Understanding opportunities in working directly with employers.
By Curt DeWeese, PT*
The entrepreneurial practice owner is challenged to identify ways to expand and diversify revenue-producing programs. Establishing relationships with employers is another opportunity to create unique service lines, guide referrals to the clinic, and market the practice. Getting training and gaining confidence in how to use the unique skill set we possess as therapists are the first steps in establishing mutually beneficial relationships with employers.
As clinic owners or therapists working in private practices, the current climate of reduced insurance reimbursement, higher patient copayments, and increased administrative demands to obtain payment for services all drive up the risks in maintaining a successful practice. Keeping visit volume at acceptable levels, successfully marketing the practice, and attracting and maintaining excellent staff add to the daily challenges of practice owners. Working directly with employers to expand your business, establishes a service line within your practice to guide patients to the clinic while also creating an opportunity for revenue generation. This initially feels like a big risk because it may negatively impact visit volume as you get started, and require time away from the clinic. However, the potential rewards are significant.
Each actively employed patient seen in the clinic is potentially affected at his or her job by the condition being treated. The injury does not have to be work related to influence that person’s ability to perform their job functions. Back pain related to moving furniture over the weekend impacts sitting tolerance at a computer workstation, and elbow pain from tennis or golf may limit use of hand tools in manufacturing. How do we use our abilities as musculoskeletal experts to understand the patient’s job demands, build a rehabilitation program to restore function, and bring these areas together for optimal outcomes? What opportunity exists for us to expand this relationship beyond the patient/employee to include the employer?
When working with an athlete with a knee injury who plays a sport requiring planting and cutting, we work on removing swelling, increasing range of motion, and improving strength. As the program progresses, we can then introduce running in straight planes and then add activities for agility and the needed planting and cutting. We can build sport-specific rehabilitation programs based on our knowledge of the sport. We may have played the sport at a much lower level or even just watched a game, but we have an understanding of what this athlete will need to perform as they return to activity.
I once had a patient who was a press operator with a shoulder problem. I was able to work through the first stages of controlling pain and swelling, restored motion, and increased strength. I thought we were home free as he returned to work. But because I did not fully understand the essential functions of the press operator job position, I did not get into the work-specific exercises that were needed. He subsequently returned in a very short time with an exacerbation. I realized I needed to know more about his job functions, how he performed them, and the equipment used. I could only understand that by seeing his work environment; I had to get on site at his place of employment.
When reaching out to employers, having a common interest is a great assist in getting the meeting. An employee out of work is that linkage; the employer wants them back, and that is the physical therapist’s ultimate outcome. Having a specific job to look at with a defined goal often makes getting the appointment easier than trying to establish a meeting to introduce yourself and your practice. This visit is for the therapist’s benefit; increased understanding of job demands and work postures will assist with better patient outcomes and satisfaction. These visits can be done at no charge as a way to establish the relationship with the employer. The outcomes are as simple as better understanding of what work-specific exercises are needed in the treatment program to more complex where the employer seeks a simple report of five ergonomic stressors and suggestions for improvement. It is the building block to the “know me” phase. Just as great outcomes and satisfaction of patients from a new referral source generate confidence, trust, and additional referrals, the relationship building with the employer becomes a source of new opportunity. Ongoing collaboration on site for ergonomics, education, and early intervention will produce results of decreased Occupational Safety & Health Administration (OSHA)–recordable incidents, reduce injury frequency, cut lost and restricted days, and drive cost savings. Those steps will lead to the “trust me” phase where the employer seeks input as a partner in safety, injury prevention, and assisting with claim management.
Our skill set makes us experts in the ergonomics of the human machine. We understand the stressors that lead to tissue breakdown or cause repetitive motion injuries. Providing onsite early intervention in the realm of first aid can prevent a small irritation from becoming a full-blown injury and claim. Workers will often persevere with discomfort because they need their job. They will give up hobbies and other leisure-time activities to be able to continue working. When the symptoms become so severe that there is disrupted sleep and inability to perform work functions, the issue will take greater intervention to correct. Being on site and correcting work postures, tool choices, and position of the work performed will abolish the soft tissue and repetitive motion stressors before the condition progresses. This is a benefit to the employee who wants to stay at work comfortably, the employer who avoids a lost time claim, and the therapist who is getting good outcomes and a direct pay revenue source from a new onsite contract.
How this is good for business
Establishing onsite presence with an employer is generally a fee-for-service relationship. There is an hourly or weekly charge for the services provided. This is a direct pay revenue source that supplements the established traditional insurance-reimbursed therapy services provided in the clinic. There are myriad other types of these arrangements being created by therapists such as wellness, sport performance training, and fitness centers. More and more, entrepreneurial practice owners are reaching new markets to diversify opportunities and create new revenue sources. Consulting with employers is another excellent option. Additionally, while providing onsite services, there is an entire population of potential physical therapy consumers who would benefit from seeing a physical therapist in the clinic. Those employees who do not respond to early intervention first aid care can be referred for formal treatment in the clinic. Trusting relationships are created with the workers, who seek input for nonwork-related symptoms or care for family members. All of these situations create opportunity for marketing and sharing the value of your practice.
Gaining understanding of the criteria OSHA uses to classify the intervention provided is in the realm of first aid versus medical treatment. Working knowledge of the Americans with Disabilities Act Amendments Act (ADAAA) is also important. Consider offering job function analysis to objectively report the physical demands of job titles, identify ergonomic stressors and ways to correct them, and develop and administer functional testing for post-offer and return to work placement. There are resources online and continuing education programs to help you obtain the tools you need. The Private Practice Section has many members who are actively working with employers and various industries. Network, ask questions, and use the outstanding resources our section offers.
Curt DeWeese, PT, is a PPS member, COO of DSI Work Solutions, and president of Work Injury Solutions & PT, PC, in Webster, New York. He can be reached at email@example.com.
The vital signs of a healthy business culture.
By Walt Porter, MPT, DPT, CEAS
It is no secret that the health care industry is undergoing major change, and formidable new challenges keep appearing from every direction. Implementing ICD-10 into practice and adapting to changes associated with the Affordable Care Act are two topical examples. More broadly, as our baby boomer population continues to age, hospitals are working to vertically integrate, and insurance groups are consolidating to prepare for the future. What is exciting is that with change come opportunities, if you are able to spot them and ready to seize them.
In these unsettled and unsettling conditions, one of the must-haves for success—not to mention survival—is a positive and compelling business culture. Dealing with the outside world is a whole lot simpler when, within the company, everybody is in sync with values and on board with goals.
Of course, from the Fortune 500 to the corner store, no two companies are exactly alike, and every business runs its own version of business culture. Scholars of business continue to define and refine the concept. For many, the wellspring of a company’s culture lies in its core mission, vision, and values—or at least, it should.
Harvard’s John Coleman, for example, identifies the six components of a great corporate culture as follows: vision to guide a company’s values and provide it with purpose; values that offer guidelines on the behaviors and mindsets needed to achieve the vision; practices, whereby values are baked into the operating principles of daily life in the firm; people who share and will strive for the same values; a narrative that crafts the company’s history into the ongoing development of its culture; and place, which through geography, architecture, and design impacts values and behaviors and so helps to shape culture.1 It is interesting to apply such analysis to your own circumstances.
Another way to monitor your business culture in action is to ask if it is unafraid of change, provides opportunity and motivation, provides stability and security, engages all of its members/employees, leads by example, is clear and appealing to external audiences, and reflects and reaches out to its community.
The more positive your answers, the more likely you are living up to your mission, vision, and values. For sure, when esprit de corps is high, a company’s energies can be focused on what it is really there to do—serve its customers, grow its people, support its community, and fulfill its mission. Another commentator, Michael C. Mankins, puts it like this: “Culture is the glue that binds an organization together and it is the hardest thing for competitors to copy,”2 creating ongoing competitive advantage for your company.
If its internal culture is not defined, embraced, practiced, and nurtured, uncertainty undermines performance, morale, and the company’s ability to attract and retain the best people. Certain brands are known for the strength of their business cultures that have been tested and proven in action during good times and others. These are companies with a clear sense of what they stand for and where they are going and with an inclusive approach to employees. They create workplaces where everybody feels engaged and that they can make a difference. Consider a few examples:
“You are part of something much bigger than you, it is not something you need to blog about to satisfy your ego,” a former Apple employee said.
As renowned leadership analysts James Collins and Jerry Porras observed two decades ago, “The Walt Disney Company’s core values of imagination and wholesomeness stem not from market requirements but from the founder’s inner belief that imagination and wholesomeness should be nurtured for their own sake.”
At the Gore Company (Gore-Tex), associates (rather than employees) are guided by the principles of fairness, freedom, commitment, and consultation. “What can you change?” the company asks.
Toms Shoes, with its One-for-One business model, offers employment with a built-in feel-good factor and the opportunity to put your social conscience to work.
Ride a Southwest Airlines flight and you get a sense of the upbeat, employee-centric spirit that has given the company its distinctive and successful presence.
All of these companies are driven by powerful internal cultures based on values and standards that are firmly established and universally accepted, with codes of behavior that are embraced rather than imposed. Each in its own way offers an example of what can happen when you get your business on course and stay the course as a team from top to bottom—as a team, that is critical . . . a team of individual talents eagerly collaborating for a collective purpose. Members of a successful team respect each other, work for each other, and strive unceasingly for their cause. How does a company best identify ability and nurture it, channel, and coordinate it for the good of all parties? How does it continue to strengthen the fabric of its business culture? Abstract-sounding questions with real significance on a daily basis.
In the physical rehabilitation industry as in every sphere of activity, we are all looking for answers. At BenchMark Rehab Partners we think a lot about how to fulfill our mission, which is “to inspire and empower people to reach their full potential.” Our vision, “by consistently exceeding expectations, we passionately strive to be the outpatient rehabilitation provider, employer, and partner of choice,” along with our mission and our core values, drive us as a company. We ensure as we grow in size that we stay personal in our approach and stay true to our founding goal of providing every patient with access to care from world-class clinicians. We constantly seek to foster everything that is good about our culture and upgrade anything else. We aspire to turn ideas with potential into programs and projects, monitor the results, and make adjustments as necessary.
We are also firm believers in John C. Maxwell’s dictum that “Small disciplines repeated with consistency every day lead to great achievements gained slowly over time.”4 As we build our company, we keep in mind the recruiting philosophy of Herb Kelleher in growing Southwest Airlines: “We will hire someone with less experience, less education, and less expertise, than someone who has more of these things and a rotten attitude. Because we can train people. We can teach people how to lead. We can teach people how to provide customer service. But we can’t change their DNA.”5
1. Coleman J, Gulati D, Segovia W. Passion & Purpose: Stories from the Best and Brightest Young Leaders. Boston, MA: Harvard Business Press; 2012.
2. Mankins M. The defining elements of a winning culture. Harvard Business Review. https://hbr.org/2013/12/the-definitive-elements-of-a-winning-culture. Posted December 19, 2013. Accessed August 10, 2015.
3. Collins J, Porras, J. Building your company’s vision. Harvard Business Review 74:5 https://hbr.org/1996/09/building-your-companys-vision. Accessed August 12, 2015.
4. Maxwell J. The 15 Invaluable Laws of Growth. New York, NY; Hachette Book Group; 2012.
5. Kelleher, H. 8 Herb Kelleher quotes that will teach you everything you need to know about life. www.freeenterprise.com/8-herb-kelleher-quotes-will-teach-you-everything-you-need-to-know-about-life. Posted March 21, 2014. Accessed August 16, 2015.
Walt Porter, MPT, DPT, CEAS, is a PPS member and senior vice president of operations for BenchMark Rehab Partners. He can be reached at firstname.lastname@example.org.
A big picture look at Revenue Cycle management and touches on the interconnected nature of the first point of patient contact through a paid claim.
By Eric Cardin, PT, MS
Revenue cycle management, a relatively mild term in the world of business jargon. It’s a simple yet important idea to look at the “management” of revenue. Physical therapy practice can be an emotionally and personally rewarding profession, but the obstacles between treatment and payment can be daunting. The term cycle implies a defined series of events or a routine that repeats itself, a cycle or pattern that is overtly and covertly tied together and the nature of which holds the key to successful management.
Visits x Charges x Accounts Receivable = Revenue (Income minus Expenses)
Simple, right? See a patient, charge for it, collect that money, pay the bills. Have something left over. Many businesses, including physical therapists in private practice, struggle or even fail by not digging deeper into what drives the factors in this basic equation for revenue cycle management.
Visits are revenue. No matter what metric you use, when you get to the bottom of the paper, visits drive the bus. Getting the patient in the door is an obvious first step but keeping them coming and growing the practice is the first and most important step. After all, there is no revenue cycle without revenue.
From the moment of first contact (phone intake, walk in, scheduling a neighbor for an evaluation on your phone—thank you, cloud-based electronic medical record (EMR)—while standing in line at the grocery store), the revenue cycle starts. So much of our ability to efficiently bill and collect revenue and manage cash flow is dependent on how well we collect information up front. “Clean” demographic information is the first obstacle we face in getting paid on time. Depending on the volume of your office, the ancillary staff you may or may not have, and the collection method, there are several “fail points.” Handwriting problems, typing errors, missed steps, and general lack of organization can and will delay a claim. It is very important to get the information from your client and get it into your billing/scheduling software in a quick and accurate manner. If you look at your turnaround time (time to get paid from the point you send out claim), you should be able to discern what the average is and also take note of what claims are rejected and why. Take note of the common errors and implement simple policy changes to reduce the rate of rejection. Your cash flow will thank you for it.
After you’ve efficiently and accurately collected demographic information and processed it without error, you still have some hurdles to overcome. Was there a referral in place? Was the patient authorized and/or do they have active insurance that will cover them during their entire episode of care? There are a few ways to go about this. One, you leave it to the consumer. It is their responsibility to know their coverage. Or two, you collect the necessary information at intake and you “trust, but verify.” There is usually a personal cost (doing it yourself) or actual payroll expense (paying someone to do it) in the time it takes to make sure all the referrals and authorizations are in order, but for a solo therapist with a full (30 to 40 hour) schedule of patients, for example, the effects on the bottom line are worth the up-front effort.
The unifying theme in the first factor of “Visits = Revenue” is the ability to collect information. The tie that binds the components together is a positive customer service experience. A pleasant phone call or face-to-face encounter that leaves your client with the feeling that you are helping them get registered, authorized, referred, and ready for what is usually their first physical therapy experience will go a long way to establish your office as the destination of choice for physical therapy. It is wise to remember that the most important marketing opportunity you have is the patient who is already in front of you. Creating an environment that helps the client heal and doing so in a way that creates a feeling that everyone in the office is helping them on their journey will only serve to grow your patient base and your bottom line.
Once you’ve seen the patient you’ve got more hurdles to jump through. What’s your payer mix, what are their coverage rules, what codes do they accept, and which ones pay well? The next factor in the equation for cycle management, “Charges,” is another important factor. Payer mix (what percentages of which insurers are paying you) should be a huge part of your due diligence prior to getting started. If you find yourself inundated with patients that have a low reimbursement rate, you might find it hard to stay in the black. Payer mix can be quite varied, and can change even from one town to the next. It is important to investigate who your patients may be, where they will come from, and who is insuring them before you decide where to practice. After you’ve made that decision, it is a good idea to routinely sample your payer mix and take note of where your bread is being buttered. Once you understand that, you can tailor your demographic collection and charge habits to maximize your revenue. As you understand payer mix, you will also find that it is important to stay on top of credentialing, continuing education (regarding coding/charges), and global changes to reimbursement. Visits x Charges = Revenue. If you have a multitherapist practice, get in the habit of sharing who pays what and what is well reimbursed and what is not. Even if they are not the practice owner, you will be surprised that they often do care that they are reimbursed appropriately. The cycle continues with or without you and your attention to detail is key. The only thing you stand to lose is money!
Now that you’ve created a positive customer service environment and efficiently and accurately collected patient demographics while understanding insurance rules and gotten the client better without going over the allotted visits—it’s time to collect your revenue. Visits x Charges x Accounts Receivable. It is important to note that this equation we use to describe the revenue cycle uses multipliers, not addition. This is done with the intention of creating an understanding that success or failure will move exponentially. Small mistakes or small victories will carry over quickly. If you are seeing a hundred patients a week or a thousand, then that is your multiple. One mistake repeated 100 times. Or one success repeated over and over. It is all connected and all part of the revenue cycle.
Accounts Receivable (AR) is a basic component of any business that allows their “product” to be taken or used with a promise of payment. Physical therapists in private practice face the delightful challenge of having varied payment methods, contractual adjustments to our fees, and limited ability to make changes. Again, there are options. Cash-only payment at time of service sounds appealing when you delve deep into third-party reimbursement, but for those of us not ready for that option we must soldier on and get on our AR. Since we know we’ve already collected accurate demographics and used our expensive billing software to send out “clean” claims, we can just sit back and watch the bank account swell. Right? Think again. The struggle is real and the cycle waits for no one.
Again, the tie that binds is customer service. Helping your client understand their benefit before they start physical therapy can seriously and positively affect your AR. Kindly let each patient know what their personal financial responsibility will be (copay) or could be (estimate their deductible) for their time in physical therapy and routinely remind them that their copayment, coinsurance, deductible, etc., is due, or will be due. Accept all forms of payment, remove all obstacles to “I forgot my [insert payment method here].” Create controls in the system to keep balances low and keep your consumer informed. Soft chasing them the same day in the front office is much easier and much more cost effective than bringing it up 90 to 120 days later. Start at the first point of contact with creating an understanding that you provide a service and that service has a cost. Too often we fall into the trap of the “helper/healer,” but have you ever tried to pay the utilities with good feelings?
Once the claims are out and awaiting payment, watch your rejections and Explanation of Benefits. Much of the payment process is automated and this has been to our benefit, but computers still can make errors and somewhere along the line someone is processing your claims who maybe—just maybe—isn’t having the best day and they just might let a charge slip through unpaid. If you are not managing this part of the cycle, there are plenty of ways to lose money. Pay attention to individual filing limits, coding rules, and coverage limitations. Bill your services as soon as you can, follow up as quickly as possible, and send out statements weekly (or more frequently if you can) to keep the cycle going and your cash flow strong. Bill the claim, correct the claim, rebill the claim. Keep the statements rolling.
Finally, you’ve collected demographics, charged appropriately, followed up on outstanding claims, and hopefully watched your bottom line grow. Revenue cycle management is constant. It begins with the first point of contact with every patient and ends with prompt and accurate payment. Tight controls, simple policies and procedures, and attention to detail should result in timely payment. Each practice should take a look at least quarterly at the components of the cycle. As time passes your data set grows, and you can see cause and effect and sharpen the parts of the cycle that lead to prompt, accurate payment.
Eric Cardin, PT, MS, is the executive director of South County Physical Therapy, Inc., which has six locations in western Massachusetts. He can be reached at email@example.com.
PPS Strategically Targets Payment at a Local Level
By Paul Gaspar, PT, DPT, CCS
Payment is quite possibly the number one concern of physical therapists in private practice. Many insurance companies have cut payment by 25 to 40 percent during the last five years. Others have chosen to hire “middleman” discount networks to effectively lower payment and curb the utilization of physical therapists’ services. To top it off, some have used “all contracts” clauses and questionable pricing and product rollout schemes to lower their costs—and this is at a time when several insurance companies have been posting dramatically higher profits and stock prices, as well as record CEO compensation. Is that fair or legal? Most physical therapists would argue it is not fair, but whether it is legal is a much more difficult question. The legality of specific payment contracts and conditions has to be determined on a case-by-case basis and largely depends on state laws and regulations for most payers. That is one of the main reasons the Private Practice Section (PPS) started a legal fund to support their PPS members at the local level. And it seems to be paying off in a big way.
California physical therapists have been frequent recipients of PPS legal grants, several of which have been used to win the legal status of the Physician-Owned Physical Therapist Services (POPTS) two years in a row. In cases where California physical therapists were no longer able to achieve their goals in the POPTS battle, they returned the remaining legal funds back to PPS so that they could be used where the outcome would be more satisfying to PPS members.
Since direct access and POPTS issues have been largely decided in California, fair payment has been the advocacy focus. California physical therapists continue to be crushed by predatory pricing, middleman networks, and questionable payer tactics. PPS has been relying on its physical therapist members in California to keep them informed about physical therapists’ rights or contracts being infringed. Recently, PPS funded a legal action against a payer’s alleged retribution against PPS members for their fair payment advocacy. The legal action resulted in a positive financial settlement for the PPS members.
PPS remains in close contact with their members in California because many consider it ground zero for payment reform. California’s PPS members are among the most proactive PPS members in the country, often pushing back forcefully if they feel they have been wronged by payers. Many in California are identifying potential actions regarding allegedly illegal contract offers, breaches of contracts, and unfair pricing schemes.
If your goal is to get paid more fairly by insurance companies, don’t sit back and expect others to do the work for you. PPS cannot be in all places at all times. If you think you are being treated unfairly, relay your concerns to your local colleagues, your local private practice group, your attorney, and/or PPS. It would not be a bad idea to consider contacting a PPS member in California either, because if there is a payer problem it is likely that California physical therapists have experienced it, or are doing so currently. After doing so, if it is clear that there may be a viable legal concern, please consider contacting the PPS Board and applying for a legal aid grant. We hope physical therapists in other states will take advantage of this unique opportunity offered only to PPS members.
Paul D. Gaspar, PT, DPT, CCS, is a Private Practice Section (PPS) member and owner of Gaspar Physical Therapy since 1994. He has served on the board of the California Physical Therapy Association, three terms as a PT PAC Trustee, and currently serves as President of the Independent Physical Therapists of California.
A recent Marquette University study assessed payer policies of the three largest health care payers in each state.
By Jim Hall, CPA
Those who know me well know that I am a huge proponent of federalization of insurance laws. Now, before you stop reading, let me make it clear that I am not referring to a single payer system but a system where one set of laws are applied in all 50 states (just like interstate banking and commerce laws). In the April 2011 issue of Impact magazine, I wrote an article outlining my reasons why I feel it is necessary.
It is easy to relate anecdotal stories of why federalization of insurance laws is necessary, but without data most legislators can only sympathize. The stories are fascinating, but how big an issue could this really be? And if you are like me, who has time to sit down and gather the information necessary and put it into a meaningful document?
Enter American Physical Therapy Association Private Practice Section (APTA PPS) Payment Policy Committee members Bridget Morehouse and Mary Daulong, along with assistance from Marquette University doctoral students Stephanie Fiore, Sabrina Weng, A.J. Butts, Nico Olson-Studler, Sarah Iglar, and Danny Coppin. Under the direction of Mary Daulong, these students were tasked with the project of researching the top three insurance payers’ websites in every state. The purpose of this study was to design a document that would assist private practitioners in researching information that would be required in order to appeal claims denials or find authorization forms. However, this purpose was overshadowed by the “bigger picture.”
Their task was to locate on each payer’s website items such as Physical Therapy Medical Policy and Medical Necessity, among other things. They were then asked to use a 1 to 5 grading scale to score how easy (1) or difficult/problematic (5) it was to find the document(s) identified. The results of this exercise were exactly what all of us would have anticipated; the students were shocked at the lack of consistency from insurance company to insurance company. They anticipated Blue Cross Blue Shield would have a consistent medical policy from state to state, however that was not the case.
This document is the first step toward illustrating the problems providers experience in trying to understand what an insurer needs from them in order to get paid. By the way, the students prepared a 17-page PowerPoint presentation and 180+ pages of insurance website information along with the grading scale described. The document will eventually be made available to PPS members, and I am hopeful that a second round of this study will provide additions, which would include how long it takes to navigate the website to determine this information, as well as downloading Medical Policies, Medical Necessity information, and Pre-Authorization forms. When this is done, I anticipate adding these documents as an addendum to the original study, and this document should grow from 180 pages to thousands of pages. That document will also illustrate how easy it is to treat a patient, but how difficult and time consuming it is to appeal a $50-$150 visit when an insurer arbitrarily decides to deny coverage and tell you all you have to do is go to their website and find the policy, forms, etc., and fill them out to complete an appeal (after waiting on hold for 30 minutes to speak with someone for direction).
If you are still not convinced this is an issue, the study encompassed the top 3 payers in all 50 states. I went out to the Trizetto Clearinghouse website and downloaded their professional payer list (Institutional/Hospital payers were excluded from the list). That list does not include payers that only accept paper claims. Want to hazard a guess as to how many payers there were? There are slightly more than 6,400 payers listed. While your practice may not file claims to more than 50 payers consistently, at some point you are going to run across new payers. This new payer experience may be a messy one, and the cleanup is going to take a while.
All that said, not only will these documents help you in that process, they will also become an effective tool to carry to legislators everywhere to ask for one cohesive set of federal insurance laws that all insurers would use to compete for business. And if that’s not a large enough task, maybe state insurance commissioners could be confronted by not only state association members lobbying for insurance reform, but other health care practitioners as well. I believe that we all owe the individuals involved in this study a collective “thank you.” We will work to share this document with other medical specialties to form a unified position.
Jim Hall, CPA, is the general manager of Rehab Management Services and a member of the PPS Payment Policy Committee. Jim can be reached at firstname.lastname@example.org.