ICD-10 Transition:What Health Lawyers Need to Know             American Bar AssociationEmerging Issues in Healthcare Law C...
Learning Objectives• Increase your overall awareness about ICD-10 and its  pervasive impact on your client base• Highlight...
What is ICD-10?Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012   Page 2February 23, 2012
What is ICD-10?• ICD-10 is a medical coding system• Like all medical coding systems, it provides a  way to condense textua...
What’s ICD-10-CM?• Diagnosis Coding System – Used to report the patient’s  condition (i.e., what’s wrong with the patient)...
ICD-10 Is Really Two Different               Code Sets•   The code sets:    – ICD-10-CM       » International Classificati...
How Big Could It Be?         ICD-9-CM                                    ICD-10-CM & ICD-10-PCS        Diagnosis: 14,025  ...
The ICD-10-CM                “Official Guidelines”•   As with ICD-9-CM, ICD–10–CM is supplemented by a set of    “Official...
ICD-10-CM ExamplePrepared for ABA – Emerging Issues in Healthcare Law Conference 2012   Page 8February 23, 2012
What’s ICD-10-PCS?• Procedure Coding System – Used to report surgical  procedures performed• Direct replacement for ICD-9-...
The ICD-10-PCS                “Official Guidelines”•   CMS has released a set of “Official Guidelines” for ICD-10-PCS•   L...
When is it official?   Per the Department of Health and Human Services, the   compliance date for implementation of ICD-10...
ICD-10 Code Comparison Examples   Tobacco Abuse                       Diabetes Mellitus                          Fracture ...
ICD-10-CM Code Comparison              Examples    Mechanical                      Suture of Artery                       ...
The GEMs• CMS has developed a bi-  directional crosswalk, referred  to as the General Equivalence  Mappings (GEMS), betwee...
Practical MappingsGEM Examples – ICD-9 to ICD-10         ICD-9-CM: 902.41 Injury to renal artery                ICD-10-CM ...
Impact of ICD-10 on               DRG Assignment• CMS did not address the impact of ICD-10 on DRG  assignment in the ICD-1...
ICD-10 Impact OverviewPrepared for ABA – Emerging Issues in Healthcare Law Conference 2012   Page 17February 23, 2012
Current State of ICD-10                                                 Providers will not be able                        ...
Who is impacted by ICD-10?                     Everyone!!• Front – Scheduling, Access Areas                               ...
Pervasive ChangeIf you care for a patient, handle a medical record, and/or process a claim   your workflow will be profoun...
Financial ReviewPrepared for ABA – Emerging Issues in Healthcare Law Conference 2012   Page 21February 23, 2012
7 Year Cost Analysis – ICD 10Year                                                    2011        2012       2013       201...
Expected Total Project CostMinich-Pourshadi, Karen. “ICD-10 Puts Revenue at Risk.” HealthLeaders Media Intelligence (July ...
Expected Denial ReasonsMinich-Pourshadi, Karen. “ICD-10 Puts Revenue at Risk.” HealthLeaders Media Intelligence (July 2011...
Summary Financial ImpactDecrease in Cash Flow / Loss of Revenue                                     • Industry experts fro...
Pro Forma ICD-10                        Implementation Budget          Cost Area                      2011           2012 ...
Compliance RiskPrepared for ABA – Emerging Issues in Healthcare Law Conference 2012   Page 27February 23, 2012
Current Compliance Environment• Recently created regulatory agencies charged with improving efficiencies  within the healt...
Current Compliance Environment• Recently enacted legislation  includes:   – Fraud and Abuse Provisions of ACA:     Implica...
ICD-10 Impact on Compliance Risk•   A huge potential for double billing exists if two systems (ICD-9 and ICD-10)    remain...
Risk MitigationPrepared for ABA – Emerging Issues in Healthcare Law Conference 2012   Page 31February 23, 2012
Risk Mitigation Strategies                                          Data Integrity –                                      ...
Thrive in the Transition                                  The realization of the opportunities, and the avoidance of the  ...
Risk Mitigation: “The Must Do’s”Create an ICD-10 impact awareness throughout the organization    Ensure your foundational ...
Risk Mitigation StrategiesReview existing software, including interfaces, to ensure its ability to successfullytransition ...
Focused Specifics: Documentation1. Focus on good documentation, which   directly impact accurate billing and   payment tim...
Focused Specifics: Collaboration4. Collaboration, transparency, and   communication between payers   and providers5. Train...
Establish dialogue and candid discussions with your primary third party payers now • Learn how each one plans to prepare f...
Key Resources• ICD-10 Proposed and Final Rules  – http://edocket.access.gpo.gov/2008/pdf/E8-19298.pdf  – http://edocket.ac...
Questions?Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012   Page 40February 23, 2012
Contact Information Thank you for allowing us to present this information to you. We appreciate the opportunity to work wi...
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ICD-10 Transition: What Health Lawyers Need to Know

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ICD-10 Transition: What Health Lawyers Need to Know

  1. 1. ICD-10 Transition:What Health Lawyers Need to Know American Bar AssociationEmerging Issues in Healthcare Law Conference 2012 February 23, 2012 Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 0 February 23, 2012
  2. 2. Learning Objectives• Increase your overall awareness about ICD-10 and its pervasive impact on your client base• Highlight the potential financial and regulatory impacts• Explore how to prepare your clients for the change that ICD-10 will enable• Discuss Risk Mitigation opportunities for your clients as you prepare for the migration to ICD-10 Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 1 February 23, 2012
  3. 3. What is ICD-10?Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 2February 23, 2012
  4. 4. What is ICD-10?• ICD-10 is a medical coding system• Like all medical coding systems, it provides a way to condense textual clinical information into “codes” that can be used for billing and other data-based applications Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 3 February 23, 2012
  5. 5. What’s ICD-10-CM?• Diagnosis Coding System – Used to report the patient’s condition (i.e., what’s wrong with the patient)• Direct replacement for ICD-9-CM Volumes 1 & 2• Will be used in all settings – hospital inpatient, hospital outpatient, physician office, etc.• Like ICD-9-CM, developed and maintained by the World Health Organization and the National Center for Health Statistics within the Centers for Disease Control Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 4 February 23, 2012
  6. 6. ICD-10 Is Really Two Different Code Sets• The code sets: – ICD-10-CM » International Classification of Diseases, 10th Revision, Clinical Modification – ICD-10-PCS » International Classification of Diseases, 10th Revision, Procedure Coding System• There is no relationship between the two code sets – they have completely different structures and uses Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 5 February 23, 2012
  7. 7. How Big Could It Be? ICD-9-CM ICD-10-CM & ICD-10-PCS Diagnosis: 14,025 Diagnosis: 68,069 Procedures: 3,824 Procedures: 72,589820.02, Fracture of midcervical section of S72031A, Displaced midcervical fracture of right femur,femur, closed initial encounter for closed fracture S72031G: Displaced midcervical fracture of right femur, subsequent encounter for closed fracture with delayed healing S72032A: Displaced midcervical fracture of left femur, initial encounter for closed fracture S72032G: Displaced midcervical fracture of left femur; subsequent encounter for closed fracture with delayed healing Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 6 February 23, 2012
  8. 8. The ICD-10-CM “Official Guidelines”• As with ICD-9-CM, ICD–10–CM is supplemented by a set of “Official Guidelines” that are designated as part of the ICD- 10-CM code set by the HIPPA “medical data code set” regulations (45 CFR 162.1002(C)(2))• The Official Guidelines provide detailed guidance on the use of the ICD-10-CM code set• The 2012 ICD-10-CM Official Guidelines are available from http://www.cdc.gov/nchs/icd/icd10cm.htm#10update Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 7 February 23, 2012
  9. 9. ICD-10-CM ExamplePrepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 8February 23, 2012
  10. 10. What’s ICD-10-PCS?• Procedure Coding System – Used to report surgical procedures performed• Direct replacement for ICD-9-CM Volume 3• Only used in a hospital inpatient setting (and only for reporting facility services)• Like ICD-9-CM Volume 3, ICD-10-PCS was developed and is maintained by CMS Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 9 February 23, 2012
  11. 11. The ICD-10-PCS “Official Guidelines”• CMS has released a set of “Official Guidelines” for ICD-10-PCS• Like the ICD-10-CM Official Guidelines, the ICD-10-PCS Official Guidelines are designated as part of the ICD-10-PCS code set by the HIPPA “medical data code set” regulations (45 CFR 162.1002(C)(3))• The 2012 ICD-10-PCS Official Guidelines are available from https://www.cms.gov/ICD10/11b15_2012_ICD10PCS.asp#TopOf Page Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 10 February 23, 2012
  12. 12. When is it official? Per the Department of Health and Human Services, the compliance date for implementation of ICD-10-CM and ICD-10-PCS is October 1, 2013. January 1, December January 1, December January 1, October 1, 2010 31, 2010 2011 31, 2011 2012 2013• Payers and • Internal testing of • Payers and • External testing • All electronic • Claims for providers should Version 5010 providers should of Version 5010 claims must use services begin internal must be begin external for electronic Version 5010 provided on or testing of Version complete to testing of Version claims must be after this date • Version 4010 5010 standards achieve Level I 5010 for complete to claims are no must use ICD- for electronic Version 5010 electronic claims achieve Level II 10 codes for longer accepted claims compliance Version 5010 medical • CMS begins compliance diagnosis and • Providers should accepting inpatient form ICD-10 Version 5010 procedures sponsorship claims team • CPT codes will • Version 4010 continue to be claims continue used for to be accepted outpatient services Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 11 February 23, 2012
  13. 13. ICD-10 Code Comparison Examples Tobacco Abuse Diabetes Mellitus Fracture of RadiusICD-9-CM: 1 Codes ICD-9-CM: 10 Code ICD-9-CM: 33 CodesICD-10-CM: 5 Codes ICD-10-CM: 318 Codes ICD-10-CM: 1818 Codes Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 12 February 23, 2012
  14. 14. ICD-10-CM Code Comparison Examples Mechanical Suture of Artery Angioplastycomplication of other ICD-9-CM: 1 Code ICD-9-CM: 1 Code vascular device, implant or graft ICD-10-CM: 276 Codes ICD-10-CM: 854 CodesICD-9-CM: 1 CodeICD-10-CM: 156 Codes Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 13 February 23, 2012
  15. 15. The GEMs• CMS has developed a bi- directional crosswalk, referred to as the General Equivalence Mappings (GEMS), between ICD-9-CM and ICD-10-CM/PCS• There are GEMs for over 99 percent of all ICD–10–CM codes and for 100 percent of the ICD–10–PCS codes Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 14 February 23, 2012
  16. 16. Practical MappingsGEM Examples – ICD-9 to ICD-10 ICD-9-CM: 902.41 Injury to renal artery ICD-10-CM GEM: S35.403A Unspecified injury of unspecified renal artery, initial encounter ICD-9-CM: 50.24 Percutaneous ablation of liver lesion or tissue ICD-10-PCS GEM: 0F503ZZ Destruction of Liver, Percutaneous Approach Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 15 February 23, 2012
  17. 17. Impact of ICD-10 on DRG Assignment• CMS did not address the impact of ICD-10 on DRG assignment in the ICD-10 Final Rule• However, CMS and 3M have used the GEMs to convert the MS-DRG definitions from ICD-9-CM to ICD-10• CMS and 3M found that the GEMs were 95% to >99% effective in converting the MS-DRGs to ICD-10 Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 16 February 23, 2012
  18. 18. ICD-10 Impact OverviewPrepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 17February 23, 2012
  19. 19. Current State of ICD-10 Providers will not be able to report ICD-9-CM codes No Grace Period for services on or after October 1, 2013Date of Discharge will be There will be no delays in used for hospital IP the implementation date of settings ICD-10 Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 18 February 23, 2012
  20. 20. Who is impacted by ICD-10? Everyone!!• Front – Scheduling, Access Areas • Documentation Analysis• Middle – Coding, CDI, Case Health • ICD-10 Education Management Information • Process Improvement• Back – Billing, Reimbursement Management • Monitoring Physician Revenue Information Post Acute Office Process Technology Services ICD-10 • IT Systems • Capability, Communication • Functionality• Staffing Effectiveness • Vendor Preparedness• Assessment of Revenue Impact • Physician Documentation• Process Improvement Operational Physician • Physician Integration• Decision Support Reporting Planning • Physician Performance Impact Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 19 February 23, 2012
  21. 21. Pervasive ChangeIf you care for a patient, handle a medical record, and/or process a claim your workflow will be profoundly impacted by the migration to ICD-10 Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 20 February 23, 2012
  22. 22. Financial ReviewPrepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 21February 23, 2012
  23. 23. 7 Year Cost Analysis – ICD 10Year 2011 2012 2013 2014 2015 2016 2017Training Coders – Inpatient $0 $0 $32 $159 $21 $0 $0 Coders – Outpatient $0 $0 $12 $96 $12 $0 $0 Code Users $0 $0 $4 $33 $4 $0 $0 Physicians $0 $0 $104 $835 $104 $0 $0 Subtotal $0 $0 $152 $1,123 $141 $0 $0Productivity Coders – Inpatient $0 $0 $0 $10 $0 $0 $0Losses Coders – Outpatient $0 $0 $0 $9 $0 $0 $0 Physician Practices $0 $0 $0 $12 $0 $0 $0 Improper and returned claims $0 $0 $0 $0 $329 $165 $49 Subtotal $0 $0 $0 $31 $329 $165 $49System Providers $23 $45 $75 $8 $0 $0 $0Changes Software vendors $17 $35 $58 $6 $0 $0 $0 Payers $30 $59 $99 $10 $0 $0 $0 Government $77 $154 $256 $26 $0 $0 $0 Subtotal $147 $293 $488 $50 $0 $0 $0TOTAL COST (IN MILLIONS) $147 $293 $640 $1,204 $470 $165 $49 Source: Center for Medicare and Medicaid Services (2010) Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 22 February 23, 2012
  24. 24. Expected Total Project CostMinich-Pourshadi, Karen. “ICD-10 Puts Revenue at Risk.” HealthLeaders Media Intelligence (July 2011), p. 19. Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 23 February 23, 2012
  25. 25. Expected Denial ReasonsMinich-Pourshadi, Karen. “ICD-10 Puts Revenue at Risk.” HealthLeaders Media Intelligence (July 2011), p. 22. Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 24 February 23, 2012
  26. 26. Summary Financial ImpactDecrease in Cash Flow / Loss of Revenue • Industry experts from CMS and AHIMA estimate the following: – Denial rates will increase by 100% to 200% – Accounts receivable days will be extended by 20% to 40% – Healthcare organizations will be hindered with payment declines for more than 2 years after the implementation Date of October 1, 2013 – Claims-error rates will increase from 6% to 10 % (The average current rate is close to 3%)• According to the American Society of Clinical Oncology, Estimated Organizational Cost by Bed Size Bed Size Cost 400 + $1.5 Million – $5 Million 100 – 400 $500,000 – $1.5 Million < 100 $100,000 – $250,000 Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 25 February 23, 2012
  27. 27. Pro Forma ICD-10 Implementation Budget Cost Area 2011 2012 2013 2014 2015 2016Total Training $ - $ 40,500 $ 468,000 $ 27,000 $ - $ 535,500IS Staff Augmentation $ 115,000 $ 1,240,000 $ 840,000 $ 265,000 $ 50,000 $ 2,610,000HIM Coding Staff Augmentation $ - $ 35,000 $ 180,000 $ 165,000 $ 65,000 $ 545,000Revenue Cycle Staff Augmentation $ - $ - $ 135,000 $ 220,000 $ 220,000 $ 575,000IS Software Upgrades $ 75,000 $ 430,000 $ - $ - $ - $ 505,000Technology Upgrades $ 10,000 $ 10,000 $ - $ - $ - $ 20,000New Software $ - $ 1,700,000 $ 380,000 $ 280,000 $ 280,000 $ 2,640,000Reports and Forms $ - $ 150,000 $ 115,000 $ - $ - $ 265,000Interface and Other Testing $ - $ 260,000 $ 260,000 $ - $ - $ 520,000 TOTALS: $ 200,000 $ 3,865,500 $ 2,378,000 $ 957,000 $ 815,000 $ 8,215,500 Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 26 February 23, 2012
  28. 28. Compliance RiskPrepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 27February 23, 2012
  29. 29. Current Compliance Environment• Recently created regulatory agencies charged with improving efficiencies within the healthcare delivery system and reducing the incidence of improper payments include: – Zone Program Integrity Contracts (ZPIC) – Medicare Drug Integrity Contractor (MEDIC) – Medicaid Integrity Contractors (MIC) – Medicaid Recovery Audit Contractor Program – Medicare Recovery Audit Contractor Program (RAC) – Health Care Fraud Prevention and Enforcement Team Task Force (HEAT) – Fraud and abuse provisions of Patient Protection and Affordable Care Act of 2010 (ACA) and related administrative roles Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 28 February 23, 2012
  30. 30. Current Compliance Environment• Recently enacted legislation includes: – Fraud and Abuse Provisions of ACA: Implications for Providers – Expanded False Claims Act (FCA); Implications for Providers – Amended Federal Sentencing Guidelines; Implications for Providers – HIPAA Privacy Standards Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 29 February 23, 2012
  31. 31. ICD-10 Impact on Compliance Risk• A huge potential for double billing exists if two systems (ICD-9 and ICD-10) remain in use during the transition period: – This scenario could potentially create unintentional billing compliance risks. – The shortage of experienced coding professionals also poses a risk since medical coders nearing retirement age may elect to retire rather than learn a new system.• Additionally, the General Equivalency Mappings (GEMS) do not provide a definitive map from ICD-9 to ICD-10 with only 5% mapping accurately 1:1 with ICD-10 codes: – Because ICD-9 codes could map into multiple ICD-10 codes, this risk rises even more. – It is important to note that ICD-10 conversions include manual review and monitoring due to the significant differences in language and structure between ICD-9 and ICD-10 Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 30 February 23, 2012
  32. 32. Risk MitigationPrepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 31February 23, 2012
  33. 33. Risk Mitigation Strategies Data Integrity – prepare for delayed accepted batches IT Preparedness – Budget for potential prepare for payor cash flow impact /vendor delays Key Areas ofRightsize staff to Compliance Risk Adjust AR Reserveshandle increased as Needed volume Denial Tracking Tool HIM Preparedness Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 32 February 23, 2012
  34. 34. Thrive in the Transition The realization of the opportunities, and the avoidance of the risks associated with the migration to ICD-10 will Impact fundamentally depend on the individuals within your Awareness Definition organization. Specifically, their ability to thrive within this changing environment. Change To support this, create a holistic approach that: ReadinessAssessment • Illustrates the impact of the ICD-10 migration across the organization; Collaborative • Diagnostically assesses the readiness of individuals to Sponsorship accept and thrive in a changing environment; Design • Design a sponsorship model that leverages the nature of the healthcare industry and intuitively distributes Training responsibility; and BlueprintConstruction • Developing a blueprint that pulls together all the training effort required across the organization for success. Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 33 February 23, 2012
  35. 35. Risk Mitigation: “The Must Do’s”Create an ICD-10 impact awareness throughout the organization Ensure your foundational IS structure is actively preparing for the transition Define your change approach to ensure you have defined the proper structure and sponsorship Develop projections of operational needs, including staffing and internal educational training Identify specific documentation gaps to determine focused educational needsCalculate potential impact on financial results Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 34 February 23, 2012
  36. 36. Risk Mitigation StrategiesReview existing software, including interfaces, to ensure its ability to successfullytransition to ICD-10Train clinical and administrative staff on new code sets, technological changes aswell as fraud, waste, and abuse regulations and reportingReview Third Party agreements to ensure any vendors involved in billingprocesses will be compliant with ICD-10 requirementsEnsure clinical documentation procedures reflect the increased level of detailrequired by ICD-10Contract with outside entities to audit six (6) to twelve (12) months of claimssubmitted by an organization to identify any activity that might be consideredfraudulentTake immediate corrective action where necessary Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 35 February 23, 2012
  37. 37. Focused Specifics: Documentation1. Focus on good documentation, which directly impact accurate billing and payment timing2. Be aware of new ICD-10 documentation guidelines in order to evaluate provider documentation for appropriateness, thoroughness, and completeness3. Take great care to document procedures, labs, and diagnostics performed in order to capture the essence of the total care provided during hospital admissions Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 36 February 23, 2012
  38. 38. Focused Specifics: Collaboration4. Collaboration, transparency, and communication between payers and providers5. Train and problem solve through the use of task forces6. Encourage CMS to continue perfecting payment groupers and mappings7. Collaborate with other healthcare stakeholders to create an industry test bed Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 37 February 23, 2012
  39. 39. Establish dialogue and candid discussions with your primary third party payers now • Learn how each one plans to prepare for ICD-10 changes, ask if they are implementing new rules for claims submission or re-submission • Share your plans for implementing these changes with them • Identify shared goals and objectives to ensure a combined approach, minimizing disruption to either’s coding processes (win-win) • Work all denials and rejects aggressively to eliminate their occurrence and ensure more first time third party payer payments Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 38 February 23, 2012
  40. 40. Key Resources• ICD-10 Proposed and Final Rules – http://edocket.access.gpo.gov/2008/pdf/E8-19298.pdf – http://edocket.access.gpo.gov/2009/pdf/E9-743.pdf• CMS Website on ICD-10 – https://www.cms.gov/ICD10/• CDC Website on Classification of Diseases – http://www.cdc.gov/nchs/icd.htm• CMS ICD-10-CM Quick Reference Guide – https://www.cms.gov/ICD10/11b14_2012_ICD10CM_and_GEMs.a sp#TopOfPage Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 39 February 23, 2012
  41. 41. Questions?Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 40February 23, 2012
  42. 42. Contact Information Thank you for allowing us to present this information to you. We appreciate the opportunity to work with you and your organization. Denise Hall, RN, BSN Neil W. Kunkel Principal SVP, General Counsel & SecretaryPershing Yoakley & Associates, P.C. Capella Healthcare 678-441-0645 615-764-3015 dhall@pyapc.com Neil.Kunkel@capellahealth.com www.pyapc.com www.capellahealth.com Prepared for ABA – Emerging Issues in Healthcare Law Conference 2012 Page 41 February 23, 2012

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