1. Diagnosis Assignment Sequencing and Coding for Long Term Care
Presented by:
Lizeth Flores, RHIT, RAC-CT
Anderson Health Information Systems, Inc.
940 W. 17th Street, Suite B
Santa Ana, California, 92706
Tel. (714)

2. Objectives Correctly identify primary / Secondary diagnoses
Participants will:
Correctly identify primary / Secondary diagnoses
Correctly assign ICD-9-CM codes to diagnoses
Correctly sequence diagnoses for coding assignment

3. Purpose of ICD-9-CM Coding
Statistical Data
Billing and reimbursement
Compliance with Federal Reporting Standards / HIPAA
Provide data into the types of Residents and conditions treated
ICD-9-CM Official Guidelines for Coding and Reporting
HIPAA

4. Requirements
Official coding guidelines require the use of V codes for aftercare and specify that applicable aftercare V-codes are to be used for conditions requiring continued / long term care or healing phase of a condition/disease.
The official coding guidelines are developed by CMS (Centers for Medicare and Medicaid Services) & NCHS (National Center for Health Statistics) and updated in October and April of every year.

5. Requirements
Per ICD-9-CM Official Guidelines for Coding and Reporting, aftercare codes are generally first to explain the specific reason for the encounter (admission)
Certain aftercare code categories need a secondary dx code to describe the resolving condition or sequelae
For others (V codes) the condition is inherent in code title
2. For example when a resident is admitted for physical therapy (aftercare) following a hip fracture (V57.1 physical therapy, V54.13 fracture, hip, healing, traumatic)
3. For example aftercare for healing traumatic facture of upper arm (V54.11), status post prostatectomy for BPH (V58.76)

6. The FI will not accept V-codes as principal diagnosis - is an INCORRECT statement.
The Principal DX must be reported according to Official ICD-9-CM guidelines for coding and reporting, as required by HIPAA including any applicable guidelines regarding the use of V-Codes

7. Not So New Coding clinic Fourth Quarter 1999
Published rules for the use of V codes
Addressed the use of V codes in LTC settings
Coding clinic Fourth Quarter 2003
Clarified the use of aftercare V codes for all subsequent encounters after the initial treatment for a fracture
“for statistical purposes, a facture should only be reported once”

8. CMS Manual System Transmittal 437
Principal Diagnosis Code - SNFs enter the ICD-9-CM code for the principal diagnosis in FL 67. The code must be reported according to Official ICD-9-CM Guidelines for Coding and Reporting, as required by the Health Insurance Portability and Accountability Act (HIPAA), including any applicable guidelines regarding the use of V codes. The code must be the full ICD-9-CM diagnosis code, including all five digits where applicable.
Other Diagnosis Codes Required – The SNF enters the full ICD-9-CM codes for up to eight additional conditions in FLs Medicare does not have any additional requirements regarding the reporting or sequence of the codes beyond those contained in the ICD-9-CM guidelines.

9. Medicare Claims Processing Manual 100-04
Chapter 6 - SNF Inpatient Part A Billing and SNF Consolidated Billing

10. 30 - Billing SNF PPS Services (Rev
30 - Billing SNF PPS Services (Rev. 2011, Issued: , Effective: , Implementation: )
Principal Diagnosis Code - SNFs enter the ICD-CM code for the principal diagnosis in the appropriate form locator. The code must be reported according to Official ICD-CM Guidelines for Coding and Reporting, as required by the Health Insurance Portability and Accountability Act (HIPAA), including any applicable guidelines regarding the use of V codes. The code must be the full ICD-CM diagnosis code, including all five digits where applicable.
Other Diagnosis Codes Required – The SNF enters the full ICD-CM codes for up to eight additional conditions in the appropriate form locator. Medicare does not have any additional requirements regarding the reporting or sequence of the codes beyond those contained in the ICD-CM guidelines.

11. What if….. Could the facility face claim denials due to this change?
NO – the FI is well aware of the ICD-9-CM coding guidelines and requirements.

12. Ready ……..Set…….Go

13. Definition of Principal Diagnosis
“FIRST LISTED DIAGNOSES” is the diagnosis that is chiefly responsible for the admissions to, continued residence in the nursing facility and the diagnosis that support the reimbursement and should be sequenced first.”
Medicare – To be covered the extended services must be for the treatment of a condition for which the resident received inpatient hospital services during the 3-day qualifying stay

14. V Codes as principal diagnosis
V Codes may be listed as a principal or secondary diagnosis as stated in official coding guidelines
V Codes are used in both inpatient and outpatient setting
V Codes indicate a reason for an encounter

15. Type of Codes used in LTC
Aftercare – used when the initial treatment of a disease or injury has been performed and the patients still requires continued care to heal or recover.
Late Effects – a late effect is a residual condition that remains and requires medical evaluation, rehab treatments and/or nursing care after the initial illness or injury.

16. Type of Codes…………
History of – (Hx) – history codes are acceptable on any Medical record regardless of reason for admission/encounter.
A history code is distinct from a “status” code in that history codes indicate that the patient no longer has the condition and “status” codes indicated a present state.

17. Practice #1 Chose from the following and assign the Correct category:
After Care
Late Effect
Chronic Condition
Acute Condition

18. Practice #1 (cont.) Hemiplegia following due to recent CVA Late Effect
Total Hip Replacement
Acute UTI treated with Cipro.
Dementia
Late Effect
After Care
Acute Condition
Chronic Condition

19. What to Code?
ALL CONDITIONS THAT EXIST AT THE TIME OF ADMISSION, THAT EFFECT TREATMENT RECEIVED

20. DO NOT CODE DIAGNOSES THAT DO NOT AFFECT TREATMENT OR LENGTH OF STAY
WHEN CONDITION NO LONGER EXISTS
DO NOT ASSIGN PROCEDURE CODES
Examples: Fractured forearm 6 years ago, pneumonia, UTI that were resolved (these will only be coded if the Resident is admitted with Antibiotics)

21. Locating the Principal Diagnosis

22. Section II. Selection of Principal Diagnosis
The circumstances of inpatient admission always govern the selection of principal diagnosis. The principal diagnosis is defined in the Uniform Hospital Discharge Data Set (UHDDS) as “that condition established after study to be chiefly responsible for occasioning the admission of the patient to the hospital for care.”
For SNF reason for admission to the facility

23. EXAMPLES
1. Resident was treated for UTI at the hospital and is still on IV antibiotic therapy.
2. Resident had surgery for a bowel obstruction and needs care to the surgical site and physical / occupational therapy

24. 1. UTI can be the primary diagnosis since Resident is still receiving ATB therapy
2. First listed diagnosis would be admission for multiple therapies and secondary diagnosis aftercare following surgery to the digestive system.

25. Admissions/Encounters for Rehabilitation
When the purpose for the admission/encounter is rehabilitation, sequence the appropriate V code from category V57, Care involving use of rehabilitation procedures, as the principal/first-listed diagnosis. The code for the condition for which the service is being performed should be reported as an additional diagnosis.

26. V57 – Care Involving Rehab
Category V57 does not indicate that rehab services were provided, only that the resident was admitted for this purpose

27. Only one code from category V57 is required. Code V57
Only one code from category V57 is required. Code V57.89, Other specified rehabilitation procedures, should be assigned if more than one type of rehabilitation is performed during a single encounter. A procedure code should be reported to identify each type of rehabilitation therapy actually performed

28. V57 Care Involving Rehab
Code also the condition requiring the rehab, such as:
Residuals
Late effects
Aftercare
symptoms

29. Choose the Principal Diagnosis
Fall 3 months ago
Chronic kidney disease
Above the knee amputation Rt. Leg (10 days ago)
Anemia
MRSA of surgical wound (resolved)

30. Where are the diagnoses???
Transfer Records
History & Physical
Progress Notes
Admission Orders

31. Discharge summary
Transfer documentation
Surgical reports
Consultations
Physician Progress notes
Lab reports and radiological studies

32. Diagnosis Sequencing
The order in which codes are listed is called sequencing.
Every effort should be made to record the codes in a logical sequence that is descriptive of the resident’s condition.

33. Secondary Diagnoses May have multiple secondary codes
List and code conditions related to therapy and services provided
Review and update as condition changes – sequence may change over time
Billing staff should work with Nursing and Health Information Department to know which diagnoses are current, which is principal, etc.
Handout #1 If you have a H.O, include that H.O. and # in the slide,

34. Secondary Diagnoses Order by complexity.
Assign the condition with the higher complexity first. (those that require the most resources i.e. wound care vs. hypertension)
All conditions present at the time of admission, and that affect the treatment provided and length of stay should be coded.
Describe how you determine that again.////

35. Choose the correct sequence
Diabetes
Fx left forearm due to fall last week
UTI (on antibiotics)
Hyperlipidemia

36. Acute Diagnoses
Acute dx treated in the hospital should be coded until the condition is resolved, after the resident is transferred to the SNF
Examples:
MRSA
Pneumonia
UTI
CVA

37. V-Codes Remember not to use acute care codes when coding aftercare
V-codes are assigned to problems that affect the patient’s health but are not in themselves a current illness or injury
V-codes can be used to represent status or history.
Examples:
Status Cardiac Pacemaker V45.01
Status heart valve prosthesis V43.3
History of falls V15.88
CABG V45.81
Remember not to use acute care codes when coding aftercare

38. Aftercare are used when the initial treatment has been performed but the patient continues to need care during the healing / recovery phase
Examples:
Aftercare following surgery
Physical and/or occupational therapy
Aftercare for healing traumatic fracture

39. Let’s Practice
Admitted for physical therapy, status post total knee replacement due to arthritis
1) Admission – rehabilitation – physical
2 ) Aftercare – following surgery for – joint replacement
3) Replacement – joint – Knee
V57.1, V54.81 , V43.65

40. Post hysterectomy for uterine cancer three years ago (no further treatment)
History – personal – malignant neoplasm – uterus
V10.42

41. Assigning Code Numbers
Both the Alphabetic Index and the Tabular List must be used when locating and assigning a code.
Do not rely on just one since this can lead to errors in code assignment and a less specific code selection

42. How to Select Codes
Locate each main term and subterm in the alphabetical index, i.e., Chronic Kidney Disease Disease
1. Disease 2. Kidney 3. Chronic
Verify the code selected in the Tabular list
Read and be guided by instructional notations that appear in both the Alphabetic Index and the Tabular List
585.9

43. Code to the Highest Level of Specificity
Assign 3 digit codes only if there are no four digit codes within the category.
There are only 100 codes with only 3 digits
Assign 4 digit codes only if there is no fifth digit.
Assign 5 digit codes when indicated.
Samples – 486, 401.x, 250.xx

44. Let’s Practice Scabies Colitis Hypertension
Benign prostatic hypertrophy (BPH)

45. Scabies
Colitis – 558.9
Hypertension – 401.9
Benign Prostate Hypertrophy

46. To “V” or not to “V” Scenario # 1
A resident is admitted for physical therapy following a hip replacement for an right hip fracture due to a fall.

47. To ‘V’ or Not to ‘V’: Scenario #1
Physical therapy:
V57.1 Physical Therapy
Intertrochantic right hip fracture due to a fall:
V54.13 Aftercare following traumatic hip fracture
Hip replacement:
V54.81 Aftercare following joint replacement
V43.64 Joint replacement, hip

48. To ‘V’ or Not to ‘V’: Scenario #2
A resident is admitted for P.T. & O.T.
following a hip fracture after a fall.
The physician indicated that the fracture was due to osteoporosis. The Discharge Summary stated that old compression fractures of the vertebrae due to osteoporosis were present on x-ray.

49. To ‘V’ or Not to ‘V’: Scenario #2
Physical Therapy and Occupational Therapy
V57.89 Multiple therapies
Hip Fracture (due to osteoporosis)
V54.23 Aftercare for continuing treatment of healing pathologic fracture of hip
Osteoporosis
Osteoporosis
Compression fractures of vertebrae
Pathologic fractures of vertebrae

50. Combination Codes “AND”, “AND/OR”
A single code used to classify TWO (2) diagnoses or a diagnosis with an associated manifestation or complication.
Key words:
“AND”, “AND/OR”
“WITH”, “WITH MENTION OF” OR “ASSOCIATED WITH”
“EXCLUDES”

51. Combination Codes
Single codes used to classify two diagnosis or a diagnosis with a manifestation
Example:
Candidiasis with meningitis

52. Let’s Practice 1. Chronic Peptic Ulcer with Hemorrhage
2. Cerebral thrombosis with cerebral infarction
3. Diverticulitis of Duodenum “with” bleeding

53. Manifestation Codes
There are written instructions in ICD-9-CM coding books for sequencing codes.
The underlying Dx (cause/s) coded first, followed by codes for manifestations.

54. Manifestation Codes Diabetic Neuropathy
Diabetes with neurological manifestations must be coded first (250.60)
The tabular list will guide you to “Use additional code to identify manifestation, as:”
Polyneuropathy in diabetes (357.2)
The tabular section will tell you that this code is not allowed as a principal Dx and will guide you to code underlying disease, as (Diabetes with complication…)

55. Combination Codes Etiology codes – USE ADDITIONAL CODE
Manifestation codes – CODE 1st Underlying Dx.
Codes in parentheses identify conditions that require multiple coding. Also, codes in parentheses CAN NOT be sequenced as PRINCIPAL Dx.
331.0 Alzheimer's Disease
Dementia in conditions classified elsewhere *Dementia of the Alzheimer’s Type*
Tabular list directs you to code underlying physical condition first as:
Alzheimer’s disease (331.0)

56. Combination Codes Anosmia following CVA 438.6, 781.1
“with”, “with mention of”, or “associated with” – this code can only be used if both conditions are present
Kidney Infection …
with Calculus 592.0

57. Slanted Brackets [ ]
Indicate proper sequencing for the two codes listed.
The code number before the bracket is coded first.
The code number inside the brackets is coded second.
Codes in brackets in the alphabetic index can NEVER be sequenced as the principal diagnosis.

58. EXAMPLES
1.Arthritis, arthritic --- due to or associated with hypothyroidism
244.9 [713.0]

59. Example
1. ALZHEIMER’S DEMENTIA
2. DIABETIC GLAUCOMA

60. Multiple Coding Aftercare following kidney transplant
Examples:
Aftercare following kidney transplant
V58.44 (aftercare involving organ transplant),
V42.0 (Organ/tissue replacement by transplant , kidney)
Aftercare following arteriocoronary bypass
V58.73 (aftercare following surgery of the circulatory system),
V45.81(aortocoronary bypass status)
 use aftercare codes to provide better detail

61. Sequencing Multiple Codes
“Using Additional Codes”
When the instructions say “Use additional code….” the additional code is sequences second.
Example
UTI due to E.coli
599.0, [041.4]

62. Let’s Practice 1. Chronic Peptic Ulcer with Hemorrhage
2. Cerebral thrombosis with cerebral infarction
3. Diverticulitis of Duodenum “with” bleeding

63. “Exclusions” Let’s have a look: See 429 section
Under Cardiovascular Disease, Unspecified
Excludes: That due to hypertension

64. Diabetes with ketoacidosis 250.1x
Coding Diabetes
Metabolic manifestations of the disease – require only one code
Example:
Diabetes with ketoacidosis 250.1x

65. Combination Codes One Code for Cause One Code for Complication
Some Diabetic Conditions Require 2 Codes
“Diabetic” or “Due to”
One Code for Cause
One Code for Complication
Always sequence cause before complication

66. Combination Codes 250.8x 707.1x Diabetes with other manifestation
Example:
Diabetic foot ulcer
Diabetes with other manifestation
250.8x
Ulcer of lower limb, except decubitus
707.1x

67. Skin Ulcers
Clarification of clinical terms related to skin ulcers trans/r4som.pdf
Pressure Ulcer is a synonym for decubitus ulcer – due to prolonged pressure
Subcategory 707.0x has fifth digits to identify site
2009- New- additional code must be used to identify stage

68. Skin Ulcers of the Lower Limbs
Non pressure ulcers of lower leg
Fifth digits to identify site
Multiple coding, code first the underlying dx, such as arteriosclerosis, diabetes, venous hypertension
i.e. diabetic ulcer of left fifth toe ,

69. Stasis Ulcers The most common type of vascular ulcers
In Alphabetical index under “ulcer” , the index lists “venous” as a non-essential modifier under the subterm “stasis” that refers to code
Under section in the Tabular List you will be instructed to code any associated ulceration from category

70. Reporting Same Diagnosis Code More than Once
Each unique ICD-9-CM diagnosis code may be reported only once for an encounter. This applies to bilateral conditions or two different conditions classified to the same ICD-9-CM diagnosis code.

71. Pressure Ulcer Use add’l code to identify pressure ulcer stage
pressure ulcer, unspecified stage
pressure ulcer, stage I
pressure ulcer, stage II
pressure ulcer, stage III
pressure ulcer, stage IV
pressure ulcer, unstageable

72. Bilateral pressure ulcers with different stages
When a patient has bilateral pressure ulcers at the same site (e.g., both buttocks) and each pressure ulcer is documented as being at a different stage, assign one code for the site and the appropriate codes for the pressure ulcer stage.ICD-9-CM Official Guidelines for Coding and Reporting Effective October 1, 2010 Page 50 of 105

73. Myocardial Infarction
A code from category 410.XX must be assigned if the admission is strictly for rehabilitation within eight weeks of the acute MI.
The fifth digit 2 would be used in LTC to designate observation, treatment or evaluation of MI within eight weeks of onset, following the acute phase or in the healing state.

74. Myocardial Infarction
If the admission takes place after eight weeks assign code (412) Old Myocardial Infarction

75. Neoplasms with Metastasis
Two codes
One for primary (original site)
One for each secondary site
Please be as specific as possible when listing the diagnoses

76. Unknown Secondary Sites
Ex: Cancer of Lower lobe of lung with metastases (162.5, 199.0)
Primary site will be coded first
An code for Unknown secondary site will be assigned to the metastasis

77. Unknown Primary Site
The site of the metastasis will be sequenced first
The unknown primary site will be assigned an “unknown site” code and sequenced after secondary site(s)
Ex: abdominal metastasis from unknown origin (198.89, 199.1)
Unknown primary would not be used as principle diagnosis in SNF
The metastatic site is coded first

78. V-Codes for Neoplasms Primary site must still be identified
If removed, eradicated no longer under treatment
Use a personal history V-code, History,site, malignant neoplasm
Using this V-code will identify primary site responsible for metastasis that is no longer present

79. V-Codes for Neoplasms
Do not use codes from category V10 for secondary metastatic sites removed or not
ICD-9-CM does not provide code numbers for “history of secondary neoplasm site

80. V-Codes for Neoplasms A primary malignancy
Previously excised or eradicated from its site
And there is no further tx directed to that site
And there is no evidence of any existing primary malignancy,
A code from Category V10 is used to identify the former site of malignancy

81. V-Codes for Neoplasms
V12.41 Personal history of benign neoplasm of the brain.
Previously, no code to indicate that the patient had benign growth. These can cause serious symptoms in the patient.

82. V58.42 Neoplasm
Official coding guidelines for neoplasm apply when using the aftercare following surgery for neoplasm V58.42
Aftercare code V58.42 may be used with either the current neoplasm code or a code from category V10, whichever is applicable

83. Code It History of breast cancer with metastasis to the lung
Carcinoma of prostate with metastasis to spine
Basal cell carcinoma of chest
Hypothyroidism due to history of thyroid cancer (thyroid removed)
197.0, V10.3
185, 198.5
173.5
244.0, V10.87

84. Late Effects of CVA ( )
Rather than code the residual condition AND the late effect, combination codes that include the late effect should be used. Additionally, these can be used with a new CVA.
DO NOT code 436 for CVA codes from categories are used for the initial episode of care for an acute CVA at the hospital

85. Late Effects….. i.e. Left Hemiplegia due to CVA 438.20
The residual condition is coded first and the late effect is sequenced second
Multiple coding is required for most late effects
A late effect is not used as a principal dx, except for Category 438 Late Effect of CVA
i.e. Left Hemiplegia due to CVA

86. 438 Late Effects of CVA
Official coding guidelines state that Category 438 is used for admission and encounter for post acute care following treatment of the CVA in the acute hospital
Codes from categories 430 to 436 are reserved for the “initial” (first) episode of care for an acute CVA that was provided in the qualifying hospital stay and should not be used in SNF

87. 438 Combination / Multiple Coding
Category 438 includes combination codes that describe both the cause and the residual deficit
Right hemiplegia due to old CVA
More than one code my be used from category 438 to identify multiple residuals from a CVA
Dysphagia and left hemiplegia post CVA ,

88. 438
Use additional codes with category 438 if the combination code does not address all elements of diagnostic statement
Multiple coding is used to identify residuals of CVA that do not have a specific code
Seizure disorder following CVA ,

89. Aftercare for Healing Traumatic Fracture
For residents admitted to a SNF for care following treatment in the acute hospital for a traumatic fx use the aftercare codes from Subcategory V54.1
Coding Guidelines require an aftercare code be used after the initial encounter for care of a fx.

90. V54.1 Aftercare for healing traumatic fracture
For statistical purposes, a fracture should only be coded once. If the same fx is coded for all encounters, it makes collection of fracture statistics difficult
The V54.1 identifies the site of the fracture and that it is in the healing phases
Aftercare for Fractures; Pathologic and Traumatic
Remember that only the physician can indicate whether or not the fracture was pathological.

91. V54.1 Aftercare for healing traumatic fracture
The fifth digits identify the specific site of the healing fracture
The fifth digit 9 is used for other specified sites
If there are several bones that would be classified to the other specified site, only one code is used

92. V54.1 Aftercare for healing traumatic fracture
DO NOT code V58.43 Aftercare following surgery for injury and trauma (conditions classifiable to ) Exclusion note states “Excludes: aftercare for healing traumatic fracture”
Remember to always refer to the tabular list and carefully read the instructions and exclusions.

93. Aftercare for Healing Pathological Fracture
To assist in accurate coding assignment; as much as possible, be specific as to the nature of the fracture
Traumatic vs. Pathological

94. Joint Replacement
Joint replacement of knee for osteoarthritis (V58.78), V54.81, V43.65
Coding guidelines direct not to code the disease condition that was treated with the surgery

95. Aftercare Following Surgery
The acute dx for which the surgery was performed is not reported for aftercare encounters or admissions but can be listed as a secondary diagnosis in order to link the LTC services to the qualifying stay and as further explanation of the after care code.
Use other aftercare or symptom codes to provide better detail
Note the instructions with each code that identifies the range of conditions that are included in the aftercare code number
i.e. aftercare post cataract extraction with lens implant: V58.71, V45.61, V43.1

96. Heart Conditions due to HTN
When there is a casual relationship is states as “hypertensive” or “due to hypertension” heart conditions are assigned by Category 402 Hypertensive Heart Disease
Arteriosclerotic disease due to hypertension

97. Circulatory System Let’s Code Chronic hypertensive kidney disease
Deep vein thrombosis patient on Coumadin
403.9, 585.9
453.40, V58.61

98. Respiratory System Let’s Code Aspiration Pneumonia
Chronic bronchitis with emphysema
507.0
491.20

99. Guidelines: the coder should make every effort to record the codes in logical sequence that is descriptive of the patient’s condition

100. AUDITS

101. Medicare
Cert / Re-Cert

102. ADMISSION

103. DISCHARGE

104. CHANGE OF CONDITION

105. HIPAA
5010

106. ASC X12 Technical Reports Type 3, Version 005010
Final Rule to change from current version X12 Version 4010/4010A1 was published January 16, 2009
5010 Compliance Date
Sunday January 1, 2012

107. Electronic Data Interchange (EDI) The next level
Implementation of HIPAA Version 5010 Presents
Changes to software, systems and billing procedures.
Substantial changes in the content of the data that providers submit with their claims, as well as the data available to them in response to their electronic inquiries for eligibility or claims status.

108. ICD-10-CM Accommodates the use of ICD-10-CM
Distinguishes between principal diagnosis, admitting diagnosis, external cause of injury and patient reason for visit codes.
This is not currently supported by version 4010/4010A1

109. Important Dates Level I* compliance to begin by: December 31, 2010
Level II** Compliance by:                                 
December 31, 2011
All covered entities have to be fully compliant on:     
January 1, 2012

110. Level I Compliance
Level I compliance means "that a covered entity can demonstrably create and receive compliant transactions, resulting from the compliance of all design/build activities and internal testing."  We expect covered entities to be testing throughout calendar year 2011, and to schedule testing as early as possible, to ensure sufficient time for corrective actions and re-testing.

111. Level II Compliance
Level II compliance means "that a covered entity has completed end-to-end testing with each of its trading partners, and is able to operate in production mode with the new versions of the standards."

112. What you need to do……. Communicate with your vendors
Discuss software updates and system requirements for transitioning to Version 5010
Will updates be made with enough time to allow for testing while continuing to use Version 4010A1
Discuss any cost involved with this transition

113. Communicate with MACs and any other payers or billing services
Learn about their testing and implementation plans and requirements
Learn about any fee changes resulting from this transition (if any)

114. Identify possible changes to your current workflow, policies and procedures
Identify staff training needs
Identify key staff and define roles to ensure an efficient transition

115. Test with your vendors
Be aware of testing dates
Don’t wait until the last minute allow yourself enough time to correct errors and ensure compliance by 1/1/12

116. Questions for discussion

117. Thanks for attending