Recoupment of Federal Healthcare Dollars: Different Approaches A Comparison of the Medicaid and Medicare Recovery Audits
By Betty Hatten, CPC-H, MHS, MT(ASCP)
While the words “fraud and abuse” have diminished in use, they have been replaced with the latest catch phrases “improper payments” and “recovery audits.” Both Medicare and Medicaid are active in their efforts to remain true to their agency’s survival during this financial crisis through the audit processes. While we are on the front end of the audit implementation it is a good time to compare the nuances of the audits and better prepare ourselves for addressing time lines, audit issues and appeal processes for the federal agencies. But don’t forget—OIG audits and 3rd party payer audits are not going away! Everyone is enforcing their agendas as providers try to maintain their revenue cycle daily activities and keep up with audits.
First off, the similarities between all the various payer audits providers are juggling are less daunting than the differences—so let’s start easy with this comparison. Table 1 delineates the similarities while Table 2 notes the basic differences. Please note that these tables display a segment of the possible comparisons and are not all-inclusive.
Table 1: Similarities between MICs and
RACs
RACs |
MICs |
Notification of selection for an audit
comes in the mail with a specified
number of days to respond. Extensions
are possible. |
Same |
Data
Mining is used on at least some of the
audits in selecting the particular issue
or claim to review. |
Same |
All
providers- not just hospitals or
physicians - who submit claims to this
payer, are eligible for audit. |
Same |
Providers
have the right to appeal the decision. |
Same |
CMS has
contracted with firms to carry out the
audits. |
Same |
Table 2: Differences between RACs and MICs
RACs |
MICs |
RACs are
mandated to post approved issues and
time lines and to reach out to providers
with proactive education on the issues. |
MICs have
no mandate for provider outreach,
however they do have remedial “education
MICS” gearing up for implementation in
2010. They have posted a number of desk
audit examples ranging from
hysterectomies on males, DRG assignments
and debridements.
These are
state specific. |
There are
4 Recovery Audit Contractors and 2 RAC
subcontractors who will oversee
specified regions (A-D) of the country.
Each of the RACs will perform financial
recovery audits for over or
underpayments. There are two types of
audits:
1)
Automated Audits
2)
Complex Audits |
There are
5 Medicaid Integrity Contractor
jurisdictions each covering 2 CMS
regions. There are 3 primary types of
MICs:
1)
Review MICs
2)
Audit MICs
a)
Desk Audits
b)
Field Audits
3)
Education MICs |
RACs are
reimbursed on a contingency fee basis. |
MICs are
eligible for bonuses based on their
effectiveness and efficiency. |
RACs will
not look at claim that has been
previously audited by any CMS entity. |
MICs
exclude previous State audits and will
not interfere with potential law
enforcement investigation. |
The
appeal process is consistent nationwide. |
The
appeal process is based on state
guidelines. |
RAC look
back period is 3 years. |
MIC look
back is based on the particular state
guidelines. |
RACs
allow providers 45 days to produce
medical records and pays 12 cents per
page for copying. |
MICs will
give providers up to 14 days (extensions
are available if requested) to produce
the medical records. There is no payment
for copying the records. |
The
number of records reviewed is limited to
200 for the RAC audits. |
There is
no record limit for MICs. |
And while we are all developing home grown electronic tracking tools to avoid missing drop dead dates or purchasing audit software from vendors, the OIG and various insurance companies are surprising all of us with their random audits and requests. Remember the old saying about “the devil is in the details?” In the case of RACs and MICs it truly is the little things that can result in major problems that haunt us.
Needless to say, there are many, many comparisons that could be explored on the topic of auditor guidelines and specifications and we have only addressed a baker’s dozen. No doubt we need to re-address RACs and MICs toward the end of the year when we all have had a chance to experience them live!
The Global Surgical Package
By Laurie Desjardins
What’s included? How the global surgical package is defined varies slightly between Medicare and the AMA. For those of you who are familiar with Medicare’s “package,” the AMA’s looks very similar. Per the AMA CPT
the Surgical Package always includes:
• Local anesthesia – metacarpal/metatarsal/digital blocks or topical.
• Related E/M services the day before or on the date of the surgery (Excluding the decision for surgery).
• Immediate postoperative care.
• Writing orders.
• Evaluating the patient in the recovery area.
• Typical post-operative follow-up care.
o The AMA further defines post-operative care as: Diagnostic = recovery from the procedure itself; and Therapeutic = care that is usually part of the service (0, 10, 90 days).
Medicare’s definition of Surgical Package, on the other hand, always includes:
• Pre-operative visits, beginning the day before the surgery.
• All services performed intra-operatively that are a necessary part of the surgery.
• All medical or surgical services required by the surgeon within 10-90 days post-operatively, including any complications that do not require the physician and patient to return to the O.R.
• Any follow-up visits during the 10-90 day period.
• Normal post-operative pain management.
• Medicare classifies surgical procedures as “Major” or “Minor.” Major procedures are assigned a 90 day follow-up period; whereas minor procedures are assigned a 10 day follow-up period.
Medicare’s definition is published in the Medicare Internet Only Manuals (Medicare Claims Processing, Pub. 100-04, Ch. 12, Sec. 40).
Frequently Asked Questions. Because there is this difference in definition, there are several questions that are frequently asked:
Q. Can nerve blocks be billed separately from the surgery?
A. Nerve blocks (64400-64520) are not separately reportable if done as an anesthetic for a surgical procedure. If you are administering nerve blocks for pain management separate from a surgical service these codes can and should be reported.
Q. How do I bill for a preoperative physical?
A. Once the decision for surgery has been made preoperative physicals are only reimbursable if they are deemed medically necessary. If the pre-op exam is done within 24 hours of a major surgery (90 day post-op) or the same day as a minor surgery then it is included in the global package. If you are outside this period and think the exam will meet the medical necessity guidelines because the patient has an underlying condition that may adversely affect the surgical outcome you should be able to get reimbursed for the clearance exam. You first need to report the service with the appropriate level visit code 99201-99215 or 99241-99245. For diagnosis coding you need code with the appropriate preoperative screening code V72.81 – V72.84, then the underlying condition you are evaluating, then the reason for the surgery.
What’s NOT included? Neither the AMA nor Medicare’s definitions for global package include the decision for surgery; post-op care outside of the global package; unrelated visits and services or procedures; or staged or unrelated procedures.
Decision for surgery. If the decision for surgery is made within 24 hours of a “major” surgery (90 postop) or on the day of a “minor” surgery (less than 90 postop) you need to indicate the E/M service you rendered was to make that decision. You do that by appending a modifier –57 or –25 to the visit code. For coding purposes, modifier –57 is the decision for major surgery while modifier –25 is used in this case to indicate the decision for minor surgery. Failure to use these modifiers appropriately may cause claims denials.
Post-op care outside the global package. As you well know, not everything you do within the post-operative period is related to the actual post-operative care. In order to indicate that a service or procedure is outside the global package, you must use the appropriate modifier. If you don’t, chances are high that the services will be denied.
Unrelated visit. If the patient is seen during the global period for an unrelated problem, that visit may be separately reportable. In this case, you should report modifier –24 (unrelated E/M service by the same physician during the postoperative period).
Honest answers are required when determining if the service is unrelated or not. For example: one of the risks of surgery is pneumonia. If the patient gets pneumonia while hospitalized can the treatment of this problem be considered outside the global package? The answer depends upon the type of surgery the patient has undergone and how common it is that patients who have had this surgery experience this problem. For an orthopedic patient this would be a relatively rare occurrence and unrelated to the surgery. Therefore, care for this problem by the operating physician would be separately reportable and modifier –24 should be reported along with an appropriate diagnosis that is different from the reason for the surgery. If, on the other hand, the patient is recovering from lung surgery, the incidence of pneumonia would probably be much higher and a common postoperative complication. In this case, the problem would be considered part of the post-operative care and is separately reportable.
Unrelated service or procedure. If you provide a service or procedure that is unrelated to the original problem or requires a return to the operating room, that service is separately reportable. Coding requirements are that you append either modifier –79 (unrelated procedure by the same physician during the postoperative period) or –78 (return to the operating room for a related procedure during the postoperative period). Modifier –78 is used when complications occur that require a return to the OR for repair (a patient has to be brought into the OR for the drainage of a peritoneal abscess after abdominal surgery 5 days ago).
Staged or related procedures. The rest of this seems pretty straightforward but just to make sure that we don’t think that coding is too simple, lets throw a wrench into the works— modifier –58 (staged or related procedure by the same physician during the postoperative period). So what’s the difference between modifier –78 and –58 besides the first digit? The answer is: “did you plan to have to do addition work such as another surgery or therapy following a diagnostic procedure?” If you planned to do more or additional services at the conclusion of the original surgery, then modifier –58 should be used. Modifier –78, however, should be used if the return to the operating room was not planned in advance. The important distinction here is that –58 does not require a return to the operating room as –78 does.
The table below helps illustrate the appropriate use of these modifiers.
MOD |
Nomenclature |
Billing Information |
Example(s) |
-24 |
Unrelated E&M Service by the Same
Physician During a Post-op Period:
The physician may need to indicate
that an evaluation and management
service was performed during a
postoperative period for a reason(s)
unrelated to the original procedure.
This circumstance may be reported by
adding the modifier ‘-24’ to the
appropriate level of E&M service. |
-
Append to E&M services only
-
Only
appropriate if the visit is not
related to a global surgery service
-
Use
if the operating physician or
physician who has assumed post-op
care performs an office visit during
the postoperative period |
-
Patient presents in the office with
a sprained wrist during the
postoperative period for a broken
ankle. While learning how to
ambulate on crutches, the patient
fell and sprained a wrist.
-
Append -24 to the E&M code for the
sprained wrist to indicate that the
E&M service was unrelated to the
broken ankle
-
Coding example: 99212-24 |
-25 |
Significant, Separately Identifiable
E&M Service by the Same Physician on
the Same Day of the Procedure or
Other Service:
The physician may need to indicate
that on the day a procedure or
service identified by a CPT code was
performed, the patient's condition
required a significant, separately
identifiable E&M service above and
beyond the other service provided or
beyond the usual preoperative and
postoperative care associated with
the procedure that was performed.
The E&M service may be prompted by
the symptom or condition for which
the procedure and/or service was
provided. As such, different
diagnoses are not required for
reporting of the E&M services on the
same date. This circumstance may be
reported by adding the modifier
‘-25’ to the appropriate level of
E&M service. Note: This modifier is
not used to report an E&M service
that resulted in a decision to
perform surgery. See modifier
‘-57’. |
-
Use
on E&M services only
-
The
service must be unrelated to other
services on the same day OR
-
The
service must be above and beyond the
other service provided OR
-
The
service must be beyond the usual
preoperative and postoperative care
associated with a minor surgical or
diagnostic procedure that was
performed (including decision for
surgery) on the same day
-
Per
the AMA a separate diagnosis is
not required to report modifier
-25
-
Payors vary on the acceptance of
this modifier. If you have questions
with a payor you can request their
policy in writing
________________________________
Post-op periods breakdown by
Major/Minor Surgery: If post-op is
<90 days, pre-op = same day as
surgery. If post-op is 90 days,
pre-op = 1 day prior to surgery. |
-
An
established patient presents in the
office for an irritated and enlarged
cyst. An E&M service was
performed. It was decided that the
cyst would be excised.
-
Both
of these services would have the
same diagnosis and would be allowed
for separate reimbursement when
modifier -25 is appended to the E&M
service. Prior to the patient being
evaluated in the office, the cyst
excision was not planned; therefore,
the E&M service is separately
identifiable and reportable
-
Coding example: 99214-25, 10060
__________________________________
-
An
established patient presents in the
office for a rash, at the conclusion
of the exam the patient requests a
flu shot.
-
The
E&M service is not related to the
vaccine
-
Coding example: 99213-25, 90732,
90471 |
-57 |
Decision for Surgery:
An E&M service that resulted in the
initial decision to perform the
surgery may be identified by adding
the modifier ‘-57’ to the
appropriate level of E&M service. |
-
Use
on an E&M service that is related to
a major surgery which has a
postoperative period of 90 days
-
Use
on an E&M service when the decision
to have surgery was made within 24
hours prior to the surgical
procedure
-
Do
not use modifier -57 for
pre-surgical history and physical
-
Do
not use modifier -57 for services
related to minor surgical procedures
*Note: Use modifier -25 for
E&M services related to a minor
surgical procedure. See also -25
modifier guidelines. |
-
A
patient presents with acute
abdominal pain; an E&M service is
performed
-
Upon
examination, it is determined that
the patient has appendicitis and an
appendectomy is scheduled for later
that day
-
Since
the appendectomy has a global period
of 90 days, the E&M service
performed should be appended with
modifier -57 indicating a decision
for surgery was made
-
Coding example: 99215-57, 44950 |
-58 |
Staged or Related Procedure or Service by the Same Physician
During the Post-op Period: The
physician may need to indicate that the performance of a procedure or
service during the postoperative period was:
a) planned prospectively at the time of the original procedure
(staged); b) more extensive
than the original procedure; or c) for therapy following a diagnostic
surgical procedure. This circumstance may be reported by adding the
modifier ‘-58’ to the staged or related procedure. Note: This
modifier is not used to report the treatment of a problem that requires
a return to the operating room.
See modifier ‘-78’. |
-
Primarily appended to surgical
codes
-
If applied to E&M service
codes, the service will be denied for inappropriate modifier
-
Use when the second and/or
related staged service is performed during the postoperative period of
the original or first procedure
-
Restarts global postoperative
period
*Note:
For unplanned, subsequent surgical procedures, see modifier -78;
see also -76 or -77 for repeat procedure |
-
After a partial colon
resection, chemotherapy is needed within the 90 day postoperative period
-
The patient has poor peripheral
venous circulation and an implantable venous access port (with subQ
reservoir) is placed for infusion of chemotherapy
-
Coding example:
36533-58 |
-78 |
Return to the Operating Room for a
Related Procedure During the Post-op Period: The physician may need to indicate that another procedure was
performed during the postoperative period of the initial procedure. When
this subsequent procedure is related to the first, and requires the use
of the operating room, it may be reported by adding the modifier ‘-78’
to the related procedure. (For
repeat procedures on the same day, see ‘-76.’) |
-
Must be appended to a surgical
code
-
Surgery must be performed in
the operating room
-
Use on surgical codes to
indicate that another surgical procedure was performed during the
postoperative period of the initial procedure
-
Must be related to the first,
original procedure but not planned prior to the previous surgery
-
Use when the surgery is a
result of complications of the initial operative session (may or may not
be the same day)
*Note:
See modifier -58 for staged or related service during the
postoperative period; -76 for a repeat procedure by the same physician;
and -77 for a repeat procedure by another physician |
-
A femoral-popliteal non-autogenous
bypass graft is placed on October 1
-
On October 3, an infection is
noted in the lower extremity of the bypass graft
-
A return to the operating room
is required to explore the site
-
The surgery in the operating
room was performed during the postoperative period of the bypass graft
and is related to the bypass graft
-
Coding example:
35860-78 |
-79 |
Unrelated Procedure or Service by the
Same Physician During the Post-op Period: The physician may need to indicate that the performance of a
procedure or service during the postoperative period was unrelated to
the original procedure. This circumstance may be reported by using the
modifier ‘-79’. (For repeat
procedures on the same day, see
‘-76.) |
-
Do not use on E&M codes
-
Applicable to surgical
procedures only
-
Use only during a postoperative
period to identify a service that is unrelated to the original procedure
-
Use only if the diagnosis is
different than the diagnosis requiring the original procedure
-
Used only if the surgery is
performed by the same physician as the original procedure during the
postoperative period of the original procedure
*Note:
See modifier -24 for E&M service |
-
Patient has a total knee
replacement on September 1
-
On September 15, the patient
falls and requires fracture care, open treatment (25620)
-
The surgery is performed during
the postoperative period of the knee surgery but is unrelated to the
knee surgery
-
Coding example:
25620-79 |
AMA Coding Guidance:
January 2010 CPT Assistant
By Jennifer Ridell, CPC
Medicare Physician Payment Changes for 2010
The 2010 changes to Medicare physician payments include a zero percent increase to the conversion factor through February 28, 2010. Additionally, the American Medical Association (AMA) and the RVS Update Committee (RUC) reviewed the new and modified CPT codes for 2010 and currently coded services that are potentially misvalued. CMS accepted 98% of the recommendations the RUC made for the new and modified 2010 codes. Specifically, CMS made payment policy decisions for some of the new codes including, 90470, H1N1 immunization administration. CMS made it clear that this new CPT code will not be used within the Medicare program because a separate HCPCS code, G9141, influenza A (H1N1) immunization administration (including physician counseling of the patient/family), was created for reporting this service. Other decisions related to consultation services (CPT codes 99241-99245 and 99251-99255) and bundled services (78451-78454, 51726-51729, 92540, 92550, and 92570) are also discussed.
What's New in the CPT Codebook.
The AMA is providing an overview in formatting changes in the CPT Codebook. The last time the AMA provided an informative article similar to this was in 1999. The new resequencing symbol is discussed along with the symbols for vaccine codes pending Food and Drug Administration approval, codes including moderate sedation and reinstated codes. In addition to new symbols, changes in the appendices are also reviewed. Since the publication of the last article similar to this in 1999, eight new appendices have been added to the CPT Codebook including: Appendix G (summary of CPT codes that include moderate sedation), Appendix I (genetic testing code modifiers), and Appendix N (resequenced codes).
Coding Clarification: Stress Echocardiography (Codes 93015-93018 and 93350-93352).
CPT codes 93015-93018 cover cardiovascular stress tests. This test includes continuous electrocardiographic monitoring, physician supervision, and reporting. The sensitivity and specificity of a cardiovascular stress test can be improved by coupling it with an image modality such as echocardiography or nuclear perfusion imaging. CPT codes 93350 and 93351 cover stress echocardiography which is performed before, after, and sometimes during a stress test to monitor pump function of specific walls in the heart.
CPT code 93350 is used to report a stress echocardiogram without all the components of a full stress test. This code can be reported in a non-facility setting and providers must report the appropriate stress test code from the 93016-93018 series to capture the necessary exercise stress test portion. Code 93351 is used in a non-facility setting to report the complete service of a stress echocardiogram and a complete cardiovascular stress test performed by a physician. Add-on code 93352 can be reported with either 93350 or 93352 to cover the administration of a contrast agent to improve the delineation of the left ventricular endocardial borders during a stress echocardiogram. Additional codes that may be added to the stress echocardiogram include 93320, 93321, and 93325 for Doppler echocardiography procedures. If a transthoracic echocardiography (93303, 93304, and 93306-93308) is performed on the same date of service as a stress echo (93350-93352) for a different clinical circumstance, modifier 59 should be appended to designate a distinct procedural service.
Coding Consultation: Questions and Answers.
An article by the CPT Editorial Panel answers questions posed to the panel regarding the subjects of surgery/musculoskeletal system, respiratory system, cardiovascular system, digestive system, pathology and laboratory/surgical pathology, medicine/psychiatry, and appendix a/modifiers. The responses answer multiple questions including: should code 28740 be reported for arthrodesis of the calcaneocuboid joint or arthrodesis of the talonavicular joint and is it appropriate to report CPT code 88321, when in fact, there has already been one consult provided and billed for the same material, including a review of the pathology report?
To view these articles via CCH Coding Comply, search from the Search Code Sets tab in Coding Comply for any of the codes listed above, view the Related Documents by clicking on the paper icon next to the code, then select the article. To view these articles in The Coding Suite go to the CPT Assistant Archives folder and in the Search field within this folder and enter “January 2010.”
Editor’s Note: All tiers of The Coding Suite include an electronic CPT Code Book that includes all 2010 changes as well as all updates made to this code set during the 2010 calendar year. Customers are able to search by code description or number; or you can menu walk through the electronic book as broken out into the procedural category. In addition, all 2010 appendices are offered electronically. To view this code book, look in “Hot Topics” on the home page of your subscription and click on the 2010 CPT and HCPCS Code Book link.
General Coding News
New Reporting Requirement for Dialysis Adequacy, Infection, and Vascular Access.
The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) requires CMS to begin a quality based payment program effective for dialysis services beginning January 1, 2012. There are currently two monthly measurements of quality of care on End Stage Renal Disease (ESRD) claims that would meet the minimum quality measurements required by MIPAA. These two measurements are: hemoglobin or hematocrit as a measure of anemia management and urea reduction ratio (URR) as a measure of hemodialysis adequacy. Additionally, MIPPA also mandates that CMS uses quality measures approved by a consensus organization. CMS has received National Quality Forum (NQF) endorsement for ESRD quality measures.
CMS and NQF determined that instead of using the URR information for quality measurements, Kt/V for both hemodialysis and peritoneal dialysis patients is a better option. Additionally, two additional quality measures are also required. There are HCPCS modifiers (V5-V7) used to report the use of an arteriovenous fistula or vascular catheters and by collecting vascular access data, CMS will be able to create a comprehensive quality based payment program without burdening dialysis providers since this data is already required for the Fistula First Initiative. The changes in reporting are effective July 1, 2010 which will allow CMS enough time to implement an accurate payment program for providers by their deadline of January 1, 2012. Medicare Claims Processing Manual, Pub. 100-04, Transmittal No. 1898, Jan. 29, 2010.
These transmittals can be viewed on the IRN or IntelliConnect at ¶158,784 in the January 29, 2010, CCH Coding Comply What’s New newsletter; or on Rex via The Coding Suite in the CMS Transmittals and MLN Matters Articles folder under the titles “R1898CP
Dialysis Adequacy, Infection and Vascular Access Reporting.”
Outpatient Intravenous Insulin Treatment Nationally Non-covered.
Effective December 23, 2009, CMS determined that outpatient intravenous insulin therapy (OIVIT) does not improve the health outcomes for Medicare beneficiaries and is therefore nationally non-covered by Medicare. This decision impacts the use of CPT codes 99199 and 94681 and HCPCS code G9147. Effective April 5, 2010, CPT code 99199, unlisted special service, procedure, or report, is no longer an appropriate code to report OIVIT. Also, effective on April 5, 2010, CPT code 94681, exhaled air analysis CO2, should no longer be reported in conjunction with OIVIT or diabetes-related conditions which are designated with ICD-9-CM diagnosis codes 250.00-250.93. If these two CPT codes are included on claims for OIVIT they will be returned as unprocessable and should be billed with new HCPCS code, G9147, Outpatient Intravenous Insulin Treatment (OIVIT) either pulsatile or continuous, by any means, guided by the results of measurements for: respiratory quotient; and/or, urine urea nitrogen (UUN); and/or, arterial, venous or capillary glucose; and/or potassium concentration. Medicare National Coverage Determinations Manual, Pub. 100-03, Transmittal No. 112, Feb. 5, 2010, and Medicare Claims Processing Manual, Pub. 100-04, Transmittal No. 1913, Feb. 5, 2010.
These transmittals can be viewed on the IRN or IntelliConnect at ¶158,799 and ¶158,805 in the February 12, 2010, CCH Coding Comply What’s New newsletter; or on Rex via The Coding Suite in the CMS Transmittals and MLN Matters Articles folder under the titles “R112NCD
Outpatient Intravenous Insulin Treatment (Therapy)” and “R1913CP
Outpatient Intravenous Insulin Treatment (Therapy).”
Revised Clinical Laboratory Fee Schedule and ZIP Code File to include Kansas Payment Locality Structure.
Clinical Laboratory Fee Schedule payments for reference laboratory claims in Kansas are not being paid properly. Zip code files have always been used to determine what locality payment should be calculated under. Kansas has always had two counties (Johnson and Wyandotte) that mapped to Western Missouri, but the system has not been set up to detect that. Beginning in 2010, CMS has revised the Clinical Laboratory Fee Schedule to include two localities for east and west Kansas. These changes will now allow the two counties mentioned above to be properly mapped to either of the two Kansas localities when laboratory service claims with the 90 modifier, reference (outside) laboratory, are submitted. One-Time Notification Manual, Pub. 100-20, Transmittal No. 638, Feb. 12, 2010.
These transmittals can be viewed on the IRN or IntelliConnect at ¶158,819 in the Feb. 22, 2010, CCH Coding Comply What’s New newsletter; or on Rex via The Coding Suite in the CMS Transmittals and MLN Matters Articles folder under the title “R638OTN
Revised Clinical Laboratory Fee Schedule and ZIP Code File to include Kansas
Payment Locality Structure.”
NOTE: To follow the MediRegs links above, you will need to be a subscriber to the Coding Suite of products and if prompted, enter your username and password. If you cannot remember your user name or password go to: http://wk.mediregs.com/login_fs.html and the system will let you request a reminder. For the Internet Research Network or IntelliConnect links, you will need to be a subscriber to the CCH Coding Comply.
Requests for information about article submission and comments from readers are welcome and should be directed to at Nicole Stone at Nicole.Stone@wolterskluwer.com, Fax 847-267-2514. Customer service inquiries should be directed to 800-449-9525. CCH Coding Compliance Advisor is published monthly by CCH, a Wolters Kluwer business
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