Information Network that links the four regional exchanges, New Jersey Medicaid, and ultimately any authorized provider, in a secure network. This web-based “brokerage” system will ensure doctors have secure statewide data in healthcare computer systems around the state.

The New Jersey Institute of Technology also received a Recovery Act grant of $23 million intended specifically to help primary-care physicians adopt health IT, and to do it in a holistic way that takes into account office workflow and envisions improved outcomes. In addition, Passaic County College received a $4.67 million training grant to develop curricula and train a 21st-Century health IT workforce. With all the opportunities available from the Recovery Act, there is predicted to be a substantial shortage in the number of IT professionals working in healthcare.

It is important that all of these programs and initiatives are coordinated–we need to help connect the dots so that EHR adoption in New Jersey doesn’t just happen haphazard- ly, it must happen thoughtfully. To facilitate HIT implementation across the state, Governor Chris Christie recently ap- pointed Colleen Woods to serve as New Jersey’s Statewide Health Information Technology (HIT) Coordinator In this position, she will be working with all state agencies, the healthcare provider community and other key stakeholders to ad-

Health Information Technology Can Transform Health Care

by Department of Health and Senior Services Commissioner Poonam Alaigh, MD, MSHCPM, FACP

continued on page 8

Focus 7


Poonam Alaigh


8 Focus

vance the consistent adoption of health information technol-ogy and health information exchange throughout New Jersey.

Before pursuing any available funding opportunities, medi-cal practices and hospitals must give careful consideration to how to deploy health IT in their daily workflow. Envision how the clinical process will change and how to adapt to those changes. Make sure each department has an ‘EHR champion’ to ensure adequate communication between all employees and that implementation procedures are fair and all-encompassing. Be precise in your contract with software vendors so that they provide adequate support, the flexibility to include new data el-ements in the future, and mandatory data elements and your desired ‘user screens’ now. If they’re not one-in-the-same, ensure that your EHR can share the appropriate information with your practice management and billing systems; that it can ac-cept lab ordering and results and populate the patient records with them. Ensure that your EHR system meets the Med- icaid criteria for meaningful use so that you can receive incentive payments. Target certain chronic diseases to track and manage with your new system. These ideas represent just some of the guidance we need to communicate with all providers.

Implementing a health IT system can be complex and there are many things you need to consider before establishing your electronic system. Although the up-front investment in

health IT can be overwhelming, the return you receive–the improved outcomes for your patients and your practice–will be worth the investment. As New Jersey moves forward on a statewide Health Information Network, the Department is working hard to ensure that the systems and technology are available to health care professionals so that you can provide residents with the best possible care that keeps them healthy.

For more information on the New Jersey’s Health IT ef-forts please visit: http://www.nj.gov/health/bc/hitc.shtml

About the authorDr. Alaigh was serving as executive medical director for Horizon Blue Cross Blue Shield when she was nominated by Gov. Chris Christie on Jan. 27, 2010 as commissioner of the New Jersey De-partment of Health and Senior Services.

Dr. Alaigh has a multifaceted background in health care ad-ministration, clinical practice, pharmaceutical medicine, health care policy and academia. A board certified internist with a spe-cialty in vascular diseases, Dr. Alaigh is licensed to practice in New Jersey and New York and is certified as a Diplomate in In-ternal Medicine. She earned her medical degree from the State University of New York (SUNY) at Stony Brook. She received a Master of Science in Healthcare Policy and Management from SUNY. She is certified as a Black Belt in Six Sigma.

continued from page 7

Balancing costs, care and operations

Balancing the demands of patient care, rising costs and the need to run a successful business can be a struggle for healthcare organizations. The professionals in

ParenteBeard’s Healthcare Services Group have decades of experience in providing financial and business advisory services to hospitals and healthcare systems, physician

and medical group practices, dental practices and other provider institutions.

Because ParenteBeard’s practice is structured regionally, we provide our clients with a thorough understanding of healthcare issues in their regions. It’s challenging to envision

what the healthcare industry will look like tomorrow. ParenteBeard can provide you with a secure business foundation today to help you move confidently into the future.

Audit | Accounting | Tax | Business Advisory Services

Parentebeard.com 800.267.9405 © Parentebeard LLC

Pennsylvania | New Jersey | New York | Delaware | Maryland | Texas

The Powerto Connect

Focus 9


Recent Developments Concerning Implementation of the New Jersey Compassionate Use Medical Marijuana Act

Nicole DiMaria

by Nicole DiMaria, Esq.

This is a follow-up to a previous article published in the May/June 2010 issue of the Garden State Focus, “The New Jersey Compas-sionate Use Medical Marijuana Act – Questions Abound.”

New Jersey’s medical marijuana law – the New Jersey Com-passionate Use Medical Marijuana Act (the “Act”) – faces an uncertain future. The effective date of the Act has now been delayed, and Governor Christie has made proposals to amend the Act. The following provides an overview of developments with respect to the Act’s implementation since June, 2010.

Delay of Act’s Effective Date: The Act was signed into law on January 18, 2010, by then-Governor Corzine before he left office. Soon into his administration, Governor Christie raised concerns with respect to the Act’s implementation. In March, 2010, the Governor and the Commissioner of the New Jer-sey Department of Health and Senior Services (“NJDHSS”), Poonam Alaigh, requested the Act be extended due to legal and security issues. Although the Act’s original sponsor, Sena-tor Nicholas Scutari, did not initially support the extension re-quest, State lawmakers ultimately approved a ninety day exten-sion in June. The extension will provide the NJDHSS – which is largely responsible for the Act’s implementation – until ap-proximately January, 2011 to issue regulations under the Act.

Gov. Christie is Advocating Amendments to the Act to Foster Centralized Growing and Distribution – Initially Pro-posed Rutgers/Hospital Growing and Distribution Amend-ment Plan Will Not Go Forward. As currently written, the Act provides for the issuance of permits to private “alternative treatment centers” (“ATC(s)”) to distribute medical marijua-na in accordance with rules and processes established by the NJDHSS. The Christie administration is seeking to amend the Act to address its concerns regarding potential security and safety threats under the ATC distribution model. In par-ticular, Governor Christie proposed a centralized growing and distribution program whereby Rutgers University’s agricul-tural center would grow the marijuana and teaching hospitals would dispense it. This plan would eliminate ATCs.

While the Act’s original sponsors expressed a degree of

support for the Rutgers plan, Rutgers issued a statement in July that it was not interested. The University explained it was not willing to put in jeopardy its federal grant and research funding – which is provided un-der the presumption that Rutgers is not violating the law – as a result of its involvement with marijuana, the possession of which remains a federal offense, regardless of any protection afforded under state law. Similar federal law concerns were expressed in an op-ed by Kate Greenwood, a research fellow at the Center for Health and Pharmaceutical Law and Policy at Seton Hall University School of Law, with respect to hospitals’ legal ability to participate in a centralized medical marijuana distribution system.

Next Steps? The Act’s original sponsors and medical mari-juana patient advocacy groups want the law implemented as written. While it is not clear whether the Christie adminis-tration will continue to seek amendments to the Act, accord-ing to Governor Christie’s spokesperson, Michael Drewniak, the administration is considering “‘other options’” and will continue “‘to work diligently to implement a high-quality and secure program for growing and distributing medical-use marijuana.’” Meanwhile, the NJDHSS has stated it is “now meeting with public stakeholders as part of the effort to design an effective program.” Whether that program will be based on the current law or a revised, more restrictive version, remains to be seen.

About the authorNicole DiMaria, Esq. is Counsel at Wolff & Samson PC, located in West Orange. Nicole is a member of the firm’s Health Care and Hospital, and Corporate and Securities Groups, representing health care professionals, physician groups, health care and hospital systems, ambulatory care facilities, and other health-related entities. Nicole provides both health care corporate and regulatory counseling, advising clients on matters such as Federal Stark and Anti-Kickback Law compliance, HIPAA compliance, Medicare/Medicaid reimbursement, state licensing, and state health care/professional regulatory compliance. Nicole can be reached at [email protected].

Focus 10

Meeting the unique needs of each client

client-focused solutions

Jeffrey Silvershein Vice President - Principal [email protected]

Successful solutions produce a significant return on investment, fit within the client’s culture, and provide long-term benefits. McBee Associates’ creates custom solutions that address the unique needs of your facility. Our world-class consulting team carefully balances the need for both short-term fixes and long-term solutions. Create a strong foundation of financial health with our full-service consulting services, including:

Revenue Cycle Enhancement—Improve billing efficiency and accuracy with the help of our knowledgeable health care finance professionals.

Denial Management—Recoup revenue associated with denied claims and reduce denial rates with our successful appeals process and root-cause analysis.

Revenue Recovery—Identify underpayments and recover lost revenue with our proven Revenue Data Mining services.

Regulatory Compliance—Strengthen internal compliance initiatives and reduce risk with the help of our expert consulting team.

Custom consulting services that meet your needs.

Focus 11


Uncovering Pharmacy Department Risks and OpportunitiesProactive Measures to Reduce Exposure and Increase Net Revenue

by Gary R. Fong, Pharm. D., Randy Wiitala, BS, MT (ASCP), & Frederick Stodolak

Gary Fong

Pharmacy Departments are often overlooked by Hos-pital Financial Managers for a myriad of reasons, but in-creased audit exposure, escalating drug cost and declining reimbursement now provide the impetus to take a closer look at your hospital’s risk and opportunity.

Hospital Financial Managers may have a false sense of se-curity where Pharmacy revenue is concerned. Comprehensive analyses and audits may shatter this sense of comfort when they demonstrate that outdated costs, improper mark-ups, invalid or missing CPT/HCPCS and NDC codes, unbilled items, undocumented medical necessity, improper descrip-tions and billable units all contribute to the Pharmacy being one of the most difficult departments to manage from a cod-ing, compliance, reimbursement and pricing standpoint.

Long Ignored Hospital Pharmacy Payments Take Center Stage

Maybe the line item descriptions such as Pegfilgrastim, Darbepoetin Alfa, Ondansetron and Intravenous Immune Globuin are simply too intimidating. Maybe the conversion of package quantities from dosages to allowable billable units is simply too daunting. Maybe it’s that Hospital Financial Managers have had false comfort in knowing that Pharmacy prices are often not included in the charge description master but instead are billed based on cost marked up by a factor to cover overhead, uncompensated care, and a profit margin. Maybe it’s that there has been a perception that Pharmacy items are used primarily by inpatients in a hospital and since most rates are based on prospectively set, or negotiated all in-clusive, rates that Pharmacy coding, compliance and pricing isn’t really that important. Whatever the reason that Financial Managers have paid little attention to this department, a few things are certain. With gross revenue levels and cost increases in this department (and medical supplies) exploding over the past decade, improper billing, coding, and pricing for Phar-

macy items can have a material impact on a hospital’s net rev-enue even with a small charge payor mix. And let’s not forget, missing HCPCS codes, payable under Medicare, can result in lost reimbursement. Improper billable units, or poor docu-mentation for medical neces-sity, can be a target for denials. The consequences for ignoring your Pharmacy department coding, compliance, pricing, and reimbursement responsi-bilities can be unbilled items, improperly billed items, un-der billed items, revenue take-backs by payers and even public relations nightmares.

Conducting your Pharmacy Department Audit – Things to look for

There can easily be tens of thousands of line items in your CDM or Pharmacy system for the drugs dispensed in a hospital each year. To perform your audit, you should consider the use of a software package, spreadsheet program, or Access database to manipulate and analyze so many items efficiently and effectively.

Required Data To get started, you’ll need data from your chargemaster,

formulary, and an external benchmark database. The bench- continued on page 12

Randy Wiitala

Frederick Stodolak

12 Focus


mark database should include the most current and compre-hensive drug information providing all NDC (National Drug Code) numbers, codes along with, at a minimum, the related primary and secondary CPT/HCPCS coding, revenue codes, billable units, reimbursement rates, wholesale acquisition cost, average wholesale cost, and manufacturer name. Utilizing the benchmark database as the standard from which to compare your hospitals chargemaster, billing system, and formulary data, you can identify areas of risk and opportunity in the coding, compliance, and reimbursement area.

Areas to Audit and WhyNational Drug Codes CPT/HCPCS Codes UB-04 Revenue Codes Billable Units AWP or WAC (Pricing)

NDC Accuracy

Overview of NDC’sThe National Drug Codes (NDC’s) are managed by the

Food and Drug Administration (FDA). The NDC System is a system that is designed to provide drugs in the United States with a specific 11-digit number that describes the product. Originally created under Medicare to help identify drugs for reimbursement, the usefulness of the system has now become more widespread. Data in the NDC are updated quarterly (March, June, September, and December). The FDA requires

firms to submit updated registered drug lists in June or De-cember of each year (or sooner as new information about a drug becomes available to the firm). Drugs listed under the NDC are identified by an 11-digit number divided into three segments. The first segment, assigned by the FDA, identi-fies the vendor (or labeler) involved with the manufacturing, packaging, or distribution of the drug. Product codes, listed in the second segment, comprise the generic entity, strength, and dosage form. The third segment, or package code, indicates the package size. The manufacturer assigns the second and third segments of the code for a given product.

Importance of NDC AccuracyThe accuracy of the NDC number is the foundation from

which your hospital will assign CPT/HCPCS codes, revenue codes, billable units, descriptions, and prices. This informa-tion drives final payment and external audit risk; it should be clear how important it is to maintain accurate and updated NDC information. In fact, because of the specific, precise na-ture of a drug’s NDC, it has been adopted by CMS as the primary driver in the development of their internal coding, billing and payment crosswalks.

At a minimum your audit initiative in this area should compare the NDC numbers, in your formulary, against that in the benchmark database to determine if the NDC number is valid. You can also compare the descriptions while you’re at it. If your hospital has a link or mapping between the NDC numbers in your formulary, and the billing codes (service codes) used in your billing system or chargemaster, you’ll need to update and maintain accurate mapping between the two systems to ensure that only current, accurate, and valid NDC’s are in use and are properly mapped.

If your hospital has a relatively high utilization by Med-icaid patients you’ll be interested to learn that NDC’s could impact Medicaid payments because Medicaid calculates drug rebates based upon what providers report. Or, if your hospital reports “static” NDC numbers that do not match the purchase records for the actual drug dispensed, you may be subject to increased potential audit risk and public relations problems.

If NDC numbers are improper or invalid, and if your pric-ing is based on the unit cost associated with that NDC, your prices may not adequately represent the actual cost incurred by your organization for the drug purchased and dispensed. From a quality standpoint, bedside dispensing systems rely upon accurate NDC’s to operate at peak efficiency.

Typical Audit FindingsIt is not uncommon when conducting Pharmacy CDM

Audits on the accuracy of NDC’s to find between 15% – 25% of NDC’s in the formulary, and linked systems, to be inactive,


Focus 13


continued on page 14

or out of date. For example, the Medi-Cal program explicitly indicates that the NDC is found on the drug container (vial, bottle or tube). The NDC submitted to Medicaid must be the actual NDC number on the package or container from which the medication was administered. Providers should not bill for one manufacturer’s product and dispense another. It is considered to be a fraudulent billing practice to bill using an NDC other than the one administered.

If there is a disconnect between the NDC that providers report on the claim and the NDC that is actually dispensed, it exposes audit risk to the hospital.

CPT/HCPCS Accuracy

Importance of CPT/HCPC AccuracyReporting accurate CPT/HCPCS is critical for correct and

compliant outpatient reimbursement through Medicare and other payers. Although all payers do not make payments based on the CPT or HCPCS codes, the safe scenario to ensure opti-mum reimbursement is to also ensure that all drugs, as defined by the NDC, have a CPT/HCPCS code assigned when ap-plicable for that NDC.

By comparing the CPT/HCPCS codes assigned in your formulary (and if available in your chargemaster) to each as-signed NDC in the benchmark database for the respective NDC’s, you can identify missing, incorrectly assigned, and/or invalid CPT/HCPCS codes.

Typical Audit FindingsIt is not uncommon when conducting Pharmacy CDM

Audits on the accuracy of CPT/HCPCS codes to find 25% - 35% of a Pharmacy CDM with missing or invalid CPT/HCPCS codes upon the first audit initiative. To the extent that some of those codes represent APC Status Indicator “K” codes payable separately by Medicare, audits have uncovered lost revenue or new incremental revenue. Conversely, if some items are coded improperly for APC payments, your hospital may be at risk of, or, during an audit.

UB Revenue Coding Accuracy

Overview of UB Revenue CodeCMS’ longstanding policy under the OPPS is to refrain

from instructing hospitals on the appropriate revenue code to use to charge for specific services. CMS believes that this al-lows hospital flexibility in their billing and accounting systems and provides the necessary autonomy for hospitals to manage the many variations that are possible when creating a hospital chargemaster for multiple payers and to manage the accumu-lation of costs and charges for completing their Medicare hos-pital cost report.

Importance of UB Revenue Code AccuracyWhile CMS does not require hospitals to use revenue code

0636 (Pharmacy- Extension of 025x; Drugs Requiring Detailed coding (a)) when billing for drugs and biologicals that have HCPCS codes, whether they are separately payable or pack-aged, CMS believes that a practice of billing all drugs and bio-logicals with HCPCS codes under revenue code 0636 would be consistent with National Uniform Billing Committee (NUBC) billing guidelines and would provide CMS with the most com-plete and detailed information for future rate setting.

Aside from Medicare, many other third party payers use specific UB-04 revenue codes to identify high cost drugs eli-gible for carve out payments or increased reimbursement rates. In fact on the website for the drug Proleukin, the manufac-turer recommends that “Documenting IV Bolus PROLEU-KIN therapy under Pharmacy Revenue Code 636 may create the potential for carve-out/add-on payment negotiations.” In summary, whether it is to identify drugs for payment pur-poses, coverage, or cost reporting, accurate and precise UB-04 revenue code reporting can have a significant impact on hos-pital revenue.

Typical Audit FindingsBecause CMS gives providers wide latitude in reporting of

UB-04 revenue codes, chargemaster audits show a very wide variation in reporting practices. In some instances, hospitals have diligently assigned revenue codes to drugs based on the exact type of drug, for example, assigning revenue code 258 “IV Solutions” to all IV solution products in the chargemaster. This practice, while time consuming, gives your claims data the highest level of “granularity” and can be very helpful in contract negotiations with payers. In other cases, the blanket application of the general revenue code 250 “Pharmacy” to all items is used. A downside to this approach is that it can impact your ability to differentiate drugs requiring detailed HCPCS coding or non-covered Self Administered Drugs at the claim level.

Billable Unit Accuracy

Overview of Billable UnitsTo receive proper payment under the Medicare OPPS, hos-

pitals must report all CPT /HCPCS codes and charges for sep-arately payable drugs, in addition to, reporting the applicable drug administration codes. Because CMS bases payment on the HCPCS code reported and the number of billable units, ensuring accuracy is critical for compliant payments. In fact, Recovery Audit Contractors (RACs) continue to target bill-able units for drugs and providers that do not pay close atten-tion will struggle with improper payments.

14 Focus


Importance of Billable Unit AccuracyIn the July, 2010 Update of the Hospital Outpatient Pro-

spective Payment System (OPPS) (Medicare Transmittal 1980), CMS emphasized once again, the importance of billable units. They go on to say “…hospitals and providers are reminded to ensure that units of drugs administered to patients are ac-curately reported in terms of the dosage specified in the full HCPCS code descriptor. That is, units should be reported in multiples of the units included in the HCPCS descriptor. For example, if the description for the drug code is 6 mg, and 6 mg of the drug was administered to the patient, the units billed should be 1. As another example, if the description for the drug code is 50 mg, but 200 mg of the drug was admin-istered to the patient, the units billed should be 4. Providers and hospitals should not bill the units based on the way the drug is packaged, stored, or stocked. That is, if the HCPCS descrip-tor for the drug code specifies 1 mg and a 10 mg vial of the drug was administered to the patient; hospitals should bill 10 units, even though only 1 vial was administered. The HCPCS short descriptors are limited to 28 characters, including spac-es, so short descriptors do not always capture the complete description of the drug. Therefore, before submitting Medi-care claims for drugs and biologicals, it is extremely impor-tant to review the complete long descriptors for the applicable HCPCS codes.”

Typical Audit FindingsBecause payment is tied to each billed unit, RAC contrac-

tors can easily target provider claims to scan for outlier behavior and tie the reported units to improper payments. Often Phar-macy CDM audits show wide variation in accuracy as some hospitals have targeted only those drugs that are payable under the OPPS. By focusing only on payable items, they unwittingly create a “two tiered” compliance policy. In effect, they are send-ing a message via their claim data that they will pay attention to billable unit accuracy only if there is payment tied to the HCPCS code that is reported. Curiously, this same effect does not occur when other ancillary departments (laboratory, physi-cal therapy infusion therapy) have to report billed units based on the HCPCS code description.

AWP or WAC (Pricing) Accuracy

Overview of AWP or WACUnlike other departments where the finance department

determines the price and hard codes that price in the charge-master, most providers determine the final price on the patient bill based on the Wholesale Acquisition Cost (WAC), Average Wholesale Price (AWP)* or the Actual Acquisition Cost.

Importance of AWP or WACAt this time, most Pharmacy systems provide the WAC and

AWP and the ability to mark-up the cost to cover overhead, uncompensated care, shortfalls from payors and a profit mar-gin. Pharmacy Directors often have full responsibility for set-ting Pharmacy charges and operate their own chargemaster with an entirely separate system tailored specifically to meet Pharmacy Department needs. Typically one mark-up factor or a few mark-up factors based on the class of drugs is provided by the finance department and utilized by the Pharmacy.

For many providers the mark-up factors utilized were pro-vided to the Pharmacy many years ago and no longer ade-quately reflect the gross revenue requirements of today. For many others, audits will uncover that the cost information utilized may also be outdated or incomplete. In both these instances the result is improper prices and reimbursement.

You can assess your hospital’s overall charge to cost mark-up factor in this area by comparing it to others in your area and state. Because many financial managers have overlooked Pharmacy Departments for so long, a wide variation is not uncommon; however, utilizing a regional or statewide median should provide an adequate measure of reasonableness. This information can be obtained from CMS via the Medicare Cost Report database.

By applying the mark-up factor(s) that you have elected to use to the current WAC, AWP or Actual Acquisition Cost from the benchmark database, you can calculate new prices and compare the result to that currently being calculated via the formulary system.


*The primary sources of AWP are private drug data com-pendia, with most pharmacies and third party payers using First Data Bank or Medi-Span as their primary source. Due to recent litigation over improper manipulation of the AWP, both First Data Bank and Medi-Span have announced deci-sions to cease the publication of AWPs for drugs no later than September of 2011. Other pricing compendia — such as Gold Standard/Elsevier and Red Book Drug Reference — have pledged to continue publishing AWP. The HHS Office of Inspector General even recommended that Med-icaid no longer use AWP as a benchmark, and many retail pharmacies and drug wholesalers recognize the potentially litigious nature of AWP. As a result, there is an emerging push in the industry to agree upon a new pharmacy re-imbursement benchmark to eventually replace AWP. While nothing is decided at this time, prudent hospitals should begin evaluating their current pricing strategies and con-sider if there are better alternatives to AWP if it is no longer a viable option.

Focus 15


To ensure confidence that your pricing data is reliable, you should also compare the WAC or AWP contained in your for-mulary to that reflected in the benchmark database. This can be accomplished most easily by comparing your current NDC data to your hospital’s actual acquisition cost per unit. You may uncover potential cost savings by comparing your cost to the WAC or AWP information provided in the benchmark database.

Typical Audit FindingsIt is not uncommon after conducting

Pharmacy Chargemaster Audits on the ac-curacy of AWP or WAC, to find a mini-mum of 20% of WAC or AWC data in the formulary to be outdated or missing upon the first audit initiative of this kind. Before adjusting or implementing the new prices, it will be important to determine the gross AND net revenue impact to en-sure that you maintain or increase your net revenue in this department.

It is important to note that most hospi-tals elect NOT to utilize their actual acqui-sition cost because, to the extent that they have negotiated (either directly or through their GPO) favorable pricing, they want to realize the benefit of that lower cost by basing their prices on the standard Whole-sale Acquisition Cost (WAC).

Be ProactiveSo perhaps a proactive approach to

auditing your Pharmacy coding, compli-ance and pricing will uncover expected incremental net revenue or maybe it will uncover outside auditor exposure. In each case financial managers will be fulfilling their fiduciary responsibility by uncover-ing such opportunities or risk today.

About the authorsGary Fong, PHARM D., is Senior Vice

President and Partner at Panacea Health-care Solutions, LLC, Wesley Chapel, Flor-ida, and a Advanced Member of HFMA’s New Jersey Chapter. Gary can be reached at [email protected].

Randy Wiitala, BS, MT (ASCP) is Senior Healthcare Consultant at Medical Learning, Inc, St. Paul, MN specializing in Pharmacy

and Chargemaster auditing and analyses for the firm. Randy can be reached at [email protected].

Frederick Stodolak, is Chairman & CEO of Panacea Health-care Solutions, LLC, Wesley Chapel, Florida, and a Advanced Member of HFMA’s New Jersey Chapter. Fred can be reached at [email protected].

Copyright 2010 Panacea Healthcare Solutions, LLC

We know the risks

We have the solutions

New Jersey’s Leading Hospital/Healthcare Insurance BrokerWe provide our clients with the best combination

of coverage, pricing and risk management.

56 Park Street / Montclair, NJ 07042-2999 / 973.744.8500

Risk Ad_2 7/18/07 4:23 PM Page 1

Focus 16

Member of Commerce & Industry Association of New Jersey

Health Care System Buildingand Networking

In the current health care environment, system building and networking are essential to

success…maybe even to survival. Health care institutions may need to find merger partners.

Physicians and physician organizations may benefit from strategic alliances with other health

care organizations. Other entities in the health care field may be looking for joint venture

partners.

Yet, system building and networking raise complex legal issues. Anti-trust concerns are thorny.Tax and tax-exemption issues abound. And the business aspects of negotiating sucharrangements are far from easy.

Norris McLaughlin & Marcus' health care attorneys are among the most experienced in assistingclients in navigating these difficult waters. Our health care attorneys have handled some of thelargest health care mergers and have been involved with the development of some of ourregion's most successful health care networks. Norris McLaughlin attorneys have alsosuccessfully dealt with some of the most sophisticated business, tax and anti-trust issues insystem and network development.

Please visit us online at www.nmmlaw.com for more information.

Bridgewater, NJ New York, NY Allentown, PA

P: (908) 722-0700 • F: (908) 722-0755

J. Anthony Manger

Ira S. Novak

John J. Eagan

Marion K. Littman

Scott M. Baach

Jill Lebowitz

Matthew R. Sorrentino

Sandra Jarva Weiss

F. Peter Lehr

Ronnie F. Hess

S. Graham Simmons

Cory P. Balliet

Norris McLaughlin & Marcus Health Care Law Group

Focus 17


by Marc Stein, MBA

Seven Elements of a Hospital’s Corporate Compliance Program: Time for an Internal Check-Up

Marc Stein

Based on the increasing scrutiny of regulatory agencies and new compliance initiatives (e.g., False Claims Act, Recovery Audit Contractors, Fraud Enforcement and Recovery Act, Deficit Reduction Act, New Jersey Office of Medicaid Inspec-tor General, etc.), hospitals should perform an evaluation of the effectiveness of their Corporate Compliance Program (CCP). This evaluation should include a review of the seven elements of a comprehensive compliance program as well as the approach to develop a risk assessment and prioritization of compliance activities.

Per the Office of Inspector General of the Department of Health and Human services (OIG), Compliance Program Guidance for Hospitals (“model guidance”), compliance pro-grams are designed to establish a culture within a hospital that promotes prevention, detection, and resolution of instances of conduct that do not conform to federal and state law and fed-eral, state and private payer healthcare program requirements, as well as the hospital’s ethical and business policies. In prac-tice, the compliance program should effectively articulate and demonstrate the organization’s commitment to the compliance process. The existence of benchmarks that demonstrate imple-mentation and achievements are essential to any effective com-pliance program. Eventually, a compliance program should become part of the fabric of routine hospital operations.

The model guidance and other regulations include the fol-lowing seven elements of an effective CCP:

1. Written Standards and ProceduresA vital element of an effective CCP is the development

and dissemination of compliance and ethics standards. Formal standards take the form of a Code of Conduct (Code) and policies and procedures.

The Code should reflect an assessment of the compli-ance risks that have been identified in the hospital. The Code should at a minimum include the following components: (1) a statement of the hospital’s mission and values; (2) a summary of the standards of conduct that are expected of the organiza-tion’s employees; (3) a statement that discipline will be im-

posed for failure to adhere to the Code; and (4) identification of the resources available to the hospital’s employees to ask questions and obtain additional information.

Policies and procedures should be developed and updated to reflect current areas of compliance risk. These policies and procedures should cover issues raised in the annual OIG Work Plans including but not limited to: (1) billing; (2) coding; (3) prohibiting vendor and employment relationships with sanc-tioned entities or individuals, etc.

The hospital should Implement a formal communication program (via web, e-mail or meetings) to Department Heads of changes made in the CCP.

2. Oversight In order to facilitate the CCP, it must have a strong leader.

The second element requires hospitals to designate a high-level employee to be the Chief Compliance Officer (CCO) and oversee all aspects of the CCP. The CCO competencies should meet the standards of the role and make certain that he/she receive the appropriate training - and have adequate time, given other responsibilities, to effectively perform the role and be held accountable.

In addition, other appropriate bodies, (e.g., a Corporate Compliance Committee charged with the responsibility of op-erating and monitoring the compliance program, etc.) should be implemented. The CCO should provide a report to this Committee which should include applicable statistics regard-ing the number of hotline calls, number of employees trained in compliance issues, summary of compliance reports, etc.

3. Education and Training In addition to developing and distributing the Code of

Conduct, employees must understand it. The hospital should develop and implement regular, effective education and training programs for all affected employees. Mandatory in-serviceemployee training and new employee orientation should include a discussion about corporate compliance as well as a required continued on page 18

18 Focus


test. Departmental level reinforcement of compliance training for the specific risk areas during the year should be tracked and captured by the Corporate Compliance Officer. In order to facil-iate the hospital’s compliance training needs, a detailed compli-ance training architecture, including areas of risk and applicable level of employee to be trained should be developed. Training topics should include but not be limited to coding requirements, claims development and submission processes, third party bill-ing policies, medical necessity standards, documentation guide-lines and records requirements, anti-kickback and anti-referral laws, patient confidentiality, system security, etc.

4. Maintenance of a Process for Reporting Exceptions To empower every employee as a member of the compli-

ance team, hospitals should create a reporting mechanism for employees and whistleblowers to voice allegations or concerns without fear of retaliation. The hospital should create and maintain a process , such as a hotline, to receive complaints and an adoption of procedures to protect the anonyminity of complainants and to protect callers from retaliation. The hot-line should be a toll free line available 24 hours per day, seven days per week. The hotline information should be included on the hospital’s website and intranet. The hotline should be rou-tinely checked to ensure it is working. Many hospitals utilize unbiased third-party vendors who offer anonymous telephone and Web site reporting for allegations of fraud, misconduct, and noncompliance.

5. Development of a System to Respond to Allegations of Improper Activities, Accompanied by Appropriate Disci-pline

To set up these rules and standards there must be conse-quences and those consequences should be levied consistently regardless of the employee’s stature within the hospital. This should include, as appropriate, discipline of individuals re-sponsible for failure to detect an offense. A process should be developed to identify procedures to be followed once a com-plaint or question has been received. This process should in-clude the role of the CCO and legal counsel, when appropri-ate, in the detailed investigation.

6. Auditing and MonitoringHospitals should employ a means to audit and monitor in-

ternal systems and verify compliance. Monitoring techniques include review of operations, billing and related functions on-site visits, and interviewing staff members. Audits can be performed by independent auditors/vendors or internal audit staff. This monitoring and reporting of findings should be ad-ministered by the CCO.

The CCO, in conjunction with the appropriate subject

matter hospital stakeholders (including the CEO), should de-velop an overall risk assessment based on his/her evaluation of the healthcare regulatory environment (e.g., OIG Work Plan, Medicare, Medicaid, etc.) taking into consideration the hospi-tal’s operating environment. Based on the risk assessment per-formed by the stakeholders and resource constraints, the CCO should prioritize which audits and monitoring should be per-formed (which can subsequently be re-evaluated as changing conditons/regulations/laws dictate). The CCO then presents the master audit/monitoring plan to the appropriate Corpo-rate Compliance Committee (which might be combined with an Audit Committee) for approval.

In addition, the CCO should develop automated moni-toring systems or manual processes to check compliance rates and implementation effectiveness. This can be summarized on an Executive Scorecard/Dashboard to routinely monitor compliance related activities. This information should be re-ported to the Corporate Compliance Committee. The CCO should reinforce who is responsible to take corrective action, when monitoring reveals exceptions. Roles and responsibilities should be clearly defined to determine the root cause of the problem, determine the method of correction, and communi-cate the appropriate standards more clearly.

7. Response and Prevention Finally, the hospital must respond. Even with standards

and procedures in place and an avenue for employees to voice concerns, progression and improvement will not occur unless the hospital responds to the offense and continues to make concerted efforts toward preventing similar conduct.

ConclusionBased on the recent regulatory activity on the federal and

state level, each hospital can’t afford to sit on the sideline and assume that its CCP is working and meeting all the current regulatory compliance requirements. Hospitals should per-form a diagnostic review of its CCP and evaluate its effective-ness in the current regulatory environment. Hospitals should consider seeking an unbiased external review of their compli-ance processes to limit their exposure to being cited for a non-functioning compliance plan and the financial penalties that are attributable thereto.

About the authorMarc Stein, MBA, is a principal in the New Brunswick office of WithumSmith+Brown, Certified Public Accountants and Consultants. He has over 30 years of senior healthcare financial management, reimbursement, internal audit/compliance and consulting experience. He can be reached at [email protected].


Focus 19


by William H. Maruca

ACOs – Health Reform’s Latest Approach to Costs and Quality

There is a new acronym floating in the increasingly crowded alphabet soup that is healthcare, right next to PPACA. It’s ACO, “Accountable Care Organization,” adopted as a curve-bending strategy in the recently enacted Patient Protection and Afford-able Care Act. Much as HMOs in the 1970s were designed to try to reorient healthcare toward maintenance of health instead of treatment of disease, the ACO concept is intended to place accountability for quality and costs collectively upon those who are believed to have the most control over them – physicians, hospitals and other community providers.

Under PPACA, ACOs may qualify for CMS incentive pay-ments under healthcare reform for achieving improvements in quality and reductions in cost based on risk-adjusted shared savings against historical benchmarks. CMS has predicted that regulations clarifying the scope and requirements of the ACO program will be published in the fall of 2010, and a shared savings program is required by the reform law to go live by January 1, 2012.

So far, ACOs are loosely defined, local delivery systems comprising physicians and the hospitals where they work or admit their patients which provide coordinated care and chronic disease management. Sound familiar? If you’ve been in the business for a while, you may also remember similar claims and goals for integrated delivery systems, gainshar-ing programs, physician-hospital organizations (PHOs), and medical staff-hospital (MeSH) organizations. Payors’ previ-ous approaches included capitation and restricting access to specialists and high-cost services through gatekeeper primary care physicians. What makes the ACO concept different from prior attempts to incentivize management of costs and quality?

One way to distinguish the ACO from its predecessors is to look at what didn’t work in the past. For instance, PHOs and integrated delivery systems were designed around fixed pay-ment models such as capitation or fees for episodes of care and shifted economic risks to providers, putting them into the eco-nomic role of insurers, but did not give them the tools to work together to achieve either financial or clinical goals. Gainshar-ing, where hospitals share a portion of their cost savings with the doctors whose decisions generate those savings, has been limited by a thicket of legislative and regulatory restrictions

and only a handful of narrowly-focused programs have been ap-proved to date, primarily in cardiology. Capitation and primary care gatekeepers have been largely abandoned by the insurance industry as failing to effectively control costs or improve out-comes.

Elliott S. Fisher, M.D., M.P.H., of Dartmouth, in his pa-per “Creating Accountable Care Organizations: The Extended Hospital Medical Staff ” (Health Affairs, Dec. 5, 2006), sug-gested that ACOs avoid the flaw of earlier efforts which incen-tivized individual providers only for the care within their direct control. Instead, ACOs reward shared accountability for the care of a population of patients spread among a hospital, those physicians providing inpatient work at the hospital, and those community physicians whose patients are treated at the hospi-tal (which Fisher calls the “extended medical staff.”)

Design and Structure

There is no single organizational model for developing an ACO. ACOs may be formed and organized by health systems using employed and contracted physicians, by integrated delivery systems, by physician groups (either primary care or multispecialty), or through joint ventures or contractual rela-tionships among providers. Regardless of the organizational structure, an ACO must be physician-led and physician- driven. Physician leadership is critical because an ACO is pri-marily a vehicle for clinical integration, not financial or risk integration. Only physicians are able to develop, monitor and adjust clinical care protocols which can more efficiently use resources based on documented effectiveness.

Qualifying ACOs will be assigned a pool of patients whose care the ACO will be responsible for managing in a cost-ef-fective and clinically appropriate manner. The ACO will need to develop internal mechanisms for monitoring and managing costs and quality which cut across traditional reporting lines and result in a higher degree of clinical interdependence than is typical in a less-integrated medical community.

The PPACA states that any of the following groups of providers of services and suppliers which have established a continued on page 20

William Maruca

20 Focus



mechanism for shared governance are eligible to participate, in accordance with regulations to be developed by the Secretary of HHS:

• ACO professionals in group practice arrangements; • Networks of individual practices of ACO professionals; • Partnerships or joint venture arrangements between hos-

pitals and ACO professionals; • Hospitals employing ACO professionals; • Such other groups of providers of services and suppliers

as the Secretary determines appropriate.

ACOs Under Health ReformSection 3022 of PPACA requires HHS to establish a shared

savings program under which qualifying ACOs may be eligible for incentive payments. The criteria in the statute, which will need to be further defined by regulation, include:

• The ACO must be willing to become accountable for the quality, cost, and overall care of the Medicare benefi-ciaries assigned to it.

• Minimum three-year agreement with CMS is required. • The ACO must establish a formal legal structure to re-

ceive and distribute payments for shared savings. • The ACO must include a sufficient number primary

care professionals to manage the ACO’s panel of benefi-ciaries. (Nobody knows what ratios will be adopted, but California currently requires at least at least one full-time equivalent primary care provider for each 2,000 enroll-ees.[1]) At a minimum, each ACO will be assigned at least 5,000 beneficiaries in order to be eligible.

• The ACO must provide HHS with information regard-ing its participating professionals to support the assign-ment of Medicare fee-for-service beneficiaries, the imple-mentation of quality and other reporting requirements, and the determination of payments for shared savings.

• The ACO must have in place a leadership and manage-ment structure that includes clinical and administrative systems.

• The ACO must define processes to promote evidence-based medicine and patient engagement, report on quality and cost measures, and coordinate care, such as through the use of telehealth, remote patient monitor-ing, and other such enabling technologies.

• The ACO must be able to demonstrate that it meets patient-centeredness criteria, such as the use of patient and caregiver assessments or the use of individualized care plans.

ACOs will be required to measure and report their prog-ress to HHS, including clinical processes and outcomes; pa-tient and caregiver experience of care; and utilization, such as rates of hospital admissions for ambulatory care sensitive con-ditions. Data reporting requirements may include care transi-

tions across health care settings, including hospital discharge planning and post-hospital discharge follow-up by ACO pro-fessionals.

One significant gap in the scheme is how patients will be assigned to ACOs’ rosters. PPACA only instructs the Secretary to determine an “appropriate method” to assign Medicare fee-for-service beneficiaries to an ACO based on their utilization of primary care services provided by an ACO professional.” It is not clear whether CMS will be able to assign a fee-for- service patient to the ACO which includes the patient’s PCP, but to the patient, there may be no economic impact. If a fee-for-service Medicare beneficiary does not want to be in an ACO, perhaps because of perceptions of pressure to ration care, it is not clear if he or she will be permitted to opt out. ACOs may not select their beneficiaries based on risk criteria – if they are caught taking steps to avoid patients at risk in order to reduce the likelihood of increasing costs to the ACO, they may be subject to sanctions including termination from the program.

Most problematically, beneficiaries may not be locked in to receive care only through ACO members, but the ACO remains accountable for the cost and outcomes of their benefi-ciaries’ care. As the rules are developed, look for heavy lobby-ing to permit ACOs to either limit beneficiaries’ access to out-of-network providers or to carve out negative consequences of such utilization from shared savings formulas. Either step may require further Congressional action, and anything that appears to limit patient choice would be hard to sell politically.

Payment Mechanisms:

The shared savings program contemplates that ACO mem-ber providers will continue to be paid under the original Medi-care fee-for-service program under parts A and B in the same manner as they would otherwise, and the ACO would poten-tially receive additional bonus payments for shared savings if it meets quality performance standards and the estimated average per capita Medicare expenditures under the ACO for Medicare fee-for-service beneficiaries for parts A and B services, adjusted for beneficiary characteristics, beats the applicable benchmark by a percentage to be specified by HHS, which percentage may vary based on the number of Medicare fee-for-service benefi-ciaries assigned to the ACO. This is the first step toward align-ing incentives – the ACO’s traditional Medicare payments are not at risk but the ACO may earn bonus payments for achiev-ing cost savings. It looks a lot like the hospital-specific gain-sharing programs of the past, but the cost savings are funded by Medicare, not the hospitals.

Several alternative risk-shifting methods are contemplated by PPACA. The Secretary of HHS may offer a partial capita-tion model in which an ACO is at financial risk for some, but not all, of the items and services covered under Medicare parts

Focus 21


A and B. The partial capitation model may be limited to ACOs that are highly integrated systems of care and to ACOs capable of bearing risk, as determined to be appropriate by the Secre-tary. It is anticipated that such model would offer greater upside opportunities in exchange for bearing more downside risk.

Another alternative method is bundled payments for epi-sodes of care. HHS is authorized to develop payment models that identify certain qualifying medical conditions and bundle acute care inpatient services, physicians’ services delivered in and outside of an acute care hospital setting, outpatient hospital services, including emergency department services and post-acute care services, including home health services, skilled nursing services, inpatient rehabilitation services, and inpatient hospital services furnished by a long-term care hos-pital, along with any other services the Secretary determines appropriate. An episode of care means the period that includes the 3-day window prior to admission, the hospital stay, and the 30 days following the patient’s discharge. Applicable con-ditions are to include a mix of chronic and acute conditions, a mix of surgical and medical conditions, conditions for which there are opportunities for cost savings and quality improve-ment, those for which there is significant variation in the number of readmissions and the amount of expenditures for post-acute care spending, and high volume conditions with high post-acute care costs.

One problem with the bundled payment model is there are no incentives to avoiding an episode of care, i.e. by aggressive preventative care. How the system will reward an ACO for managing a patient who avoids a hospital stay due to effective preventative services remains unanswered.

The Devil in the Details:

As noted in many media reports, the phrase “the Secretary shall” appears 976 times in the health reform law. The Secre-tary of Health and Human Services must put a lot of flesh on the bones of the PPACA before the shared services program becomes a reality. Among the many unanswered questions are:

• How to assign patients to ACOs; • How to set benchmarks; • What percentage savings from those benchmarks will

qualify for payments; • What quality measurements and criteria will protect

patients from rationing; • How to avoid cost shifting by non-governmental payors; • How to adjust payments for patient population risk

variations; • How to account for out-of-network services; • What to do about mobile patient populations such as

“snowbirds” who spend winters in the south and the rest of the year in the north? Which ACO gets credit for their cost savings or dinged for their utilization?

• How much IT and governance infrastructure will be needed to track the statistics required to qualify for shared savings, and what will it cost;

• Will independent or semi-integrated physicians, hospi-tals and other providers be able to develop the level of trust needed to cooperate to succeed in this new envi-ronment?

Some of these questions can and will be answered by the Secretary, but others, particularly those requiring the coopera-tion of traditional competitors, cannot be imposed by Uncle Sam and must evolve organically.

What Now?

Although many of the details about ACOs remain murky, one clear message is that success will require further integra-tion of clinical decisions, measurement of costs and outcomes, and improved information gathering and reporting capabili-ties. Larger hospital networks and larger group practices may have an apparent head start due to their size and top-down organizational structure, but independent players who can collaborate, integrate and make informed decisions may ul-timately be better positioned to take full advantage of these opportunities. The long-predicted death knell for the mom-and-pop small practice may not have arrived, but by working together to integrate clinically as well as economically, well-organized physician practices may be best ready to lead the development of ACOs.

About the authorWilliam H. Maruca is a partner with the Pittsburgh office of the law firm of Fox, Rothschild LLP. He is a past Chairman of the American Health Lawyers Association Fraud and Abuse, Self-Referral and False Claims Practice Group and a member of the Pennsylvania Bar Institute’s Health Law Advisory Committee. His practice is concentrated in the area of healthcare and he is a frequent national speaker and author on healthcare topics. He can be reached at [email protected]

This article first appeared in the Allegheny County Medical Society Bulletin.

© 2010 Fox Rothschild LLP. All rights reserved. All content of this publica-tion is the property and copyright of Fox Rothschild LLP and may not be reproduced in any format without prior express permission. Contact [email protected] for more information or to seek permission to reproduce content. This publication is intended for general information purposes only. It does not constitute legal advice. The reader should consult with knowledgeable legal counsel to determine how applicable laws apply to specific facts and situations. This publication is based on the most current information at the time it was written. Since it is possible that the laws or other circumstances may have changed since publication, please call us to discuss any action you may be considering as a result of reading this publica-tion.

Focus 23


Childhood Obesity – The Challenge for Our Generation by Paige Litten

Linda is a single mother, working hard to earn money for her children. She works so much that she doesn’t have time to exercise, or to make sure that she is consuming a balanced diet. She sends her children off to school each day with lunch money, unaware that the majority of the food served in the caf-eteria consists of mainly fried food and soda. Linda tells her kids not to play outside after school, as she will not be home from work yet to watch them. Her children then spend hours after school sitting on the couch, watching television that is constant-ly showing food commercials. When Linda’s day at work is final-ly over, she is exhausted. Not only is Linda too tired to cook dinner, but also she does not want to spend her hard-earned money on expensive produce. For dinner, Linda decides to pick up McDonald’s.

Linda’s lifestyle is far too common, so many people don’t think twice about it. The truth is, however, that all of the factors previously described combine to cause a great, rapidly growing disease: obesity. From 1990 to 2008, the obesity level in the United States rose from less than 19% to 32.8% in some parts of the country. This is not the only alarming statistic: according to a 2005 study, re-searchers found that kids today may live two to five years less than their parents did because of obesity.1 Because the cause of this epidemic lies in so many different areas, America as a whole must completely change its lifestyle to confront it.

The modernization of society, combined with human evolutionary predispositions, has fueled a transition from a healthy-weight to an over-weight population. Although most of the weight-gains have been fairly recent, a main cause of obesity can be linked back as far as the industrial revolution. During this time, women left the kitchen where they spent time preparing healthful meals, and went out to find jobs in the world.2 In addition, after World War II, as the country was thriving, marketing reached a climax. Within this newfound commercialism, the food industry targeted many individuals, who would soon show the physical effects of the successful marketing.3 The actions of previous generations not only in-fluenced the habitual behavior of Americans today, but they even affected the genetics of the current population. Scien-tist Lemonick reported in 2004 that human beings evolved to

crave high calorie foods like fats and sugars.4 As a result of the eating habits of past generations of Americans, and the current marketing, the country today is suffering.

Although the direct causes of obesity are multiple, one major contribution to the outbreak of this epidemic is the quanti-ty of food being consumed today is increasing, while sensi- tivity to the quality of food is decreasing. Claudia Kalb de-scribes America’s pattern: “When McDonald’s opened in the 1950s, a soda weighed seven ounces, according to a study in the Journal of the American Dietetic Association; today, 7-Eleven

serves a behemoth 44-ounce Super Big Gulp, which has its own fan club on Facebook.”5 These drastic fluctuations in quantity are biologically unneces-sary, and only contribute to the fact that Americans today do not have a good idea of portion size. In addition, when food portions increase and prices remain the same, people believe they are getting a better value and, thus, feel financially obliged to order the larger size. While many Americans are satisfied with the 44-ounce drink that costs a small price, they do not realize how unhealthy the drink is. In America’s Unhealthy Lifestyle:

Supersize It!, Ellyn Sanna comes up with the perfect way to phrase the eating pattern: “Americans eat with their eyes, but the French eat with their noses.” Europeans mainly care about the quality of their food, and many are repulsed by the large portions served in the United States. Americans, on the other hand, do not care as much about what the food tastes like, but care about how much food is in front of them. This habit of constantly wanting more food is unhealthy, and is a large con-tributor to obesity.

However, contrary to common belief, becoming over weight is not only an effect of eating too much food. Duncan describes, “Animals rarely get fat, even when food is abundant, unless they are old and domesticated. Young people do all too frequently.” Obesity does stem from over-eating, but it is also the result of unhealthy eating patterns. In the Agriculture In-formation Bulletin, Lisa Mancino observes, “over-weight and obese women go significantly longer intervals between meals than healthy-weight women.”6 This shocking statistic shows continued on page 24

“If the average school day is only about six hours, why do snack foods or beverages need

to be sold at all?” Making snack foods available when

they are not needed teaches stu-dents, from a young age, to eat

when they are not hungry.

24 Focus


that being overweight not only has to do with quality and quantity of the food, but with the frequency that the food is consumed. Many try to pin the start of obesity on one or two reasons, but, in reality, obesity is caused by more than just two factors.

While many do not realize it, finances play a major role in influencing the weight of people in the United States. This observation is true for a number of reasons. First, the most fattening and unhealthy ingredients are the least expensive. For example, hydrogenated vegetable oil is made by adding hydrogen atoms to oil. This oil is used as a cheap substitute for butter, and it also contains many trans fats.2 Because un-healthy food costs little, while fresh fruits and vegetables are often extremely expensive, lower- income families are often not even financially capable of choosing the healthy option. Lisa Mancino, author of “The Role of Economics in Eating Choices and Weight Out-comes”, examines the health patterns within different income groups. “In-dividuals with higher incomes tend to make greater investments in their own health.”6 Furthermore, because education is highly related to income, individuals with higher income gen-erally have had a better education. Therefore, since better-educated peo-ple know more about eating healthfully and exercising, they are less likely to become obese.

In addition to the high prices of healthy food, the profit interests of individuals working in the food industry also con-tribute to the growing weight problem. Grocery stores set a person up for impulse buys, which, in turn, contribute to an obese population. In Stuffed, Hank Cardello describes the ma-nipulative way a grocery store is organized: “South Beach Diet products produced by the same manufacturer, were directly adjacent to the Oscar Mayer kids’ foods on the refrigerated shelves.”7 Thus, the busy mom on a diet impulsively buys fast food for her kids. Also, as unhealthy foods are less expensive to obtain and store, the food industry makes sure that none of their ingredients are better than absolutely necessary, as they try to squeeze out every last dollar.

Although some food companies have recently attempted to produce healthy options, such as KFC’s grilled chicken and Coca Cola’s mini 7.5 ounce can, these efforts are still aimed at competing with companies marketing to health-conscious people, as opposed to a general concern for the population.

Kelly Brownell, head of Yale’s Rudd Center for Food Policy and Obesity, says:

The country defaults to give the industry the benefit of the doubt, Industry says you don’t need to regulate us; we’ll police ourselves. The tobacco industry abused that with God knows how many lives as a consequence. To expect the food industry to be different may be wishful thinking.

Numerous studies have shown that the eating habits estab-lished during childhood are the habits the individual continues throughout his or her adult life. For this reason specifically, in order to prevent weight gain in the future, the United States should be focusing on teaching children good eating habits, and providing them with healthful foods. However, by providing children with access to unhealthy food in school, the

country is doing the opposite. In the mid 1940s, President Tru-man came up with the National School Lunch Program to feed hungry children. Today, this same organization feeds 31 million kids that do not need it.5 While this pro-gram is being over-used, it is also serving mainly junk food to children. Claudia Kalb reports, “Al-most 42 percent of schools do not offer any fresh fruits or raw vege-tables on a daily basis.”5 In addi-tion, schools have begun to care more about their own budgets

and less about the health of their students. Many schools na-tionwide have signed contracts with different soda companies, promising the companies exclusive access to the district in return for money.8 In addition to serving unhealthy food in the cafe-teria and having high-sugar soda machines, many schools have recently added vending machines in the hallways filled with snacks. Mary Story, director of the Robert Wood Johnson Foundation’s Healthy Eating Research, asks a simple question: “If the average school day is only about six hours, why do snack foods or beverages need to be sold at all?”5 Making snack foods available when they are not needed teaches students, from a young age, to eat when they are not hungry.

The growing popularity of television has also had a bigger effect on the weight of the American population than many people realize. Because it is often not safe for children in lower- income neighborhoods to play outside, they watch televi-sion frequently. This extra time in front of the television takes away from the time children should be active.3 Not only does television detract from the amount of daily exercise the aver-age person should be getting, but it also subjects children to numerous food commercials. Tom Corwin describes a study about how commercials can affect one’s appetite:


Above all, the actions of eachindividual need to change. The government can onlydo so much; the American

population needs to recognize how serious obesity is, and must change

their lifestyles to confront it.

Focus 25


In the study published last year in Health Psychology, Yale researchers showed two groups of children a car-toon, one with food ads and one without, and provided snacks. The children watching foods ads ate 45 percent more than the other group.9

This study shows that because most television shows are packed with food commercials, people subconsciously crave more food. The combination of lack of exercise and a larger appetite caused by television increases the weight of all Ameri-cans nationwide.

As obesity spreads, the problems associated with the disease increase exponentially. The government has recognized this epidemic, and taken steps to attempt to stop the spread of obesity. First Lady Michelle Obama is taking an aggressive approach at tackling the crisis, as she is not only planting fresh fruit and vegetables on the White House lawn, but she is also taking time to dedicate government money to help stop obesity and promote healthy living.1 The First Lady isputting $400 million in tax credits towards making sure there are grocery stores and other healthy foods available in areas where people rely on gas stations and convenience stores for food. These larger grocery stores will not only carry more healthy food options, but they will also be able to charge less for them. Michelle Obama is not stopping there; she is putting $25 million towards the renovation of schools’ kitchens, and replacing their deep-fryers with different types of equipment that will be able to serve more fresh produce.1 The first lady is also partnering with the American Academy of Pediatrics, advising and urging doctors nationwide to think of obesity as an actual illness, and to write exercise and eating “pre-scriptions” for their patients.5 In the Wall Street Journal, JeanSpencer describes how President Barrack Obama is recognizing the obesity crisis: “The health bill President Barrack Obama signed into law… requires that restaurant chains post calorie counts for all the food items they sell. The law covers any chain with at least 20 outlets, amounting to more than 200,000 restaurants nationwide.”2 This calorie posting may cause Americansto rethink eating out, and may encourage them to return to home-cooked meals more often.

Despite the aggressive actions the Obama family is taking to help reshape the American population, they are not enough. There are still numerous possible solutions that need to be con-sidered before the citizens of the United States are once again at a healthy weight. For example, if the price per calorie of junk food goes up, people will consume less junk food and manufacturers will make the same amount of money.7 Dun-can also cites a great idea for promoting healthy living: “The health secretary, Tommy Thompson, is trying to…allow health companies to give discounts to people on fitness programs.”2 Rewarding individuals for fitness programs may help promote

incorporating exercise into daily life. In addition, every state should make sure that children are not capable of making un-healthy decisions in the cafeteria at school.2 The government should also find a more effective way of educating people about different types of unhealthy foods. When people go out to eat, they don’t order ingredients like hydrogenated oils and trans fats; they order hamburgers and fries.7 If the government ex-plained the cause of obesity in terms the average person could relate to, as opposed to using lengthy ingredient names, it would be more effective in getting the point across.

Above all, the actions of each individual need to change. The government can only do so much; the American population needs to recognize how serious obesity is, and must change their lifestyles to confront it. For example, “if a person cut or burned just 100 extra calories a day—by replacing soda with water, say, or walking to school, it would lead to a significant weight loss over time: more than 10 pounds a year.”11 Americans need to get more physical activity, eat more health-fully, and make sure their children are doing the same. Obesity is a serious disease on the uprising – second, after smoking – as the leading cause of preventable death in America. Every citizen in the United States must stand together to tackle the disease, before it makes a permanent dent in the nation and leaves a legacy of worsening the health for future generations.

About the authorPaige Litten is currently beginning her senior year in high school in Moorestown, New Jersey. Paige wishes to thank her honors English teacher, Mrs. McDowell, for her guidance and encourage-ment in drafting this article.

1Hall, Mimi, and Nanci Hellmich. “First Lady Says: ‘Let’s Move’ on Child Obesity.” USA Today 9 Feb. 2010: A. 1. SIRS Researcher. Web. 27 Mar. 2010.2Duncan, Emma. “Spoilt for Choice: A Survey of Food.” The Economist [London, England] 13 Dec. 2003: n. pg. SIRS Researcher. Web. 18 Feb. 2010.3Ruskin, Gary. “The Fast Food Trap.” Mothering Nov.-Dec. 2003: 34-44. SIRS Researcher. Web. 17 Mar. 2010.4Sanna, Ellyn. America’s Unhealthy Lifestyle: Supersize It! Illus. Michelle Bouch and MK Bassett- Harvey. Broomall: Mason Crest Publishers Inc., 2006. Print.5Kalb, Claudia. “Culture of Corpulence.” Newsweek 22 Mar. 2010: n. pg. SIRS Researcher. Web. 31 Mar. 2010.6Mancino, Lisa, Biing-Hwan Lin, and Nicole Ballenger. “The Role of Eco- nomics in Eating Choices and Weight Outcomes.” Agriculture Information Bulletin Sept. 2004: iii-18. SIRS Government Reporter. Web. 25 Feb. 2010.7Cardello, Hank, and Doug Garr. Stuffed. Ed. Matt Harper. New York: HarperCollins Publishers, 2009. Print.8Parker-Pope, Tara. “Eat Less, Weigh Less? Not Necessarily.” International Herald Tribune 4 Mar. 2010: 9. SIRS Researcher. Web. 27 Mar. 2010.9Corwin, Tom. “Food, Beverage Ads on TV Could Spur Overeating.” Augusta Chronicle 6 Feb. 2010: n. pg. SIRS Researcher. Web. 29 Mar. 2010.10Spencer, Jean, and Shirley S Wang. “Coming to the Menu: Calorie Counts.” Wall Street Journal 24 Mar. 2010: p. A. 4. SIRS Researcher. Web. 29 Mar. 2010.11Parker-Pope, Tara. “Eat Less, Weigh Less? Not Necessarily.” International Her- ald Tribune 4 Mar. 2010: 9. SIRS Researcher. Web. 27 Mar. 2010.

26 Focus


The Centers for Medicare and Medicaid Services (CMS) recently released the final rule governing the eligibility re-quirements for the electronic health record (EHR) incentive program. The guidelines of the EHR incentive program show both the Medicare and Medicaid incentive calculations use charity care charges to develop an add-on to payments. In the past, charity care, as reported on the S-10 worksheet of the Medicare cost report, did not have any influence on a hospi-tal’s Medicare reimbursement, leading some hospitals to either neglect the form S-10 or not fill it out accurately. In order to receive the maximum incentive payment for which a hospital is eligible, special care must be taken when reporting charity care on the Medicare cost report.

CMS will be implementing a new version of the Medicare cost report (CMS 2552-10) for cost reporting periods begin-ning on or after May 1, 2010. For most New Jersey hospitals, which operate on a calendar year, this means the new cost re-port will be used beginning in 2011. Until then, the majority of New Jersey hospitals will continue to use the older version of the Medicare cost report (CMS 2552-96). This is important to note as CMS will use the most recently submitted 12-month cost report once the hospital has qualified as a meaningful user to determine the preliminary incentive payments. For exam-ple, this means for a hospital which qualifies as a meaningful user as of October 1, 2010 CMS will use data from the hospi-tal’s 2009 cost report, which would be on the CMS 2552-96 form, to calculate a preliminary incentive payment, scheduled to begin in May 2011. CMS will then calculate a final incen-tive payment and reconcile it against the preliminary incentive payment. The final incentive payment, according to the rule, will be “using data from the first 12-month cost reporting pe-riod that begins after the start of the payment year.” Since the first payment year possible begins with calendar year 2011, the final incentive payment will be calculated using data from the CMS 2552-10 version of the cost report.

In the final rule, CMS states they will be taking charity care charges from worksheet S-10, line 22 on the CMS 2552-96 version of the cost report. On the CMS 2552-10 version

of the cost report CMS will use line 20 of the revised S-10 worksheet. According to the rule line 20 is “the most accurate measure of charity care charges as part of the hospital’s overall reporting of uncompensated and indigent care for Medicare purposes.” Line 20 should include charity care charges and non-Medicare bad debt, which CMS defines as the following:

Charity Care: “[h]ealth services for which a hospital dem-onstrates that the patient is unable to pay…[and] results from a hospital’s policy to provide all or a portion of services free of charge to patients who meet certain financial criteria.”

Non-Medicare Bad Debt: “[h]ealth care services for which a hospital determines the non-Medicare patient has the finan-cial capacity to pay, but the non-Medicare patient is unwilling to settle the claim.”

Hospitals need to be aware of the accuracy of the charity care figure reported and ensure it includes the proper amounts for charity care and non-Medicare bad debt. CMS explains in the rule that the Medicare contractor (Highmark) has the ability to obtain charity care data elsewhere and use it to verify the accuracy of the charity care reported on the S-10. If the MAC finds the hospital did not report charity care properly they have the right to set the revenue ratio equal to 1 in the Medicare and Medicaid incentive calculation, zeroing out any charity care add-on.

The New Jersey Hospital Association (NJHA) has run a preliminary analysis on the amount of incentive payments New Jersey can expect to receive. Statewide NJHA estimates as much as $500 million dollars may flow to New Jersey hos-pitals as a result of Medicare and Medicaid EHR incentive payments. The charity care add-on is an integral part of these payments. NJHA has estimated if all New Jersey hospitals disregard reporting charity care charges on the S-10 form it would result in upwards of $30 million in incentive payments lost. The following example shows the calculation of a Medi-care and Medicaid incentive payment for an average hospital in New Jersey with and without charity care reported:

Charity Care Matters for Hospital EHR Incentive Payments

by Stacey Bigos

Stacey Bigos

Focus 27


Hospital A:Total Discharges: 16,686Total Charges: $1,121,611,205Total Charity Care Charges: $72,910,307 or $0Total Days: 77,815Medicare Days: 38,360Medicaid Days: 11,422Average Growth Rate: 2.5%


Medicare Incentive CalculationWith Charity Care Charges = $72,910,307

Base Amount: $2,000,000

Qualifying Discharges: 15,537If discharges > 23,000 then21,851, else discharges - 1,149

Discharge-related Amt: $3,107,400$200 per Qualifying Discharge

Revenue Ratio: 0.935If Charity Care charge = 0, then 1; else(charges – Charity Care charges)/charges

Medicare Share Ratio: 0.527Medicare Days / (Total Days * Revenue Ratio)

Year 1 Payment: $2,692,811(Base Amt + Discharge Related Amt) *Medicare Share Ratio

Year 2 Payment: $2,019,608(Year 1 Payment * 0.75)


Year 4 Payment: $673,203(Year 1 Payment * 0.25)

Total 4 Year Incentive: $6,732,027

Medicare Incentive CalculationWith Charity Care Charges = $0


Qualifying Discharges: 15,537If discharges > 23,000 then21,851, else discharges - 1,149

Discharge-related Amt: $3,107,400$200 per Qualifying Discharge

Revenue Ratio: 1If Charity Care charge = 0, then 1; else(charges – Charity Care charges)/charges

Medicare Share Ratio: 0.527Medicare Days / (Total Days * Revenue Ratio)

Year 1 Payment: $2,517,765(Base Amt + Discharge Related Amt) *Medicare Share Ratio



Year 4 Payment: $629,441(Year 1 Payment * 0.25)


As demonstrated from the examples negligence in reporting charity care would cost Hospital A over $500,000 in combined Medicare and Medicaid incentive payments over four years. Any hospital participating in the EHR incentive program must ensure their S-10 worksheet is completed as accurately as pos-sible. Failure to do so will certainly result in reduced incen-

tive payments over the course of the program. With enhanced scrutiny on the reporting of charity care and Medicare bad debt New Jersey hospitals can take advantage of the full benefit of the EHR incentive program.

About the authorStacey Bigos is a healthcare data analyst in the Health Economics department of the New Jersey Hospital Association in Princeton, NJ. She can be reached at [email protected].

See next page for more information.

28 Focus



Medicaid Incentive CalculationWith Charity Care Charges = $72,910,307


Revenue Ratio: 0.935If Charity Care charge = 0, then 1; else(charges – Charity Care charges)/charges

Medicaid Share Ratio: 0.157Medicaid Days / (Total Days* Revenue Ratio)

Qualifying Discharges Year 1: 15,537If discharges > 23,000 then 21,851, else discharges - 1,149

Qualifying Discharges Year 2: 15,954If (discharges* (1 + growth rate) ) > 23,000 then 21,851; else (discharges* (1 + growth rate) ) – 1,149

Qualifying Discharges Year 3: 16,382If (discharges* (1 + growth rate) )2 > 23,000 then 21,851; else (discharges* (1 + growth rate) ) – 1,149

Qualifying Discharges Year 4: 16,820If (discharges * (1 + growth rate) )3 > 23,000 then 21,851; else (discharges* (1 + growth rate) ) – 1,149

Discharge Related Amt Year 1: $3,107,400$200 per Qualifying Discharge




Year 1 Payment: $801,806(Base Amt + Discharge Related Amt Year 1)*Medicaid Share Ratio





Medicaid Incentive CalculationWith Charity Care Charges = $72,910,307


Revenue Ratio: 1If Charity Care charge = 0, then 1; else(charges – Charity Care charges)/charges

Medicaid Share Ratio: 0.157Medicaid Days / (Total Days* Revenue Ratio)

Qualifying Discharges Year 1: 15,537If discharges > 23,000 then 21,851, else discharges - 1,149

Qualifying Discharges Year 2: 15,954If (discharges* (1 + growth rate) ) > 23,000 then 21,851; else (discharges* (1 + growth rate) ) – 1,149












Focus 29


Ask the Ethics Guy®!Five Easy Principles?It’s not enough to know what to do. Understand-ing why is important, too, so the Ethics Guy explores the deceptively simple guidelines that govern behavior

Bruce Weinsteinby Bruce Weinstein, Ph.D.

As a professional ethicist, my responsibility is not merely to explain what we ought to do, but, perhaps more importantly, to say why we ought to do it. My ethical obligation to you is to provide good reasons for how we ought and ought not to act.

For the next several columns, I will present an account of the five fundamental ethical principles that are the foundation of right conduct in any arena of your life. They are:

•Donoharm•Makethingsbetter•Respectothers•Befair•BecompassionateThese principles reveal the secret to living a rich, satisfying,

and happy life, and we have known about them for more than 5,000 years. Every religious tradition in the world teaches them, as do parents in every country. Without them civilization would be impossible because there would be nothing but chaos everywhere. These principles have a transforming effect on who we are and where we go in life, and for that reason, we can rightly refer to them as “life principles.”

Values We’re Tempted to IgnoreYou might wonder, “If these principles are so commonplace,

why should I waste my time reading a column about them?” It’s true that they’re commonplace, but it’s also true that in our hectic, overcommitted lives, we get so caught up in the details of getting through the day that it’s easy to forget how important these principles are in everything we do. We’re also tempted every day to ignore them and to place value on things that ultimately aren’t that important. So taking a few steps back to consider these principles is a helpful thing to do.

Yes, they are simple, but too often we let fear, anger, or other negative emotions get us off track from following these principles, and it’s sometimes difficult to get back to where we want to be. For example, how often do we really keep “Do no harm” in mind during our daily interactions with people? If a co-worker is nasty to us, aren’t we tempted to return the

nastiness and tell ourselves, “Serves them right?” Do we always keep the principle of fairness front and center

in our thinking? If so, how do we explain our choice at work to surf the Internet, make personal phone calls, and take a sick day when we’re feeling fine?

On the face of it, the principles are about making a difference in the lives of other people. To this extent, taking them seriously seems like something we have to do, something we ought to do, something that, quite frankly, we’d rather not do.

Central to HappinessWhat we’ll discover, however, is that making ethics our

central concern is actually the best way to lead a richer, more fulfilled life. A life that helps us get the things we want: a job we love, the right partner, and a comfortable place to live. By taking ethics seriously, we serve as role models to our children and increase the chances that they will go into the world and make us proud.

Recent scandals in the news show the risks we take when we neglect these principles: public humiliation, shame, and in some cases a lengthy visit to prison. But the main reason for taking ethics seriously is not the dangers of failing to do so, but rather because it’s the right thing to do.

The path to a happier, more fulfilled life lies in becoming reacquainted with the principles of ethics, which tell us how we should treat one another. When we act with integrity, we feel better about ourselves, and we then create the conditions for making many wonderful choices in our own lives.

Just as a house needs a strong foundation so that it can do what it was meant to do, society needs a strong moral foundation to function effectively. The most fundamental building block of any society is Principle No. 1: Do no harm. This is both the most important of the five ethical or “life” principles and the easiest to put into action. It is the most important, because we would live in constant fear if we could continued on page 30

30 Focus


not trust others to take the principle seriously. It is the easiest of the five principles to apply to our lives because in most cases, all we have to do is…nothing.

The Ethics of Getting InvolvedThe ethics of getting involved requires that we take action so

that harm will not occur to someone else, and thus a corollary of “Do no harm” is “Prevent harm.” When we’re at a cocktail party and we see an obviously inebriated person about to leave and drive away, the right thing to do is to prevent a foreseeable accident, which can mean taking the person’s keys away or arranging for someone to take him or her home.

Edmund Burke once said, “All that is necessary for evil to flourish is for good [people] to do nothing.” When we witness someone else doing something they shouldn’t be doing, it may

be easier to do nothing, but the easiest thing to do isn’t always the right thing to do.

When we take the high road, we give a gift to others—and ourselves. It’s the greatest gift of all. Next week, we’ll consider whether simply avoiding harming other people is sufficient for living an ethical life.

About the authorDr. Bruce Weinstein is the public speaker and corporate consultant known as The Ethics Guy. His new book, Is It Still Cheating If I Don’t Get Caught?, (Macmillan/Roaring Brook Press) shows teens how to solve the ethical dilemmas they face. Follow Weinstein on Twitter at TheEthicsGuy. For more information, visit TheEthicsGuy.com.


New MembersAnnMarie TreppiediSelf Pay Solutions LLCCOO(973) [email protected]

James L. JohansenARMDSManager(973) [email protected]

Colleen DiClaudioCommunity HealthCare Director of Business Services(856) [email protected]

Ashley R. FergusonSomerset Medical CenterProvider Reimbursement Specialist (908) [email protected]

Ann-Marie McWilliamsAetnaManager(732) [email protected]

Jennifer L. SmithChildren’s Specialized HospitalOffice Manager, Ambulatory Care Center(908) [email protected]

Jennifer BarrSomerset Medical CenterFinancial Analyst(908) [email protected]

Michael McQuaidMcKessonClient Executive(978) [email protected]

Michael DiFrancoGrant ThorntonAudit Senior Manager(215) [email protected]

Ingo JurkNestle HealthCare NutritionStrategic Accounts Leader(973) [email protected]

Robert BrittsAlacriti, Inc.Healthcare Services, Director(732) [email protected]

Brian K. BuchananPricewaterhouseCoopers LLPCPA(973) [email protected]

Tina FordBESLER ConsultingSenior Manager(732) [email protected]

Victor HinojosaCustom House, A Western UnionDirector(902) [email protected]

Oliver LewisJP MorganExecutive Director(973) [email protected]

Susan HatchVirtuaAVP Internal Audit & CCO(856) [email protected]

Karen KassarPricewaterhouseCoopers LLPSenior Manager(973) [email protected]

Jay RajuIBMBusiness Development(609) 647 [email protected]

Angela P. CraparottaPrinceton House Behavioral HealthManager, Utilization Management(609) [email protected]

Rosemary BainOnsite Neonatal PartnersSenior Accountant(856) [email protected]

Constanzia ChurnRobert Wood Johnson - HamiltonManager of Patient Financial Services(609) [email protected]

Leona PeifferMcKessonClient Executive(203) [email protected]

Focus 31


A.Q.

IRS Governance Check Sheet: Key Governance Areas You Should Know About by Anthony Panico, CPA, MS, Partner WithumSmith+Brown, PC

Late last year, the IRS released a Governance Check Sheet for not-for-profits, which applies to my hospital. In which areas of governance does this check list address?

In recent years the Internal Revenue Service (“IRS”) has shown an initiative in enforcing governance policies to the not for-profit industry. In February of 2007 the IRS posted a discussion draft on its website (www.irs.gov) of possible good governance practices for charitable organizations. Subsequently, in June of 2007, the first draft of the redesigned Federal Form 990 was introduced and included a separate section on governance. After a comment period, the IRS released the final version of the redesigned Form 990, effective for tax years beginning on or after January 1, 2008, which included Part VI of the Core Form entitled Governance, Management and Disclosure. This section of the redesigned Form 990 addresses areas such as governing body and management, policies and disclosure. Although the form does state that the IRS is requesting in-formation in this section of the form that is not required by the Internal Revenue Code (“IRC”), it is evidence that the IRS is gathering this type of information in an effort to, in essence, enforce Sarbanes-Oxley to charitable organizations. The IRS has stated that their intention is to increase awareness by charities in the governance areas.

In yet another instance of the IRS enforcing governance to not for-profits and as a follow up to the redesigned Form 990, Core Form, Part VI, Governance, Management and Dis- closure, the IRS, on December 10, 2009, released a Governance Check Sheet. The Check Sheet will be utilized by IRS agents during examinations of organizations recognized as public charities and tax-exempt under Internal Revenue Code (“IRC”) §501(c)(3). The Check Sheet addresses several governance areas and, according to Robert Choi, Director of Rulings and Agreements of IRS Tax Exempt/Government Entities Division,

is designed to go into more detail and gather more information than is required to be disclosed in the Form 990.

The guide sheet to be used by IRS agents in completing the Check Sheet asks IRS agents to determine if organizations comply with a number of governance practices that the IRS believes lead to compliance with IRS rules and regulations for maintaining tax exemption, safeguarding of charitable assets and furtherance of tax-exempt charitable purposes.

The Check Sheet addresses several key governance areas including, but not limited to, the following:

1. Governing Body and Management wherein the questions are designed to gather information on the organization’s written mission statement, information in the organization’s bylaws with respect to members of the organization’s governing body, number of board mem-bers with voting rights, number of board meetings for voting and non-voting members and whether or not this was in compliance with the required number of meetings outlined in the organization’s bylaws.

2. Compensation questions that gather information with respect to organizations meeting the requirements of the rebuttable presumption of reasonableness that states that compensation arrangements of officers, directors, trustees and key employees are reviewed and approved by an independent committee based upon an analysis of comparability data and contemporaneous documentation.

3. Organizational Control questions that delve into the areas of family/business relationships between officers, directors trustees and key employees outside of the organization’s umbrella and where effective control of the organization rests (e.g. with a single or select few individuals).

Anthony Panico

•Focus on Finance•


32 Focus


4. Conflict of Interest questions that gather information on the details of the organization’s written conflict of interest policy, whether the policy addresses recusals, enforcement of the policy and whether or not the policy was adhered to if any actual or potential conflicts were disclosed.

5. Financial Oversight questions designed to gather infor-mation on the organization’s use of assets, written financial reports provided to and reviewed with board members, board review of Form 990, independent accountant’s report and management letter.

6. Document Retention questions designed to gather detailed information about the organization’s policy with respect to document retention and destruction, whether or not it was adhered to and contemporaneous documentation relative to board meetings.

It is clear that the IRS is convinced that there are abuses by tax-exempt organizations in the governance area as they continue to find ways to gather more and more information.

The IRS already has a sample Conflict of Interest Policy published on its website and in the instructions to Federal Form 1023, Application for Recognition of Tax Exemption. It is likely that the IRS will post additional sample governance policies on its website in the future. Jack Siegel, Charity Governance Consulting in Chicago, said about the Check Sheet, “I don’t think it’s that big of a deal from a substantive standpoint, but it is an indication that the IRS is not backing off governance.” Tax-exempt organizations need to have proper policies in place that will ensure that good governance practices are followed and maintained. The IRS has stated that a well-governed charity is more likely to obey tax laws, safeguard charitable assets and serve charitable interests than one with poor or lax governance.

About the authorAnthony J. Panico, CPA, MS, is a tax partner in the Morristown office of WithumSmith+Brown, CPAs, with a specialized focus on healthcare and not-for-profit clients. Tony can be reached at [email protected].


Meet A New MemberWho is your employer, and what is your position?

What was your first job as a teen?

What do you like best about your work responsibilities?

A job I would enjoy doing without pay is...

My favorite place is...

I will not eat...

If I’m not at work, you will find me...

Allison Kimowitz

WithumSmith+Brown, P.C. - Tax Associate.

Tennis Instructor.

The opportunity to meet clients.

Working at an animal shelter.

On the tennis court.

Olives.

At home with my family and dog or hanging out with my friends.

Focus 33



by Theresa Borzelli, Harvey M. Katz, Sarah K. Ivy and Daniel N. Kuperstein

As many employers may already know, the new health care reform law has created a special status for health care plans that allows them to be exempt from many of the law’s new require-ments - a status referred to as “grandfathered plan status.”

What many employers may not know, however, is that under new interim final regulations, if a fully-insured health plan loses its grandfathered plan status, it will have to com-ply with the requirements of the tax code’s “nondiscrimina-tion” provisions - provisions that prohibit a plan’s more fa-vorable treatment of highly compensated individuals. Prior to these regulations, these nondiscrimination requirements only applied to self-insured plans.

Overview of Grandfathered Plan Status Generally, to be a grandfathered plan, the policy or group

health plan must have had at least one individual enrolled on March 23, 2010. With some exceptions, any new policy, cer-tificate, or contract of insurance issued after that date, is not grandfathered. Grandfathered status applies separately to each benefit package offered under a policy or plan. For example, if a plan offers three options, but replaces the insurance issuer for one of those options after March 23, 2010, that option will lose its grandfathered plan status, but the others will still be grandfathered.

The benefit of this status is that a grandfathered plan is generally exempt from the health care law’s insurance reform requirements related to: preventive care; internal and external review; nondiscrimination; choice of providers; emergency care; clinical trials; cost sharing and deductibles; guaranteed

issue/renewal; and rating restrictions. However, grandfathered plans are not exempt from requirements related to: annual and lifetime limits; dependent coverage to age 26; rescission; pre-existing condition exclusions; waiting periods; and employer mandates.

Changes Affecting Grandfathered Plan Status Under the regulations, there are a number of ways that

changes to health plans will result in a loss of grandfathered plan status. These include: reducing benefits in a way that re-sults in the “elimination of all or substantially all benefits to diagnose or treat a particular condition”; increasing the fixed-amount and percentage cost-sharing requirements imposed on individuals for covered services and items; imposing or modi-fying an annual limit on the cost of health insurance cover-age; and failing to comply with recordkeeping and disclosure requirements.

The Tax Consequences

Under these new regulations, fully-insured health plans that have lost their grandfathered plan status will have to com-ply with the Code’s nondiscrimination requirements as of the earlier of: (1) the first day of the plan year beginning after September 23, 2010; or (2) the date upon which the plan is no longer grandfathered.

The tax consequences for a fully-insured plan that vio-lates the nondiscrimination requirements are different from those affecting a self-insured plan. Instead of subjecting highly

Theresa Borzelli

The Implications of Losing“Grandfathered Plan” Status

Harvey M. Katz Sarah K. Ivy Daniel N. Kuperstein

34 Focus


compensated individuals to additional tax, violations of the nondiscrimination requirements by a fully-insured plan subject the sponsoring employer to a $100 per day per participant excise tax, capped at the lesser of $500,000 or 10% of the em-ployer’s healthcare expenses for the previous year.

Under the tax code (§ 105(h)), “highly compensated indi-viduals” are defined as those who are: (1) among the 5 highest paid officers; (2) shareholders owning more than 10% in value of the employer’s stock; or (3) with some exceptions, the high-est paid 25% of all employees.

Transition Rules The regulations provide for a number of “transition rules”

or exceptions to the rules that require loss of grandfathered plan status. Under one such rule, if changes to a health plan were adopted before March 23, 2010, a plan or a policy will not lose its grandfathered status, even if the change takes ef-fect after that date. However, such changes must have been adopted under a legally binding contract, insurance filing, or written plan amendment in order for a plan or policy to ben-efit from this rule.

Potential Problems in the Workplace In light of the above, problems may arise if employment

policies, non-binding agreements, or other employment docu-ments provide for compensation arrangements resulting in an automatic imposition of the excise tax because they discrimi-nate in favor of highly compensated individuals and call for the issuance of a new policy after March 23, 2010.

For example, an employer with a fully-insured plan may have entered into non-binding employment agreements with high-level employees prior to March 23, 2010 that discrimi-nate in favor of such employees and that call for the issuance of new health insurance after the plan’s COBRA continuation coverage has expired. Under these circumstances, and other similar circumstances that may arise, employers and high-level employees may want to consider negotiating changes to their existing agreements. In any event, all employers should review their policies, agreements, and other documentation regarding health coverage for high-level employees in light of these new regulations.

About the authorsTheresa Borzelli – is a member of the Employee Benefits &

Compensation Planning Practice in Fox Rothschild LLP’s Rose-land, NJ office. She has practiced in the area of employee benefits and the tax and labor and employment law aspects of employee benefits for more than 20 years. Theresa also has significant expe-rience in the area of state and federal tax and corporate laws that govern tax-exempt organizations.

Harvey Katz – Harvey serves as co-chair of Fox Rothschild LLP’s Employee Benefits & Compensation Practice. Resident in its New York office, his practice focuses on all aspects of pension, executive compensation and employee benefits law. During his 31-year legal career, Harvey’s practice has included an extremely broad array of sophisticated employee benefits issues for public and private companies.

Sarah Ivy – Sarah is a member of the Tax & Estates De-partment in Fox Rothschild LLP’s Exton, PA office. She focuses her practice primarily in the areas of corporate law, taxation and executive compensation. Sarah also has experience with preparing and reviewing documents for asset purchase and stock purchase transactions and executive compensation plans for closely held companies, among others.

Dan Kuperstein – A member of Fox Rothschild LLP’s Labor & Employment Department in its Roseland office, Daniel focuses his practice on the representation of management in labor and employment law matters. In particular, Dan works with clients in the I.T./software, grocery and food service industries.

© 2010 Fox Rothschild LLP. All rights reserved. All content of this publication is the property and copyright of Fox Roth-schild LLP and may not be reproduced in any format with-out prior express permission. Contact [email protected] for more information or to seek permission to reproduce content. This publication is intended for general information purposes only. It does not constitute legal advice. The reader should consult with knowledgeable legal counsel to determine how applicable laws apply to specific facts and situations. This publication is based on the most current infor-mation at the time it was written. Since it is possible that the laws or other circumstances may have changed since publica-tion, please call us to discuss any action you may be consider-ing as a result of reading this publication.


Focus 35



CFO Spotlight:Kevin Lenahan, FHFMA - Atlantic Health

FOCUS: CFO backgrounds are diverse, please tell us about yours. How did you get started? What is your education and professional background?

KEVIN: I am a graduate of William Paterson University with a BA in Ac-counting. I started my professional career at Blue Cross & Blue Shield of New Jersey as a Medicare Audit and Reimbursement analyst. It was there I was given the HIM 15 and Medicare Cost Report instruction booklet and told to read it and figure it out; I did. I then went to work for Coopers & Lybrand LLP for three years doing health care audits and consulting as well as auditing in manufacturing, real estate and communications. Coopers & Lybrand gave me the opportunity to understand the entire financial picture and the chance to work on various types of businesses. I then went to work for Morristown Memorial Hospital just prior to the creation of Atlantic Health; my initial responsibilities were putting the financial aspects of the merger together as well as internal audit. When the merger was complete and Atlantic Health was formed, I went to Mountainside Hospital to be the initial post merger site CFO where my task was to assist in consolidating the finance operations into a centralized office for the system. I then went on to become the Director of Budget and Reimbursement for Atlantic Health. After a few years I also assumed accounting responsibilities for the system, a role I held for the past five years.

FOCUS: Did you ever think, all those years ago, that you would be here, doing this today?

KEVIN: No, when I went to work for Coopers & Lybrand, I wanted to get exposure to other areas of finance. However, I found health care to be a niche that I liked and had interest in.

FOCUS: What new skills do you think are needed for rising CFOs?

KEVIN: A CFO today has to have strong technical and leadership skills as well as be a passionate and proactive

promoter for the organiza-tion. In addition to managing the entity’s financial re-sources, the CFO must ensure the integrity of the organization, as well as support the company’s overall business and mission objectives. The CFO must work closely with employees, managers, physicians, senior management and the board to ensure that there is alignment of expectations in achievement of the vision of the entity. Atlantic Health’s vision is to be recognized

as one of the nation’s best health care systems. It is my role to ensure that we are successful in achieving this goal. FOCUS: What are your hospital’s specifics - are you asingle facility or part of a system? Do you have a religious affili ation? Please describe your location, demographics and the ser vices offered at your hospital.

KEVIN: Atlantic Health is one of the largest hospital systems in New Jersey and parent company of Morristown Memorial Hospital, Overlook Hospital, Atlantic Homecare/Hospice, Atlantic Ambulance and At Home Medical. Atlantic Health is on the forefront of hospital care and medical technology, and

is a recognized leader in quality health care for New Jersey and nationwide. Renowned for its breadth of expert cardiac services, Morristown Memorial Hospital performs the second most heart surgeries in the New York metropolitan area. Overlook Hospital, the regional leader in comprehensive stroke care and neurosciences, was the first hospital in the Northeast to offer CyberKnife treat-ment, a leading technology for precision radiation in the treatment of prostate cancer, brain tumors, spine, lung, liver and pancreatic cancers. In all our specialties, such

Kevin Lenahan

A CFO today has to have strong technical

and leadership skills as well as be a passionate and proactive promoter

for the organization.

A CFO must ensure the integrity of the

organization, as well as support the company’s overall business and mission objectives.

36 Focus


as pediatrics, orthopedics, cancer care, rehabilitation medicine, women’s health, cardiovascular care, sports medicine and neuroscience, Atlantic Health physicians are leaders in their fields, always searching for the most effective diagnosis and treatment options for each patient.

FOCUS: Can you tell us about your hospital’s: a) turnaround, b) new building, c) new infrastructure, d) new procedures offered, etc?

KEVIN: Atlantic Health, which has been named by FORTUNE® as one of the magazine’s “100 Best Companies to Work For®,” for two consecutive years, recently completed an extensive strategic planning process that includes bringing advances in medical research, technology, and quality initiatives to the community and the region. Morristown Memorial Hospital, a designated Magnet Hospital for Excellence in Nursing Service, has been serving the Morris County community for more than 100 years – setting high standards as a quality hospital for patient care with state-of-the-art facilities and a full range of medical specialties and services. We are the official health care of the New York Jets and offer a comprehensive sports medicine program.

Named a Level I Regional Trauma Center by the American College of Surgeons and a Level II by the state of New Jersey, Morristown Memorial offers superior care by our highly trained trauma teams. Our cardiac surgery center is the largest in the state, and the Gagnon Cardiovascular Institute is one of the top 100 hospitals in the nation for cardiovascular care. In 2009 Atlantic Health completed a $250 million restructuring & expansion project of the Gagnon Cardiovascular Center, which brought state-of-the-art technology to Morristown as well as eight new state of the art cardiovascular operating rooms, including hybrid OR’s and endovascular rooms as well as 146 hotel-like private rooms. Our Level III Regional Perinatal Center provides specialized care to sick or premature infants; and the Goryeb Children’s Hospital has more than 100 pediatric specialists dedicated to patients in a child-centered facility.

Morristown Memorial has been awarded the prestigious Gold Seal of Approval™ from The Joint Commission, achieving Disease-Specific Care Certifications for its joint replacement programs in the hip and knee categories.

Atlantic Neuroscience Institute, located at Overlook Hos-pital, houses the first Comprehensive Stroke Center in New Jersey, offering patients groundbreaking technologies such as the Merci Retrieval System™ and Penumbra devices. The Brain Tumor Center of NJ is renowned for its patient centered, multidisciplinary approach including unique treatments like the CyberKnife radio surgery and clinical trials for new brain tumor targeted vaccines. Among an array of outpatient and inpatient services include the Pain Management and

Concussion Centers, and the level 4 Epilepsy Center

FOCUS: What types of financing are utilized to meet the hospital’s goals?

KEVIN: In February 2008, when the bond auction rate market collapsed, in approximately 90 days Atlantic Health refinanced all our debt through a bond issue, for a total of $360 million; Series 2008A for 50% fixed, and Series B & C for 50% variable rate, each issue B and C is backed by a letter of credit from JP Morgan Chase or Bank of America. In August, Atlantic Health’s bond rating was reaffirmed by Moody’s as A1 Stable.

FOCUS: What are your spare time activities?

KEVIN: In my spare time I like to play golf and spend time with my two sons.

FOCUS: What are your professional memberships?

KEVIN: I am a Fellow in the HFMA, a member of the New Jersey Society of CPA’s and a member of American College of Healthcare Executives.

FOCUS: You are just told you have 30 minutes to pack - you are going to a sparsely populated island. What would you bring, besides food, clothes, hygiene products, etc?

KEVIN: My sons, my iPod touch and, most importantly, my best friend and love of my life.


The CFO must work

closely with employees,

managers, physicians, senior

management and

the board to ensure that

there is alignment of

expectations in achievement

of the vision of the entity.

Focus 37


FOCUS: Please provide us with a short bio of yourself.

EILEEN: I started work here at Riverview Hospital in 1982 as a per diem registrar in the Admitting office. In those days surgical patients came in the day before their surgery, so we would register the patients over the phone and get all the needed paperwork ready for the following day. We also did their admission when they arrived and we ‘admitted’ the ER and Maternity & Nursery patients. I found out right away that I had a “passion” for the patient. I loved the department and the role that I played in a patients encounter. I stayed part time for many years as my children grew, working the 2nd shift and weekends. I took every opportunity to learn anything new, I wanted to know and understand it all. At some point I became a full time.

In 1997 our hospital merged be-coming Meridian Health System, with Ocean Medical Center & Jersey Shore University Medical Center. We also said goodbye to the Admitting deepartment and became Access Services taking on all areas of registration, pre-registration, insurance verification, cashier-ing and financial assistance.

That was an exciting time. In 2000 I became a Supervisor, and then in 2005 I became the Manager of Access Services here at Riverview Medical Center. During the years I became more actively involved in the HFMA Patient Access Services committee. Eventually I became the secretary for the Patient Access Services forum, then the Co Chair, then the Chair. Now I am an Associate Board member and learning lots.

FOCUS: Please talk about your employer and your duties there.

EILEEN: I am very fortunate to work for Riverview, part of the Meridian Health Family. I have had awesome Managers, Directors, VP’s and Presidents along the way. Each of them has always been supportive and encouraging during my career. Duties involve whatever come across my desk, whoever needs help. You never know what the day may bring and who we may be able to assist in accessing their healthcare needs.

FOCUS: Please name a few of the special challenges you face in your position.

EILEEN: Getting out and about with the staff. It’s so important to thank the staff for

their role in the financial bottom line of the system. You need to keep the staff focused. Whether it is registration, verification or financial assistance, giving great customer service, ensuring the registrations are getting done quickly, courteously and accurately, all are important steps so that the hospital gets paid.

FOCUS: What advice can you give other professionals that are interested in entering your line of work?

EILEEN: To remember the patient and their family. To have a passion for

the patient. To remember that we may register 30-40 patients each a day, but that this is the patient’s only encounter, and we can make a difference. We are the 1st impression of their hospital experience.

FOCUS: What are your hobbies and outside interests?

EILEEN: I enjoy spending time with my husband and three children. My husband, Bob, and I also enjoy our 5 yr old grandson Kaen, going on a cruise whenever we can, and any type of Football. One of our sons is a high school football coach so we travel to his games and are fans of NY JETS football.

FOCUS: Thank you for taking the time out of your busy schedule to be interviewed for this edition of Member Spotlight.

Member Spotlight:Eileen Smith, CHAM

Eileen Smith

Remember the patient and their family. Have a passion

for the patient. Remember that we may register 30-40 patients each day, but that this is the patient’s only encounter, and

we can make a difference.

38 Focus


•Certification Corner•

To assist our membership with preparing for the certification exam, the NJ Chapter Education and Certification Committee is offering a 6 - week certification series class this fall, starting Wednesday, September 15th. The series will be held at Raritan Bay Medical Center from 5 – 8 PM. At the end of the series we will offer a proctored exam. If you think you may not be ready for the proctored exam, you may schedule an alternative date with a proctor that is convenient to both of you. The course is designed to assist individuals to understand all aspects of services related to hospital and physician practice. The course will examine payment for services rendered in accordance with regulatory, contractual and operational policies, practices and protocols, and their impact on the financial condition of an institution. Participants will be awarded a NJHFMA Financial Certification Certificate upon successful completion. Please look on the website http://www.hfmanj.org/Events.calendar for more details.

Additional Reimbursement OpportunitiesThe NJ Chapter is encouraging members to become

Certified Healthcare Financial Professional (CHFP), and ultimately Fellows in HFMA by reducing the financial burden associated with achieving these designations. The NJHFMA Board of Directors will reimburse NJ chapter members for applicable certification related fees. Reimbursable fees include the testing fees for the Core Exam and one Specialty Exam, CHFP application fee, and local technical fees. NJHFMA sponsored certification exam study courses will be eligible for reimbursement too. So, please take advantage of this opportunity to participate in this Fall’s Certification Series. For those that are interested, The NJ Chapter will further reimburse the examination and application fees related to successfully obtaining certification in additional specialties beyond the CHFP or FHFMA designation. Reimbursement will be made to the member, or to the member’s employee, based upon the source of the original payment.

So what does it take to become a Certified Healthcare Financial Professional?

• Membership – Be a current regular or advanced member of HFMA for at least two years

• Exams – You must successfully complete the Core exam and one specialty exam (Accounting and Finance, Patient Financial Services, Financial Management of Physician

Practices, or Managed Care) within a 24-month period.• Education – Complete a minimum of 60 semester hours

at an accredited college or alternatively, you may complete 60 hours of relevant professional development.

• Professional Experience – Two years of experience in healthcare financial management.

• References – HFMA Chapter President or other chapter officer and your CEO or immediate supervisor.

• CHFP Certification Application/Affidavit – Your signature and the seal of a notary public are required.

NEW requirements for obtaining HFMA Certification in 2011Effective, January 2011, earning the Certified Healthcare Financial Professional designation will be made easier. Here are a few of the key changes:

• Membership – Candidates must hold a current and active HFMA membership.

• Exams – You will only have to successfully complete one comprehensive certification exam.

For more details regarding the new model, please access http://www.hfma.org/certification/.

Test your Knowledge:Four kinds of cost behaviors in cost accounting are:

A. Incremental, fixed, variable, and semi-variable.B. Discretionary, fixed, variable, and semi-variable.C. Direct, indirect, fixed, and variable.D. Fixed, variable, semi-variable, and semi-fixed

For the answer and more information about the HFMA certification program go to www.hfmanj.org/certification3 or contact one of the members below.

Lindsey Colombo, FHFMA, MPA, Committee ChairWork: (732) 324-6031Email: [email protected]

Maria Facciponti, FHFMA – Committee Co-ChairWork: (973) 614-9100 Email: [email protected]

Michael Alwell, FHFMAWork: (973) 656-6949 Email: [email protected]

Lisa R. Hartman, M.P.H - Education Committee ChairWork: (609) 430-7789 Email: [email protected]

Step Up – Consider HFMA CertificationWhat does it take to obtain HFMA CertificationThere is still time to participate in this Fall’s Certification Series

Focus 39


•Focus on...New Jobs in New Jersey•

JOB BANK SUMMARY LISTING

HFMA-NJ’s Publications Committee strives to bring New Jersey Chapter members timely and useful information in a convenient, accessible manner. Thus, this Job Bank Summary listing provides just the key components of each recently-posted position in an easy-to-read format, helping employers reach the most qualified pool of potential candidates, and helping our readers find the best new job opportunities. For more detailed information on any position and the most complete, up-to-date listing, go to HFMA-NJ’s Job Bank Online at www.hfmanj.org.

[Note to employers: please allow five business days for ads to appear on the Web site.]

Job Position and Organization

MANAGER OF ACCOUNTING Fletcher Allen Health Care Burlington, VT

CONTRACT SPECIALIST Health Plus Brooklyn, NY

DIRECTOR FINANCIAL PLANNING Provider of Managed Healthcare Services Northern, NJ

VP TAXATION Provider of Managed Healthcare Services Northern, NJ

CDM COORDINATOR Saint Peter’s University Hospital New Brunswick, NJ

DIRECTOR OF FINANCE AND REIMBURSEMENT Bayada Nurses Moorestown, NJ

SR. ACCOUNTANT/FINANCIAL ANALYST Robert Wood Johnson University Hospital at Hamilton Hamilton, NJ

mark your calendar . . .Wednesday eveningsSept. 15, 2010 through Healthcare Financial Mgmt. Nov. 13, 2010 Certification Series5PM – 8PMRaritan Bay Medical Center

October 20 – 22, 2010 The Annual Institute The BorgataAtlantic City, NJ

PLEASE NOTE: NJ HFMA offers a discount for those members who wish to attend Chapter events and who are currently seeking employment. For more information or to take advantage of this discount contact Laura Hess at [email protected] or 888-652-4362. The policy may be viewed at: http://hfmanj.orbius.com/public.assets/A02-Unemployed-Discount/file_168.pdf

40 Focus


•Who’s Who in NJ Chapter Committees•

2010-2011 Chapter Committees and Scheduled Meeting Dates*NOTE: Committees have use of the NJ HFMA Conference Call line.

The call in number is (888) 269-3831 for all but the PFS and Institute Committees.The call in number for PFS and Insitute Committees is (888) 290-0578.

If the committee uses the conference call line, their respective attendee codes are listed with the meeting date information below.

PLEASE NOTE THAT THIS IS A PRELIMINARY LIST - CONFIRM MEETINGS WTH COMMITTEE CHAIRS BEFORE ATTENDING.

CHAIRMAN/EMAIL/ CO-CHAIR/EMAIL/ SCHEDULED MEETING LOCATION BOARDCOMMITTEE PHONE PHONE DATES/TIMES LIAISONCARE (Compliance, Audit, Darlene Mitchell Michael McKeever First Thursday of the Month Meeting in person at Deloitte & Touche, Heather WeberRisk, & Ethics) [email protected] [email protected] 9:00 AM Princeton, NJ for Oct., Jan., April and July [email protected] 908-237-7059 609-893-1200 ext 5201 Attendee Code: 5952498 Balance are calls. Please call to confirm 732-388-5210 ext 12769

Elizabeth Litten Al Rottkamp First Thursday of each month Fox Rothschild offices Tony ConsoliCommunications [email protected] [email protected] 9:15 AM 997 Lenox Dr Bldg 3 [email protected] 609-896-3600 609-584-6508 Attendee Code: 7844155 Lawrenceville, NJ 973-401-5223

Education & Lisa Hartman Matt Glass First Friday of each month Conference Calls with Tracy Davison-DiCanto Certification [email protected] [email protected] 8:30 AM in-person quarterly meetings. [email protected] 609-430-7789 732-632-5854 Attendee Code: 7363742 Call for info. 609-620-8471

FACT (Finance, John Doll Adam Bavifard First Wednesday of each Month To alternate between in Tom ShanahanAccounting, Capital [email protected] [email protected] 8:30 AM person and conf. calls; [email protected]& Taxes) 732-915-5430 201-368-4522 Attendee Code: 8730600 locations TBD 732-324-5401

Deborah Shapiro Howard Krain First Tuesday of each Month WFS offices Mary TaylorInstitute 2010 [email protected] [email protected] 8:00 AM Secaucus, NJ [email protected] 201-617-7100 908-377-5020 Attendee Code: 8788393 609-978-3373

Elizabeth Jennings Joe Privatera 6/17, 7/20, 9/16, New Jersey Hospital Dan WillisManaged Care [email protected] [email protected] 10/13, 12/16 – 9-11:00 AM Association [email protected] 516-282-8233 201-833-7010 No conference calling Board Room 908-301-5458 Membership Services/ John Manzi Erica Waller Call for meeting arrangements Locations alternate Caitlin ZullaNetworking [email protected] [email protected] Attendee Code: 5495569 by month – [email protected] 732-575-2520 609-620-8335 please contact the chairs 201-786-6020

William Hunt Diana Sessions Second Thursday of each Month CBIZ KA Consulting offices Laurie GreyPatient Access Services [email protected] [email protected] 9:30 AM in East Windsor, NJ [email protected] 201-996-2897 609-584-6465 Attendee Code: 8942192 609-620-8383

Marilyn Koczan Josette Melillo Second Friday of each Month New Jersey Hospital Mary CroninPatient Financial Services [email protected] [email protected] 10:00 AM Association [email protected] 732-897-7126 201- 291-6017 Attendee Code: 6748634 Board Room 732-839-1217

Regulatory & Mike Sabo Scott Besler Third Tuesday of each Month Locations alternate Joanne VaulReimbursement [email protected] [email protected] 9:00 AM by month - [email protected] 732-751-3389 732-839-1219 Attendee Code: 9169098 please contact the chairs 609-967-4562

Focus 41


With even fast food restaurants adding fruit smoothies to the menu, it is obvious that the “eat healthier movement” is going mainstream. Change is also coming to hospitals and senior living facilities where these institutions that are dedicated to health are now embracing the notion of healthier eating as well. By cutting back on processed foods, serving fresh fruits and vegetables, and reducing salt, fats and sugar, fewer hospitals and senior living residences are being held hostage to processed, carbohydrate-heavy foods; instead, they are positioning them-selves to successfully meet the needs of those they serve by offer-ing choices and education that support a healthy lifestyle.

Progressive institutions today are looking to offer healthier food to nourish patients, residents, staff and visitors and to combat disease, all while supporting more sustainable agriculture. A study entitled “Healthy Food, Healthy Hospitals, Healthy Communities” by the Minneapolis-based Institute for Agriculture and Trade Policies (IATP) pointedly states: ”We believe that the population of North America is in great nutritional peril…It must be a highest priority that our medical centers serve healthy food…How can the medical

profession encourage people to make better dietary choices if it cannot itself exemplify healthy eating habits?”

“It’s great that hospitals are starting to ‘walk the talk’ when it comes to food. They aren’t just telling people to eat better, but are making quality food more accessible,” says the report’s author Marie Kulick, senior associate in IATP’s Food and Health Program.

Hospitals around the country are beginning to respond. For example, the Cleveland Clinic, in Cleveland, Ohio, recently announced its system affiliates will no longer sell food or drinks that have added sugar or sugar variants. Jersey Shore University Medical Center in Neptune, N.J., serves locally sourced food grown within a 150-mile radius of the hospital whenever possible. And Barnes-Jewish Hospital in St. Louis offers a monthly Farmer’s Market Corner in which they pre-package together all the fresh ingredients needed to prepare a featured healthy recipe at home.

Heeding - and leading - the call for better nutrition through flavorful foods are food service partners like Morrison Management Specialists. Morrison began realigning its approach to nutrition and wellness several years ago in order to bring the healthcare and senior living industries more effective nutrition and wellness tools. Believing healthy food and nutrition along with education play an integral role in patient and resident care, Morrison began pioneering innovative approaches in healthy food alternatives that it believes will eventually be standard for forward-thinking facilities throughout the industry.

To help drive this change, Morrison asked celebrity chef Cary Neff, author of the New York Times best-selling cookbook “Conscious Cuisine,” to revamp its menus and create new concepts that reflect the company’s passion for flavorful, nutritious food. One of the newest concepts is Flavors 450 – where meals are all nutritionally balanced, bursting with flavor and under 450 calories.

Lifestyle Changes Sizzle with FlavorHospitals and Senior Living Facilities Embracing Healthier Menus

by Mary WelchMary Welch


42 Focus


Neff, who has appeared on The Oprah Winfrey Show, focuses on quality, seasonality, portion size, nutrition, colors and aromas to deliver healthy and satisfying meals. Sodium is reduced or eliminated by adding herbs. Soups are thickened with millet (a cereal grain) rather than cream, and ingredients are sautéed in olive oil instead of butter. All dishes are low in fat with an emphasis on whole grains, lean proteins, low-fat dairy products and the freshest ingredients, including local produce grown within 150 miles.

Dr. Alexis Abramson, a lifestyle gerontologist who often appears on The Today Show speaking about lifestyle issues for the over-50 population, believes this approach and the health movement is here to stay – and applauds it.

“People are understanding the need to stay healthier or become healthier, but at the same time, they want to live a life that’s fulfilled and eating is one of life’s pleasures,” she says. “We have to create menus that add nutritional value but still taste great. Remember, we lose 75 percent of our taste buds after age 30, so we have to make that taste up somehow. We no longer should do it with salt, but instead with herbs and interesting food combinations.”

This approach is finding converts in hospitals as well as senior living facilities where patients and residents are

increasingly becoming more vocal about what they want to eat. Brian Lawrence, president and CEO of Fellowship Village,

a continuing care retirement community with about 375 residents in Basking Ridge, N.J., says the demand for healthier food has recently gotten louder in the senior living industry. Residents are “looking for greater variety – for things like lower sodium, lactose-free, low carb, organic and gluton-free choices. There’s not as much demand for organic, but they are interested in local produce and sustainability. We want to enhance the quality of life for residents and one way we can do that is through their belly.”

Renu Sethi, registered dietitian and director of Food and Nutrition Services for Jersey Shore University Medical Center, says hospitals are seeing the same trend and Jersey Shore has observed “an increase in patients requesting vegetarian and vegan options. As ethnic diversity changes, we see patients requesting vegetarian meals for religious or cultural reasons. Patients do have an increased awareness in selecting ‘healthier’ choices and it’s very reflective of what we see in the general population.”

The Evergreens, a continuing care retirement community in Moorestown, N.J., is an example of a community that has listened to those residents who are seeking a different type of dining experience. “We selected Flavors 450 because the meals are rich in flavor, yet still provide great nutrition for older adults,” said Doug Halvorsen, president and CEO of The Evergreens. “Since the quality and taste of menu selections are top concerns for our community, a group of our residents was very involved in the planning of this program’s launch to ensure it is a good fit for our community. We introduced it June and it’s been very well received.”

To stay ahead of the demand for healthy food that tastes great, Chef Neff suggests that institutions take a fresh look at the way their culinary staff and nutritionists work together.

“In many places, nutritionists take existing menus and make them nutritionally sound to address a particular condition like diabetes or heart health,” Neff explains. “But it’s rare to have a collaboration with the culinary staff. We believe patients, residents and the facilities that serve them will benefit from a new way of thinking - developing a seamless relationship between the culinary staff and nutritionists, resulting in a new food style and directive that’s nutritionally sound but also great-tasting.”

It seems to be working. At Missouri Baptist Medical Center in St. Louis, Neff worked with nutritionists and dietitians to design new menu options – not only for patients, but in the café where they now offer the Flavors 450 menu to staff and visitors as well. Deanna Miller, clinical nutrition manager at Missouri Baptist, told the St. Louis Post-Dispatch she believes that the changes are long overdue. “We used to have food items


Focus 43


that had an abundance of fat or sodium, and we’d have to modify it for certain patients,” she said. “So we were preparing the same entree four different ways. Now, we serve the same healthy, tasty entree for everybody.”

In addition to providing healthier choices, hospitals and senior living facilities are also recognizing that they can’t change menus without helping to change lifestyles. At several of the facilities with Flavors 450, for example, ingredients and recipes are available for people to buy in the café and create at home. There are DVDs available showing Neff cooking meals tailored to health conditions such as diabetes, heart disease and celiac disease. And dietitians work one-on-one with patients to show how they can make healthy choices even after they leave the hospital.

Such a comprehensive, hands-on approach is necessary to make the change to a healthier menu work, says Neff. “The most difficult thing we face is helping people deal with change because it is difficult for most of us. It is critically important to interact frequently with patients and residents through cooking demos, food tastings, sharing food preparation tips and most importantly one-on-one consultations with dietitians.”

A New Generation, A New ApproachWhile hospitals are recognizing that doctors and patients

want healthier foods, administrators of senior living communities are facing even bigger challenges – a changing population. A study done by Strategic Management Initiatives for Morrison indicates that over the next five to 10 years, the attitudes of the senior living populations will drastically change and senior communities will need to transform themselves in order to meet residents’ needs.

According to the study, those who currently live in senior communities (the “GI” Generation) view senior living facilities as the last stage of their lives. But replacing this group in coming years will be the “Silent Generation” who view their retirement community as a place to improve their quality of life and continue having life experiences. They are informed consumers with higher expectations who are assertive about their needs and desires. They are focused on maintaining their health through sound nutrition, exercise and an active lifestyle and demand more control of their lives than the GI Generation.

“What this means for senior living communities, and the dining facilities that serve them, is that we have to rethink everything,” says Morrison Senior Living President Kevin Svagdis. “These residents approach buying decisions completely differently than those we serve now. They demand a range of options so that they can configure them to best suit their needs. To survive, facilities will have to transform into communities that can provide them with the choices they demand.”

Abramson echoes, “The first of the Baby Boomers are now moving into senior living facilities but they are not retiring their life or their life experiences These are dynamic people and they want to continue living and enjoying life. In terms of food, they often ate ethnic foods so that should be part of any menu. Look at Mexican, Thai, Chinese, and Indian. These are menus that are healthy and provide the taste that today’s - and future - seniors want.”

Healthy Food as a Competitive AdvantageFellowship Village’s Lawrence believes that senior facilities

that meet this changing demand for nutritious, great-tasting food will gain a competitive advantage in the marketplace. “The second sentence in our mission statement is: We provide seniors in need with a high quality of services that foster longer-term health, personal independence, spiritual growth and fellowship. What we’re doing with healthy food speaks right to that. Nutritious meals are certainly a part of providing high quality dining services and help with a healthy lifestyle that fosters long-term health. The healthier you eat, the healthier you are, and the more independent you can be. Without a doubt, this makes us more competitive.”

Many hospitals are finding healthier menu options are extension of their mission as well.

“A commitment to improving the health and well-being of patients is key to the mission and service of any hospital,” says Jersey Shore Medical Center’s Sethi. “Providing healthy food choices definitely supports the larger health initiative not only during hospitalization, but continues to impact patient care after they are discharged. In addition, by educating patients, staff, and their families, hospitals are able to extend the message into the community.”

In the end, says Neff, it really comes down to looking at food in a whole new way. By offering nutritional education and meals that entice the taste buds, satisfy the soul and maintain the body, both hospitals and senior living facilities can accelerate the patient and resident journey to wellness and a healthy lifestyle. In today’s world, it’s not a trend, but an approach that is quickly becoming required to be competitive and successful.

About the authorMary Welch is an Atlanta-based freelance writer who specializes in business, lifestyle and travel stories. She is the former editor in chief of Atlanta Woman magazine and Business to Business magazine.

44 Focus


2010 NJ HFMA Chapter Holds 8th Successful Leadership Retreat

On June 10th and 11th, 2010, Chapter leaders for the 2010-2011 Chapter year gathered at Ocean Place Resort and Spa in Long Branch, NJ for the 8th Annual Leadership Re-treat. The event was attended by NJ Chapter Officers, the Board of Directors, and Committee Chairs. Both returning attendees and newcomers were welcomed to assist the Chapter in beginning its planning for the current year.

This year’s event began on Thursday with an afternoon business session from 2-5:30pm, followed by a cocktail party, buffet dinner and a beach bonfire complete with the makings for s’mores. On Friday morning the meeting reconvened with breakfast at 8am, followed by a 9-12:30pm business session and lunch.

2010-2011 Chapter President, Mary Taylor, opened the session on Thursday with introductions of all attendees. Greg Adams, HFMA National Chair Elect, began the presentations with an overview of HFMA national areas of focus for the year including the challenging economy, healthcare reform, HFMA’s role in helping membership, volunteering and lead-ership roles. The discussions that followed included review of the following: review of chapter leadership position respon-sibilities, available local and national tools and resources for Chapter leaders, the DCMS Reporting System, Chapter Bal-anced Score Card requirements, the program planning tool, the Chapter’s web site, various policies and procedures, and a roundtable discussion of the 2010-2011 chapter goals.

The weather that evening was wonderful, and the attendees were able to have a BBQ dinner on the Long Branch beach with a bonfire, marshmallow roast, and some great s’mores!

Friday’s meeting involved discussion of the Chapter 2010 Annual Institute plans, and further discussion and develop-

ment of Chapter goals. The group then split into four groups to further brainstorm on the goals, and to develop a plan as to where to concentrate the Chapter’s efforts and resources dur-ing the year. The selected categories to explore were Certifica-tion/Education Programs, Future Leaders/Social Networking, Vendor Events, and Member Recognition

The following outlines ideas for board consideration from each discussion:

Certification/Education Programs - The group discussed various programs which could be offered on soft skills and net-working, public speaking, team building and other relation-ship focus areas. Ways to continue to enhance the certification program were also discussed during the session.

Future Leaders/Social Networking - Discussion for these areas focused on developing the Chapter’s future leaders and evaluating the potential of social networking media.

Vendor Events - The group discussed many ways that the Chapter can provide value to members who are vendors, such as education series, networking events and enhanced commu-nication to this important membership group.

Member Recognition - The theme of this discussion involved ways the Chapter can continue to “give back” to our members. The group brainstormed different forms of awards and rec-ognition that could be provided to members who have been significantly involved in the Chapter or achieved various mile-stones.

by Laura Hess, FHFMA and David Wiessel

Focus 45


The Chapter Leadership Retreat was a great success. With so many excellent ideas brought up, the NJ HFMA Board certainly has some things to think about! Thanks to all who took the time out of their busy schedules to attend and offer their invaluable input. It is a wonderful team of leaders that we have working together to ensure another successful NJ Chapter year. Consider “Stepping UP” and joining a commit-tee yourself!

46 Focus


Focus 47


Stat

emen

t of O

wne

rshi

p,M

anag

emen

t,an

dC

ircul

atio

n(R

eque

ster

Pub

licat

ions

Onl

y)1.

Pub

licat

ion

Title

2. P

ublic

atio

n N

umbe

r3.

Fili

ng D

ate

4. Is

sue

Freq

uenc

y5.

Num

ber o

f Iss

ues

Pub

lishe

d A

nnua

lly6.

Ann

ual S

ubsc

riptio

n P

rice

(if a

ny)

8. C

ompl

ete

Mai

ling

Add

ress

of H

eadq

uarte

rs o

r Gen

eral

Bus

ines

s O

ffice

of P

ublis

her (

Not

prin

ter)

9. F

ull N

ames

and

Com

plet

e M

ailin

g A

ddre

sses

of P

ublis

her,

Edi

tor,

and

Man

agin

g E

dito

r (D

o no

t lea

ve b

lank

)P

ublis

her (

Nam

e an

d co

mpl

ete

mai

ling

addr

ess)

Edi

tor (

Nam

e an

d co

mpl

ete

mai

ling

addr

ess)

Man

agin

g E

dito

r (N

ame

and

com

plet

e m

ailin

g ad

dres

s)

10.

Ow

ner (

Do

not l

eave

bla

nk. I

f the

pub

licat

ion

is o

wne

d by

a c

orpo

ratio

n, g

ive

the

nam

e an

d ad

dres

s of

the

corp

orat

ion

imm

edia

tely

follo

wed

by

the

nam

es a

nd a

ddre

sses

of a

ll st

ockh

olde

rsow

ning

or h

oldi

ng 1

per

cent

or m

ore

of th

e to

tal a

mou

nt o

f sto

ck. I

f not

ow

ned

by a

cor

pora

tion,

giv

e th

e na

mes

and

add

ress

es o

f the

indi

vidu

al o

wne

rs. I

f ow

ned

by a

par

tner

ship

or o

ther

uni

ncor

pora

ted

firm

, giv

e its

nam

e an

d ad

dres

s as

wel

l as

thos

e of

ea

ch in

divi

dual

ow

ner.

If th

e pu

blic

atio

n is

pub

lishe

d by

a n

onpr

ofit

orga

niza

tion,

giv

e its

nam

e an

d ad

dres

s.)

11.

Kno

wn

Bon

dhol

ders

, Mor

tgag

ees,

and

Oth

er S

ecur

ity H

olde

rs O

wni

ng o

r Hol

ding

1 P

erce

nt o

r Mor

e of

Tot

al A

mou

nt o

f Bon

ds, M

ortg

ages

, or

Oth

er S

ecur

ities

. If n

one,

che

ck b

ox

PS

For

m 3

526-

R, S

epte

mbe

r 200

7 (P

age

1 of

3 (I

nstru

ctio

ns P

age

3))

PS

N: 7

530-

09-0

00-8

855

PR

IVA

CY

NO

TIC

E: S

ee o

ur p

rivac

y po

licy

on w

ww

.usp

s.co

m

Non

e

7. C

ompl

ete

Mai

ling

Add

ress

of K

now

n O

ffice

of P

ublic

atio

n (N

ot p

rinte

r)(S

treet

, city

, cou

nty,

sta

te, a

nd Z

IP+4

®)

_

Con

tact

Per

son

Tele

phon

e (In

clud

e ar

ea c

ode)

Full

Nam

eC

ompl

ete

Mai

ling

Add

ress

Com

plet

e M

ailin

g A

ddre

ssFu

ll N

ame

12. T

ax S

tatu

s (F

or c

ompl

etio

n by

non

prof

it or

gani

zatio

ns a

utho

rized

to m

ail a

t non

prof

it ra

tes)

(Che

ck o

ne)

Has

Not

Cha

nged

Dur

ing

Pre

cedi

ng 1

2 M

onth

sH

as C

hang

ed D

urin

g P

rece

ding

12

Mon

ths

(Pub

lishe

r mus

t sub

mit

expl

anat

ion

of c

hang

e w

ith th

is s

tate

men

t)

The

purp

ose,

func

tion,

and

non

prof

it st

atus

of t

his

orga

niza

tion

and

the

exem

pt s

tatu

s fo

r fed

eral

inco

me

tax

purp

oses

:

Gar

den

Sta

teF

ocus

70

38

9/24

/10

Bi-m

onth

ly6

N/A

C/O

Fox

Rot

hsch

ildLL

C,9

97Le

nox

Dr.

Bld

g3,

Law

renc

evill

e,N

J08

648-

2317

Eliz

abet

hLi

tten

609-

895-

3320

Hea

lthca

reF

inan

cial

Mgm

tAss

ocia

tion

NJ

Cha

pter

,PO

Box

6422

,Brid

gew

ater

,NJ

0880

7

C/O

Fox

Rot

hsch

ildLL

C,9

97Le

nox

Dr.

Bld

g3,

Law

renc

evill

e,N

J08

648-

2317

Sam

eas

Pub

lishe

r

Sam

eas

Pub

lishe

r

Hea

lthca

reF

inan

cial

Mgm

tAss

ocia

tion

NJ

Cha

pter

C/O

Eliz

abet

hLi

tten,

Fox

Rot

hsch

ildLL

C,9

97Le

nox

Dr.

Bld

g3,

Law

renc

evill

e,N

J08

648-

2317

10

78

�

PS F

orm

352

6-R,

Sep

tem

ber 2

007

(Pag

e 2

of 3

)

Exte

nt a

nd N

atur

e of

Circ

ulat

ion

Aver

age

No. C

opie

s Ea

chIs

sue

Durin

g Pr

eced

ing

12 M

onth

s

No. C

opie

s of

Sin

gle

Issu

e Pu

blis

hed

Near

est t

o Fi

ling

Date

a. T

otal

Num

ber o

f Cop

ies

(Net

pre

ss ru

n)

c. T

otal

Pai

d an

d/or

Req

uest

ed C

ircul

atio

n (S

um o

f 15b

(1),

(2),

(3),

and

(4))

In-C

ount

y Pa

id/R

eque

sted

Mai

l Sub

scrip

tions

sta

ted

on P

S Fo

rm 3

541.

(Incl

ude

dire

ct w

ritte

n re

ques

t fro

m re

cipi

ent,

tele

mar

ketin

g an

d In

tern

et re

-qu

est s

from

reci

pien

t, pa

id s

ubsc

riptio

ns in

clud

ing

nom

inal

rate

sub

scrip

tions

,em

ploy

er re

ques

ts, a

dver

tiser

’s pr

oof c

opie

s, a

nd e

xcha

nge

copi

es.)

d.N

onre

-qu

este

d D

istri

butio

n(B

y M

ail

and

Out

side

th

e M

ail)

Tota

l Dis

tribu

tion

(Sum

of 1

5c a

nd e

)

17.

Sign

atur

e an

d Ti

tle o

f Edi

tor,

Publ

ishe

r, Bu

sine

ss M

anag

er, o

r Ow

ner

13.

Publ

icat

ion

Title

15.

Perc

ent P

aid

and/

or R

eque

sted

Circ

ulat

ion

(15c

div

ided

by

f tim

es 1

00)

Dat

e

Non

requ

este

d C

opie

s D

istri

bute

d O

utsi

de th

e M

ail (

Incl

ude

Pick

up S

tand

s,Tr

ade

Show

s, S

how

room

s an

d O

ther

Sou

rces

)

Tota

l (Su

m o

f 15f

and

g)

14. I

ssue

Dat

e fo

r Circ

ulat

ion

Dat

a Be

low

16.

Publ

icat

ion

of S

tate

men

t of O

wne

rshi

p fo

r a R

eque

ster

Pub

licat

ion

is re

quire

d an

d w

ill be

prin

ted

in th

e is

sue

of th

is p

ublic

atio

n.

b. L

egiti

mat

e Pa

id a

nd/o

rR

eque

sted

Dis

tribu

tion

(By

Mai

l an

d O

utsi

de

the

Mai

l)

Cop

ies

not D

istri

bute

d (S

ee In

stru

ctio

ns to

Pub

lishe

rs #

4, (p

age

#3))

Out

side

Cou

nty

Paid

/Req

uest

ed M

ail S

ubsc

riptio

ns s

tate

d on

PS

Form

354

1.(In

clud

e di

rect

writ

ten

requ

est f

rom

reci

pien

t, te

lem

arke

ting

and

Inte

rnet

re-

ques

t s fr

om re

cipi

ent,

paid

sub

scrip

tions

incl

udin

g no

min

al ra

te s

ubsc

riptio

ns,

empl

oyer

requ

ests

, adv

ertis

er’s

proo

f cop

ies,

and

exc

hang

e co

pies

.)(1

)

(2)

(4)

Req

uest

ed C

opie

s D

istri

bute

d by

Oth

er M

ail C

lass

es T

hrou

gh th

e U

SPS

(e.g

. Firs

t-Cla

ss M

ail®

)

Sale

s Th

roug

h D

eale

rs a

nd C

arrie

rs, S

treet

Ven

dors

, Cou

nter

Sale

s, a

nd O

ther

Pai

d or

Req

uest

ed D

istri

butio

n O

utsi

de U

SPS®

(3)

(1)

(3)

(2)

(4)

Out

side

Cou

nty

Non

requ

este

d C

opie

s St

ated

on

PS F

orm

354

1 (in

clud

eSa

mpl

e co

pies

, Req

uest

s O

ver 3

yea

rs o

ld, R

eque

sts

indu

ced

by a

Prem

ium

, Bul

k Sa

les

and

Req

uest

s in

clud

ing

Asso

ciat

ion

Req

uest

s,N

ames

obt

aine

d fro

m B

usin

ess

Dire

ctor

ies,

Lis

ts, a

nd o

ther

sou

rces

)

In-C

ount

y N

onre

ques

ted

Cop

ies

Stat

ed o

n PS

For

m 3

541

(incl

ude

Sam

ple

copi

es, R

eque

sts

Ove

r 3 y

ears

old

, Req

uest

s in

duce

d by

aPr

emiu

m, B

ulk

Sale

s an

d R

eque

sts

incl

udin

g As

soci

atio

n R

eque

sts,

Nam

es o

btai

ned

from

Bus

ines

s D

irect

orie

s, L

ists

, and

oth

er s

ourc

es)

Non

requ

este

d C

opie

s D

istri

bute

d Th

roug

h th

e U

SPS

by O

ther

Cla

sses

of

Mai

l(e.

g. F

irst-C

lass

Mai

l, N

onre

ques

tor C

opie

s m

aile

d in

exc

ess

of 1

0%Li

mit

mai

led

at S

tand

ard

Mai

l® o

r Pac

kage

Ser

vice

s R

ates

)

Tota

l Non

requ

este

d D

istri

butio

n (S

um o

f 15d

(1),

(2),

and

(3))

f.e. g. h. i. I cer

tify

that

all

info

rmat

ion

furn

ishe

d on

this

form

is tr

ue a

nd c

ompl

ete.

I un

ders

tand

that

any

one

who

furn

ishe

s fa

lse

or m

isle

adin

g in

form

atio

n on

this

form

or w

ho o

mits

mat

eria

l or i

nfor

mat

ion

requ

este

d on

the

form

may

be

subj

ect t

o cr

imin

al s

anct

ions

(inc

ludi

ng fi

nes

and

impr

ison

men

t)an

d/or

civ

ilsa

nctio

ns (i

nclu

ding

civ

il pe

nalti

es).

Gar

den

Sta

teFo

cus

July

/Aug

ust2

010

1242

1150

1127

1028

00

1127

1028

64

5264

1179

1092

6358

1242

1150

99.9

%99

.9%

9/24

/10

52

Sep

tem

ber/O

ctob

er20

10

Advertiser FocusPlease consider supporting our sponsoring companies

Since 1986, BESLER Consulting has been assisting healthcare providers in enhancing revenue, gaining operational efficiencies and achieving compliance. BESLER Consulting clients benefit from a team of highly experienced, dedicated professionals. They bringto each engagement in-depth knowledge in a wide range of financial, operational and compliance issues. Telephone 1.877.4BESLER • Web site Beslerconsulting.com

Established in 1973, McBee Associates, Inc., one of the nation’s largest, independent health care consulting practices, provides managerial and financial consulting services to health care organizations. The firm’s consultants maintain an extensive array of financial and managerial expertise, enabling them to resolve any financial chal-lenge that faces a health care provider today. Visit: www.mcbeeassociates.com

For over twenty-five years, CBIZ KA Consulting Services has provided customized financial solutions to healthcare providers. Our staff blends industry knowledge and practical experience to provide services in the fields of reimbursement optimization, Medicare and Medicaid recovery, managed care, decision support, benchmarking and clinical resource management. For informa-tion, visit www.kaconsults.com.

ParenteBeard is the Mid Atlantic’s leading regional certified public accounting and con-sulting firm with over 1,200 employees serv-ing middle market and small business clients

across the region. The 170 partner firm has 24 offices located in Pennsylvania, New Jersey, New York, Maryland, Delaware and Texas. The firm is ranked among the Top 20 firms in the USA and is an independent member of Baker Tilly Inter-national. For more information, please visit ParenteBeard at www.parentebeard.com.

Founded in 1974, WS+B is one of the largest regional accounting and consulting firms in the mid-Atlantic area with office locations in New Jersey, New York, Pennsylvania and Maryland. With over 375 employees, the firm ranks among the top 35

CPA firms nationwide. WS+B services hundreds of health care providers in the areas of accounting & auditing, consulting, tax, corporate governance and risk management. Contact Scott Mariani at [email protected] or 973.898.9494. www.withum.com

www.foxrothschild.com

Counted among the 200 largest law firms in the country, Fox Rothschild LLP is a full-service firm with offices in Pennsylvania, New Jersey, New York, Florida, California, Nevada and Delaware, providing a complete range of legal services to public and private business entities, charitable, medical and educational institutions and individuals.

The Health Care Law Group at Norris McLaughlin & Marcus is one of the largest in New Jersey. We provide a variety of services to clients throughout the health care field, includ-ing highly specialized work in the regulatory areas governing the delivery of health care services under state and federal law. Our health care clients include hospitals and their affiliated corporations, hospital medical staffs, nursing homes and other long-term care facilities, joint venture groups, professional practices, and other providers of health care ser-vices. For more information, visit our web site at www.nmmlaw.com.

Panacea Healthcare Solutions, LLC with offices in Florida and New Jersey, provides expert financial and information technology services and systems to healthcare providers, payers, and software companies. Panacea’s areas of expertise include coding, compliance, finance, reimbursement

and revenue cycle consulting and systems. These services include CDMauditor.com, RACauditor.com, LostRevenueRecovery.com, and hospital Zero Base Pricing consulting.

For more information, visit www.PanaceaHealthSolutions.com or contact Mike Kennedy at 1-866-926-5933 x702.

new jersey chapter

Breadth & Depth in Reimbursement, Revenue,

Coding & Compliance

Improving the health of the healthcare community through unmatched solutions

Keeping you on the right path through uncertainty

3 Independence Way, Suite 201Princeton, NJ 08540

877.4BESLER • www.beslerconsulting.com

Documents

new jersey chapter - HFMA NJ · 2013. 4. 18. · Highmark Medicare Services. Thanks to the Regulatory & Reimbursement Committee, led by Mike Sabo, Chair, and Scott Besler, Co-Chair,