C258 Financial Resource Management Task Two

Running head: C258 FINANCIAL RESOURCE MANAGEMENT TASK TWO 1
C258 Financial Resource Management Task Two
Melinda Burns Smith
Western Governors University

C258 FINANCIAL RESOURCE MANAGEMENT TASK TWO 2
C258 Financial Resource Management Task Two
A1. Goals of the Physician Quality Reporting System (PQRS)
The PQRS went into law in 2006 and it instructs medical professionals who meet the
eligibility standards to report on certain, designated sets of quality measures using the CPT
category II codes.
One of the primary goals in using these codes is to demonstrate that specific services in
these codes have been connected to quality patient care. Safian states “Each code’s description
explains clinical fundamentals (such as vital signs), lab test results, patient education, or other
facets that might be provided within a typical office visit.” (Safian & Johnson, 2016, p. 330-331).
Another goal for PQRS is to provide a bonus for physicians to report Medicare-eligible
patients and use the measures to provide high-quality health care. A third goal is to use measures
that have a large amount of data supported by science that a certain intervention used in a
category II code will influence a patient’s health to improve. The PQRS codes also have
modifiers that will report a performance measure exclusion based on medical, patient, or system
reasons. Because providers do not get reimbursed on the basis of each code being used, CMS
has listed four steps for providers to become eligible for the yearly bonus for use of PQRS.
A1a. Advantages and Disadvantages of PQRS
The advantages of using PQRS are:
~~Extra counseling regarding health conditions.
~~Research can be done into the reasons a physician may recommend a course of action
and the patient not follow that advice.
~~Provide high-quality, evidence-based health care.

~~Providers may be able to justify adding an RN or NP to the staff to provide the piece
counseling piece and participate without more stress on the physicians.
The disadvantages of using PQRS are:
~~The medical providers cannot see a financial upside to the extra time involved and
decide not to bother with the codes.
~~Small practices with only one or two providers and a busy practice will be
overwhelmed to try and use the system and they may not have received any training on
using the codes. This student’s office of one surgeon decided that the program would be
of no benefit to him and his surgical practice.
A2. Goals of the Value-Based Purchasing System (VBPS)
The VBPS has been a long-term goal of Medicare to marry together the payment system
of Medicare to a value-based system to help improve the quality of healthcare, especially in the
inpatient system. Medicare has established a mandate to add a value-based system to skilled
nursing facilities also.
Medicare is moving reimbursement methods, such as the Outpatient Prospective Payment
System (OPPS) and the Inpatient Prospective Payment System (IPPS) towards VBPS as a way to
de-emphasize volume of patients and more to the value of services to the patients’ health.
Medicare wants to achieve a goal of 30% by 2016 year end and 50% by end of 2018 for the PPS
systems. They have also set a goal of fee-for service (FFS) payments tied into VBPS, 85% by
the end of 2016 and 90% by the end of 2018.
The overarching goal for this move from volume to value is better, more thorough care,
spending health care dollars more wisely and communities consisting of healthier people.
A2a. Advantages and Disadvantages of VBPS

VBPS was conceived to encourage providers to give better quality medical care rather
than large volumes of medical care. It was set up to discourage the fee for service system that
rewards providers for doing a high volume of care as a way to increase profits. One large
advantage to VBPS is that CMS is paying for medical care based on care that is producing better,
healthy outcomes for patients, rather than just a number of treatments done. The goal is to
encourage better health habits for patients.
By using VBPS, doctors are rewarded for demonstrating quality care for their patients
and less for seeing large volumes of patients. Attention is paid to patient outcomes and their
assessment of their experiences with the care in facilities, prevention of some chronic conditions,
adoption by providers of EHRs to track the outcomes, and care coordination.
VBPS has started to impact the world of commercial insurance also. In a study done
recently, 90% of payers and 81% of hospitals have begun a mixture of value-based and FFS
payments. It is anticipated that as VBPS gains a steady foothold, the FFS will decrease from
56% to 30%. Blue Cross/Blue Shield has implemented programs that increase the emphasis on
primary care. The providers get paid using pre-set, non-FFS methods to manage patient care up
front, rather than having the patients get care using expensive hospital care.
One very big disadvantage to using VBPS is that the metrics used to try and measure
quality care are very difficult for providers to agree on. The risk of having one system is that a
one size fits all system won’t necessarily produce good care across the board.
The other problem is that some medical care that is primary in nature and designed to
head off problems is not well-rewarded, such as counseling and vaccinations, like the
pneumococcal vaccine. Physician practices will need to report and meet the quality cost metrics,
leading the way for reporting penalties and certain downward cost adjustments. Another

disadvantage for hospitals is that certain facilities, such as teaching hospitals, may experience
negative evaluations from patient regarding their care.
A3. Health Information Management (HIM) Roles
HIM personnel will have a large role to play in both PQRS and VBPS. HIM
professionals are the subject matter experts when it comes to using and maintaining data. Using
and managing the large amounts of data required to make these programs operational will
challenge HIM departments to the fullest.
HIM personnel will be able to provide the medical record information that providers and
facilities will need to use the report cards inherent in these plans. Data analytics will be a critical
component of both systems by tracking the care and performance and giving a measurement of
the improvements in the health of a patient. Data warehouses contain data related to the care and
outcomes of patients and HIM personnel have experience in using data warehouses. The data
they can access for providers and facilities will be able to show when variations and waste in
healthcare have been eliminated, thus raising the care measures to be reimbursed by Medicare in
both PQRS and VBPS.
Sharing this information with other providers helps all involved. HIM folks can design
assessment tools for all to use and encourage the use of those tools to develop new strategies to
meet the benchmarks set by these measures. Butler states “Patients have been telling their
caregivers their symptoms and concerns long before there were records to document them.
What’s changed is how patient information is being captured-and that is where HIM excels.”
(Butler, M. 2015, p.19).
B. Quality Improvement Organization (QIO) Roles in Coding

A QIO department monitors quality aspects of medical care in hospitals, surgery centers
and clinics. QIO organizations and facility QIO departments work with CMS to make sure that
the diagnosis and procedure coders that are submitted for payment can demonstrate medical
necessity.
The diagnosis codes explain why the patient has come to the provider for care. The
procedure codes explain what procedures, treatments and services have been done. QIOs
monitor all of those code parings to endure that medical necessity has been established. QIOs
also monitor and ensure that when patients are admitted for care, that the admission is reasonable
and appropriate, so that insurance companies are not paying for erroneous services. They also
address quality issues and ensure that all services that have been submitted in coded form on the
claims meet standards that have been set by professional organizations, such as the American
Medical Association (AMA) or the American Nurses Association (ANA).
In hospitals, the QIO department will make sure that the diagnosis and procedure
information that affects the diagnosis-related group (DRG) assignment for a patient’s illness or
condition is properly assigned and clinically present in the medical record. That includes making
a determination as to what conditions are either present on admission (POA) or not present. This
affects patient care that will ultimately be coded and placed on a claim form for reimbursement.
C1. Medicare/Medicaid Patient Protection Act of 1987
This act is also called the “Anti-kickback statute” and ensures that there are criminal
penalties for certain acts that impact both the Medicare and Medicaid programs. A section of
this statute focuses on the concept of the offer or acceptance of payback for granting referrals
and recommending supplies or services that are reimbursed by government health plans.

The remuneration is question can include any rebate (direct or indirect), a bribe situation,
or a kickback of money or goods and is considered a felony and fined $25,000, a possible prison
term of 5 years, or both. Anyone found guilty may also be excluded from the Medicare Program.
This applies to both the person doing the bribing and the person or persons receiving the bribe or
kickback.
In the statute are certain exceptions to the language of the statute that allow some
conditions that would be considered unlawful. A case in point would be a particular discount
given by a supplier to a cost-reporting provider. These are known as “safe harbors” and were set
up and are closely monitored by the Department of Health and Human Services (HHS). Under
the safe harbor provisions are things like: 1) space rental, 2) equipment rental, 3) the sale of
practices, 4) discounts, 5) group purchasing organizations, and 6) a safe harbor0000 to allow any
Federally Qualified Health Centers (FQHC) to provide services to underserved population
demographics.
Legal precedent was set for this statute in the case of United States v. Greber. This case
established the “one purpose test,” which states that if inducement for future referrals was the
one reason for violation, then the one purpose test was satisfied and the statute had been violated.
C2. Medicare Prescription Drug Improvement Act of 2003
This act is also called the Medicare Modernization Act (MMA). The MMA act, signed
into law in 2003, gave CMS a directive to begin a Recovery Demonstration project for three
years. The official agents of this project were called the Recovery Audit Contractors (RAC).
The goal was to help CMS get back inappropriate payments that had been made by the CMS
program to providers. The project was rolled out to a select number of states in the initial phase
with complete rollout to all 50 states upon a successful completion of the project by 2010.

Even though CMS, due to significant compliance efforts, had a declining mistake rate for
5-7 years, it was felt that more improvement could be made. The RAC project was designed to
detect and correct improper payments that had come about in FFS payments. The first three
states RAC targeted were the ones with the highest Medicare population: New York, Florida, and
California.
RACs find potential cases for review using a CMS-designed analysis and identification of
possible bad payments. This resulted in cases flagged for possible error and requests for medical
records to be audited from providers. Claims could be denied due to several reasons, chiefly,
improper coding, no medical necessity being established, bad documentation, duplicate charges,
and unbundling of codes.
CMS was able to demonstrate that $1.03 billion in improper Medicare payments had been
made. About 96% of those payments were overpayments made to providers and 4% were
identified as underpayments that were repaid to providers. CMS deemed the project a success
with a projected cost of 22 cents per dollar, and has implemented a permanent RAC program
using the same commercial entities to be administrators of the program in the four geographical
regions.
D1. Stark II related to Medicare funding
Stark laws state that doctors cannot refer patients to another entity in which that provider
maintains a financial partnership. This can include companies that bill Medicare for durable
medical equipment and supplies, radiology services, home health services, and clinical lab
services.
Medicare is a very large payer for these types of services and CMS makes changes to the
Stark regulations quite often, thus necessitating that providers must review the law at least

annually. Medicare will deny claims that it suspects of violating the Stark law, if it can be
proved that a provider violated the law and Medicare already paid the claim, they can demand a
refund of the amount paid. Medicare can levy civil penalties of $5,000 to $15,000 for each claim
that is found to have violated the Stark law, and three times the amount of any improper
collection by the provider.
D1a. The Effects of Stark laws on Providers
An understanding of the Stark law is of vital importance to healthcare providers to help
them not run afoul of CMS. Cleverley states, “The Stark law was premised on the assumption
that a physician may not make the best medical decision for a patient where the physician has
economic ties to a related for-profit business…healthcare costs may be increased by referring for
services that may not be medically necessary…” (Cleverley, Song, & Cleverley, 2011, p. 92).
With the Stark law, there does not need to have intent proved, unlike the Anti-Kickback
statute. A financial relationship is understood to mean any type of investment or any ownership
and compensation arrangements. There is an exclusion from the statute for services that are part
of a composite payment, as in certain home health and inpatient services or procedures.
If a provider knowingly files a claim and there is found to be a Stark law violation, CMS
can pursue all of the actions referred to in D1, as well as registering the claim with the False
Claims Act (FCA) and involving the Office of the Inspector General (OIG). The OIG will begin
an investigation, sometimes in partnership the Federal Bureau of Investigation (FBI).
CMS holds the position that it may not impose any penalties or further investigations if
the situation is one of temporary non-compliance with the statute. A provider may be under
greater scrutiny, however, to ensure that a pattern of misconduct is not developing. If a provider

does end up having to refund any payments made due to improper behavior, that provider must
make those payments in a timely manner.
D2. Anti-Kickback Statute (AKS) related to Medicare Funding
The AKS is an important regulatory statute that can have effect, such as exclusion for the
Medicare program if providers are found to be violating its provisions. CMS can also
recommend further action in filing under and involving the FCA. Anytime a provider violates
the AKS and proceeds to file a claim with Medicare, that particular claim is considered to be
false, since the act of making a claim by a provider is his or her statement of certification that
they are in compliance with Medicare rules and regulations. Medicare is then justified in
reporting the claim to the OIG to investigate the action under the FCA.
D2a. The Effect of the AKS on Providers
The AKS is important to providers for the reasons detailed in D2 and because if a
provider is investigated for making false claims, the OIG who investigates under the FCA, can
impose some very stiff financial penalties and possible prison terms on providers who violate the
AKS.
Within the FCA is a section that encourages the reporting of suspicious fraud and abuse
in billing and coding situations by rewarding and protecting whistleblowers. The relator of the
misbehavior is protected from employer retaliation and if money is recovered by the OIG, may
receive between 15 to 25 percent.
Under the AKS, providers who make a practice of waiving coinsurance or deductibles are
considered to be in violation of the AKS. They may think they are helping patients in a tough

financial situation, but they should be aware of the consequences. A provider can be excluded
from the Medicare program altogether, either for a certain period of time or for serious offences,
be banned for life. Their names are posted on a list of excluded parties on the OIG and CMS
websites.
The OIG can seek penalties of up to $10,000 for each item or service that was improperly
placed on a claim form. They can also in some kickback cases, seek a possible penalty of up to
$50,000 for each item or service. Many states will also have different versions of kickback
statutes and may use the FBI, in conjunction with OIG to investigate complaints.
E. The Importance of Sherman, Clayton, Federal Trade Commission (FTC) Acts
The Federal Trade Commission (FTC) released a ruling in 2007, establishing the Identity
Theft Red Flag policy. This act requires financial businesses and businesses that offer credit to
customers, have in place policies and procedures to identify and respond to possible patterns that
could indicate different types of identity theft.
This act affects doctors’ offices who extend any type of credit to their patients. This
could take the form of extended payment plans, hardship discounts, professional courtesy
discounts, and cash discounts. Any time a medical office or hospital facility performs services
first and allows patients to make any kind of payments on accounts, the Red Flag rule applies.
The healthcare providers must do several things to be in compliance with this ruling. The
first action that needs to be performed is to do an assessment of the things in the office that could
be at risk of identity theft. Especially vulnerable would be computers and fax machines.
Medical records left lying around are also at risk of people snooping in them and stealing patient
information.

The next step an office should take is to write up a formal Red Flag policy that addresses
the actions the provider will take to reduce the possibility of ID theft from the office. The policy
should also include how to check with law enforcement as a follow-up if a patient states they
have been a victim of ID theft. The third step will include the training procedures that the office
will take to educate the staff on the policy. The training plan should be done on an annual basis
and written documentation should be kept, either with the policy or in the employee’s work file.
This student, as an office manager, made it part of the employees’ annual performance review.
The FTC has the ability to seek civil monetary amounts for violations of the rule. If they
do decide to seek the penalties, they will refer the case to the US Department of Justice (DOJ).
The Justice department may ask for the maximum penalty of $3,500 per violation. Each time the
rule is violated by a practice counts as one violation.
The Sherman Act will apply to all entities who conduct business in this country. The
purpose of the act is to prohibit any agreements that will restrain trade to an unreasonable degree
and allow businesses to fix rates or prices, split up markets or territories into groups of
customers, cause other firms to be boycotted, or to use unreasonable and coercive methods that
could cause harm to other companies.
The government has been trying to include insurance company industry in this act, but
have so far been unsuccessful. The act tries to prevent any action that will cause inefficient
practices with the result being higher prices or a lessening of the quality of services.
Many activities done by businesses may be justified from the viewpoint of business
owners but have been listed as illegal under the Sherman antitrust act because they will cause a
restraint on trade that reaches an unreasonable level. One example of this practice that affects
medical practices is the use of a “no compete” clause that can prevent an entity from selling a

business, and then engaging in that particular business ever again. In many cases, this cannot be
a justifiable action, so would fall afoul of the Sherman act.
Another example of a violation of the Sherman act can be considered in price fixing. In
the healthcare arena, when doctor organizations, hospital groups and other healthcare networks
negotiate with payers as a large group, price-fixing possibilities can arise. Cleverley
states,”…where healthcare providers are all owned by the same parent, sharing price information
is always acceptable.” (Cleverley, et al, 2011, p.104). The DOJ and FTC improved the
guidelines in 1996 and specify how agencies will apply the antitrust laws to the conduct of
providers, facilities, nursing homes and other entities regarding joint purchasing and information
exchange.
The Clayton Act of 1914 will prohibit any mergers or acquisitions that night reduce
competition in a substantial fashion. This holds true of any type of commerce in any part of the
country. In the original act, mergers of competing companies, price discrimination, or the
process of tying and exclusive deal contracts were against the law, but not criminal acts.
The act was modified by Congress in 1950 to stop companies from developing
monopolies. In 1980, Congress added new language to extend the reach of the Clayton act to
any person subject to FTC regulations. Most healthcare providers belong to either partnerships
or are sole proprietors and the amended act now included those also.
The DOJ/FTC agencies apply a five-step process to decide if a merger, especially
involving healthcare entities, have broken any of the provisions of the acts. There are specific
guidelines in the healthcare area to examine and prevent any antitrust problems from stopping
actions resulting in lower costs, increased competition and consumer choice by watching the
issue of hospital mergers. Just last week on 7/21/2016, the DOJ announced it would file a

lawsuit and injunction to stop the merger and acquisition of Cigna Health Plans by Anthem and
Aetna taking over Humana, effectively creating only three giant health insurance plans. They
cited the above antitrust laws in their decisions.
F. Comparisons of AKS of Stark and the Protection Act of 1987
There can be a comparison made of the anti-kickback statutes for both Stark law and the
Medicare Protection act in that providers cannot profit from sending patients as referrals to any
type of business where the doctor may get a cut of the profit from that referral. There have been
many cases in which the DOJ have prosecuted physicians who made referrals to physical therapy
or chiropractic clinics that turned out to be bogus after billing CMS for millions in fraudulent
claims. These doctors were offered a percentage of the money collected when they sent patients
exclusively to a particular clinic and also gave the phony office their provider billing numbers.
With both acts, if a provider and their office are investigated and found to be in violation,
CMS and the OIG will make a decision to prosecute the case in conjunction with the DOJ. If the
OIG decides to not prosecute the case, a provider may negotiate the terms of a specific Corporate
Integrity Agreement (CIA) in exchange for the OIG and DOJ not putting the provider on the
excluded party list and allow continued participation in the Medicare, Medicaid and other federal
plans. This occurs in both the Stark law and the Patient Protection Act. As part of the CIA,
providers agree to submit regular reports to OIG, ensure that written policies and procedures are
made, have a compliance officer and committee, and review questionable practices and claims.
G. Revenue Cycle Management (RCM) Diagram

G1. HIM Department Work in the RCM
The RCM process usually begins with step 1 in the graphic model when the patient’s
insurance coverage is verified by patient access management personnel in the HIM department
and will obtain any necessary prior authorizations for services provided. In step 2, the patient
will then be admitted for healthcare by the admitting department. HIM professionals will
monitor the admission process to ensure that the critical data elements are entered correctly. The
patient’s demographic and financial data are the elements captured most often and must be
correct to facilitate coding and billing. If the patient has been admitted before, the HIM
department must ensure that the correct patient is entered from the Master Patient Index (MPI)
file.
After admission, the patient undergoes their treatment, procedure, or service. After they
have recovered and been discharged, step 3 involves the medical record (MR) being collected by
HIM department to be sorted and analyzed. In step 4, the procedures are coded by the certified
coders within the HIM department. These certified coders interpret the documentation into the
1)Eligibility
Verify pt. coverage
by HIM
2) Patient
admitted by HIM
Treatment/service
done
3) Medical record
reviewedby HIM
4) Services coded
by HIMcoders
5) Billling entered
into PMS
6) Claims sent to
clearinghouse
7) Payment /EOB
received
8) Payment
appliedto PMS
9) A/R analysis &
followup
10) Revenue
recovery
Claims
resubmitted
11) Patient
account billed
Payments posted
Patientaccount
closed

proper ICD-10-CM diagnosis codes and ICD-10-PCS or CPT-4 procedure codes. If there are
any physicians’ records that are unclear or the coders do not have enough information to code for
the services, a query is sent to that physician to provide the missing information.
In step 5, HIM billing personnel enter the coded procedures into the practice management
system (PMS) of the EHR and the claim is generated and scrubbed with editing software, such as
the National Correct Coding Initiative (NCCI) to ensure accuracy. If mistakes are found and the
claim fails to be processed, it is sent back to the revenue cycle management department and the
coders in electronic work queues for correction. Once the claim is clean, in step 6 it will
transmitted electronically to the clearinghouse, who will forward it to the proper insurance
company.
In step 7, payment will be received from the insurance companies with an Explanation of
Benefits (EOB) detailing the amount that was billed, the amount the insurance company paid, the
contractual adjustment the provider must adjust off, and the amount owed by the patient in the
form of copayment, coinsurance, or deductible. In step 8, these amounts are applied to the
patient accounts in the PMS.
Accounts receivable (AR) analysis is started in step 9. The AR ratio represents the
amount collected versus the total amount billed as a ratio. With an A/R ratio of 80% or higher,
the facility is collected the money owed to them efficiently and not leaving large amounts of
money uncollected. Accurate analysis of any problems in the A/R process should be done and
prompt follow-up will ensure a high A/R ratio. In step 10, if the analysis by HIM personnel
finds problems with claim denials, then revenue recovery begins with the claims being corrected
and re-submitted.

After the third-party reimbursement has been received and posted, the HIM and billing
department will begin billing the individual patient accounts, as in step 11. Once the patients
have sent in their payments, those are applied to their accounts to zero them out and signals the
end to that particular RCM course.
H. HIPAA Transaction and Code Sets (TCS) Requirements
The Health Insurance Portability and Accountability Act (HIPAA) Administrative
Simplification Act, Title II, mandates that all medical providers and facilities use a standard set
of codes to transmit electronic information to payers. These code sets are called the Transaction
& Code Sets (TCS).
By requiring the TCS, a uniform standard is set and everyone is “speaking the same
language.” Providers and facilities are not allowed to just make up their own codes for the
procedures they bill for. Chiefly among the TCS and mandated for use are the International
Classification of Diseases, 10th revision, clinical modifications (ICD-10- CM) diagnosis codes,
the ICD-10-PCS inpatient procedure codes for facilities, and Current Procedural Terminology
CPT-4) procedure codes.
The ICD-10-CM codes report the reason for WHY patients come in to see their doctors.
For example, a patient comes in with a non-displaced fracture of the proximal phalanx of the
finger, initial encounter, resulting from a fall from a sidewalk curb. The I-10 code to report the
fracture would be S62.649A and to report the fall from the curb would be W10.1xxA. This
information tells Blue Cross Blue Shield (BCBS), the payer, why the patient was seen that day.
Using a standardized code set, such as I-10, means that any insurance company will know
that exact same information for the patient. Furthermore, if this accident happened while the

patient had been traveling in London, the same codes would be used, since all countries use the
same ICD-10 codes.
The CPT-4 codes are used in physicians’ offices and some outpatient departments of
hospitals to report WHAT treatment or procedure was performed to help heal the patient’s
condition. In the above scenario, the patient with the finger fracture had a closed manipulation
of the fracture to re-align the broken bone and a splint applied to facilitate healing. The CPT-4
code that would be reported is 26720. The claim form submitted to BCBS had the two diagnosis
codes to explain why the patient saw the doctor and the one procedure code to explain what was
done.
Other types of TCS are; drugs provided by a doctor during an office visit, supplies
provided by a medical supply co., the place of service where a procedure or treatment was done,
and codes for dental procedures. By using the required TCS, instances of diseases can be better
tracked and isolated by health organizations, such as the World Health Organization (WHO).
Every covered entity (CE) under HIPAA is required to keep their databases of code
information updated on a yearly basis and delete old codes no longer reported. Many providers
subscribe to coding software that updates the databases as soon as changes are made.
H1. The Impact of TCS on Coders
One of the biggest impacts the TCS will have on coders is to mandate that a coder
maintain his or her proficiency in coding continuously. New codes are released frequently and
regulations may change right along with them. Ignorance is no longer a valid excuse for not
knowing coding information.
The coding of claim forms is an integrated and vital piece of the financial health and
well-being of an office or facility. Coders should be encouraged to become certified and by

doing so, can maintain up-to-date knowledge of the field. Coders must know the regulatory
piece of coding. They must know how to interpret the codes to prevent incorrect information
from being placed on a claim. They must know and understand the rules of assigning codes to
prevent issues such as, coding for coverage, upcoding, downcoding, and unbundling. These
activities are fraudulent behavior and can result in large monetary fines and possible prison.

References
Butler, M. Mastering the Inbox Information Era: Patient-generated Data and Mobile Health are
Changing the Management of Health Information. Journal of AHIMA, Vol 86, no 9, p. 19
Cleverley, W., Song, P.H., Cleverley, J.O. Essentials of Health Care Finance. (2011), 7th ed.
Sudbury: Jones & Bartlett Learning.
Safian, S. & Johnson, M. The Complete Procedure Coding Solution. (2016), 3rd ed. New York:
McGraw-Hill Ed.

C258 Financial Resource Management Task Two

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