August 2007 Vol. 4, No. 8
Use these tips to write
better business memos
Good writing takes practice. Those who ignore this
fact must face the wrath of staff members frustrated with
the poor communication often found in radiology memos.
Whether you realize it or not, you write every day. And
through these seemingly mundane memos, e-mails, policy changes, and audit reports, you create important documents that relay the fates and fortunes of your radiology
facility and its staff members.
According to Paul Larson, president of Paul Larson
Communications in Evanston, IL:
➤ The best writing is simple
➤ The best words are short
➤ The best writers are organized
“We feel we have to overcomplicate our writing,”
said Larson, who spoke at the Radiology Business Management Association annual conference in St. Louis in
May. “It’s a curse of the 21st century. We seem to think
In this issue
if we don’t use big words then our memo, or letter, or
policy change won’t seem important enough.”
Learn the simple rules
In healthcare, as elsewhere, nearly every manager
tends to convolute the written word, Larson said.
Certainly,
no one expects
“It’s a curse of the 21st
you to compose
century. We seem to think
Shakespearian
if we don’t use big words,
sonnets about
the next radiology coding com-
then our memo, or letter,
or policy change won’t
seem important enough.”
pliance policy
—Paul Larson
change. (Why write “One must expect that the general
population of the genus Rosa tends to cultivate at least
one barb” when you could write “Every rose has its
thorn”?) But your staff members expect you to communicate changes effectively.
Larson said written communications should:
➤ Stay concise by eliminating fancy words; qualifying or
modifying words; and clichés, superlatives, and jargon
➤ Avoid the passive voice
➤ Use action verbs
p. 3 Ask the Insider
CMS’ Transmittal 66 attempts to clarify
payment for services provided overseas. Our
experts interpret the effect on teleradiology.
p. 5 CMS set to roll out new ABN form
Learn how changes to the advanced beneficiary notice (ABN) affect your
radiology facility.
Get organized
Organize your thoughts prior to putting your pen
to paper. It will improve your writing significantly. No
amount of polishing can mend a poorly crafted document. Follow Larson’s steps to organize what’s on your
p. 6 Assess compliance awareness with regular reviews
Determine whether staff members use your compliance program on a
regular basis with a simple analysis during regular appraisals.
p. 7 Coding corner
Melody Mulaik offers tips for picking the right cardiac CT codes.
mind and communicate it on paper:
1. Form your big idea. Always have a theme. If you
don’t know exactly what you want to say, it will be
impossible for you to write a strong document.
2. Know your audience. Figure out who you want
to read your document. Executives, ­technologists,
> continued on p. 2
Radiology Administrator‘s Compliance & Reimbursement Insider
Page Better memos
August 2007
< continued from p. 1
­radiologists, vendors, and the general public all approach
Create a thought bucket
data from different perspectives. Create your document
Visualize your point by sketching out your memo.
with your specific audience in mind. Explain the items
Put your “big idea” in the center of the page, and sur-
that the particular audience needs to know about most.
round it with the things that you need to say. Create
3. Make your point. Explain the three or four most im­­
buckets of common thoughts or messages. Put every-
portant points that you need to make. “Remember the
thing that’s similar into its proper bucket. Position these
rule of threes,” Larson said. “Readers and listeners gen-
buckets around the big idea, and include supporting data
erally aren’t able to absorb groups of more than three.
and other information.
So try to limit your message to two or three essential
Now, think about the beginning, middle, and end of
points whenever possible.” Also, tell your audience
your document. Introduce your main idea, and then sup-
what you want them to do. Big business experts call
port it with examples, documentation, and information.
this the ‘call to action’ or ‘action items.’
Explain why your main idea is important. Conclude your
Editorial Advisory Board
Radiology Administrator’s Compliance &
Reimbursement Insider
document with what you want your audience to do with
the information you just provided.
Group Publisher: Lauren McLeod
Executive Editor: Melissa Osborn
Managing Editor: Melissa Varnavas
Larry Balmer
Radiology Incorporated
Mishawaka, IN
Stacie L. Buck, RHIA, CCS-P,
LHRM, RCC
Southeast Radiology Management
Stuart, FL
Melody W. Mulaik, MSHS, CPC,
CPC-H, RCC
Coding Strategies, Inc.
Powder Springs, GA
Claudia A. Murray
Provider Practice Analysis, LLC
Baldwin, MD
Mark B. Canada, MHA, CPC
Medical Practice Management
Richmond, VA
Paula Richburg
QuadraMed
Columbia, MO
Alice Gosfield, Esq.
Alice G. Gosfield & Assocs., PC
Philadelphia, PA
William A. Sarraille, Esq.
Sidley Austin Brown & Wood
Washington, DC
Thomas W. Greeson, Esq.
Reed Smith, LLP
Falls Church, VA
Michael F. Schaff, Esq.
Wilentz Goldman & Spitzer
Woodbridge, NJ
Stacy Gregory, RCC, CPC
Gregory Medical Consulting Services
Tacoma, WA
Jay Silverman, Esq.
Ruskin Moscou Faltischek, PC
Uniondale, NY
Mark B. Langdon
Arent Fox, PLLC
Washington, DC
Edward Townley
Moncrief Cancer Center
Fort Worth, TX
Jackie Miller, RHIS, CPC
Coding Strategies, Inc.
Powder Springs, GA
Tobin N. Watt, Esq.
Smith Helms Murliss
& Moore, LLP
Atlanta, GA
Diane S. Millman, Esq.
Powers Pyles Sutter & Verville
Washington, DC
Radiology Administrator’s Compliance & Reimbursement Insider (ISSN: 1527-2338) is published monthly by HCPro, Inc.,
200 Hoods Lane, Marblehead, MA 01945. Subscription rate: $249/year; back issues are available at $25 each. • Postmaster:
Send address changes to Radiology Administrator’s Compliance & Reimbursement Insider, P.O. Box 1168, Marblehead,
MA 01945 • Copyright 2007 HCPro, Inc. All rights reserved. Printed in the USA. Except where specifically encouraged, no part of
this publication may be reproduced, in any form or by any means, without prior written consent of HCPro, Inc., or the Copyright
Clearance Center at 978/750-8400. Please notify us immediately if you have received an unauthorized copy. • For editorial comments or questions, call 781/639-1872 or fax 781/639-2982. For renewal or subscription information, call customer service at
800/650-6787, fax 800/639-8511, or e-mail [email protected]. Visit our Web site at www.hcpro.com. • Occasionally,
we make our subscriber list available to selected companies/vendors. If you do not wish to be included on this mailing list,
please write to the Marketing Department at the address above. • Opinions expressed are not necessarily those of Radiology
Administrator’s Compliance & Reimbursement Insider. Mention of products and services does not constitute endorsement. Advice
given is general, and readers should consult professional counsel for specific legal, ethical, or clinical questions. Radiology
Administrator’s Compliance & Reimbursement Insider is not affiliated in any way with The Joint Commission, which owns
the JCAHO and Joint Commission trademarks.
Be concise
Frequently, managers use too many words to describe
a simple concept, Larson said. Take the following example
of a recent radiology department memo:
Going forward all current and future employees should
operate within the hospital’s new basic radiology coding
system regardless of departmental roles and relative job
descriptions as this new computerized programming will
allow the administration to track, audit, and report appropriate use and reimbursement of radiology procedures.
Now consider the following, more readable version of
the same memo:
As of July 1, please use the new coding software. This new
program provides better patient service and ensures that we
get paid appropriately for the work we do.
The latter version efficiently informs the reader of the
important points, such as who (everyone), what (implementation of a new computer program), when (July 1),
and why (to receive proper reimbursement). n
Insider source
Paul Larson, president, Paul Larson Communications, 1017 Greenleaf
Street, Evanston, IL 60202, 647/475-1283; [email protected].
For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978/750-8400.
© 2007 HCPro, Inc.
August 2007
Radiology Administrator‘s Compliance & Reimbursement Insider
Page Ask the Insider
CMS transmittal clarifies some teleradiology confusion
Q
Here’s the scenario: A hospital contracts with a
nical component of the radiology service within the
radiology group to interpret radiology images.
United States, the payment limitation described in the
The hospital bills the technical portion, and the radiol-
­transmittal does not apply, says Aaron, who clarified the
ogy group bills the professional services. The radiol-
information with CMS representative Fred Grabau.
ogy group subcontracts with a service that employs a
So an American facility may bill for the technical
radiologist overseas to do a preliminary read for radiol-
component even if a radiologist interpreted the image in
ogy exams that the hospital performs after hours. The
another country as long as the hospital billed Medicare
radiology group then overreads the film and bills the
separately for the technical component. professional fee.
Medicare always had very limited coverage for services outside of the United States, says Regulatory Specialist
Does this arrangement between the radiologist and
overseas provider make both the professional fee
Peggy S. Blue, MPH, CPC, of HCPro, Inc.
“In fact, if it was not for the advent of telemedicine,
handled by the radiology group and technical fee billed
this transmittal would probably not have even been nec-
by the hospital not payable by Medicare? Or do the
essary,” Blue says. “I know it can be very attractive for
Medicare rules regarding reimbursement for overseas
patients to seek medical services in other countries due to
payments apply only to the services that the radiolo-
a significant cost savings in their out-of-pocket expenses,
gist provides, because that portion involves overseas
but I don’t see practitioners going that way.”
­services?
Change Request 5427, Medicare Benefit Policy
A CMS
Manual, Transmittal 66, amends Chapter 16, Section
60, of the manual to add the following paragraph:
However, for a variety of reasons, both radiology
practices and hospital administrations increasingly look
to overseas radiologists to perform the professional component of exams.
Under these arrangements, the overseas physician
Payment may not be made for a medical service (or a por-
provides a preliminary read, and the United States–based
tion of it) that was subcontracted to another provider or
radiologist provides an overread.
supplier located outside the United States. For example, if
a radiologist who practices in India analyzes imaging tests
that were performed on a beneficiary in the United States,
The United States–based physician then bills Medi­
care for the interpretation of the exam.
CMS has received several inquiries regarding wheth-
Medicare would not pay the radiologist or the U.S. facility
er radiologists providing professional interpretations in
that performed the imaging test for any of the services that
the United States can bill Medicare after receiving pre-
were performed by the radiologist in India.
liminary reads performed abroad. However, CMS “has not yet decided whether it will
The payment limitation applies only to the portion
issue any guidance or clarification,” Aaron says. n
of the service furnished outside of the United States, says
Hugh E. Aaron, MHA, JD, CPC, CPC-H, senior vice
president of compliance and regulatory affairs/regulatory
counsel for HCPro, Inc., in Marblehead, MA. But if the radiology technologist performs the tech-
Insider sources
Hugh E. Aaron, MHA, JD, CPC, CPC-H, senior vice president of compliance and regulatory affairs/regulatory counsel, HCPro, Inc., 200 Hoods Lane,
Marblehead MA, 978/639-1872; [email protected].
Peggy S. Blue, MPH, CPC, regulatory specialist, HCPro, Inc., 200 Hoods
Lane, Marblehead MA, 717/284-3479; [email protected].
For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978/750-8400.
© 2007 HCPro, Inc.
Radiology Administrator‘s Compliance & Reimbursement Insider
Page August 2007
Sample ABN
Source: CMS.
Editor’s note: This is one of three sample forms that Medicare was considering as of presstime. For more information,
visit www.cms.hhs.gov/PaperworkReductionActof1995.
For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978/750-8400.
© 2007 HCPro, Inc.
Radiology Administrator‘s Compliance & Reimbursement Insider
August 2007
Page CMS set to roll out new ABN form
CMS announced several changes to the advanced beneficiary notice (ABN) in the February 23 Federal Register.
Healthcare providers use ABNs to inform patients
of their potential financial liability for services that
Medicare won’t cover.
According to the draft, CMS’ goal is to “design a form
that is clear and understandable for beneficiaries, while
permitting appropriate customization by the various types
of providers, practitioners, and suppliers that use ABNs.”
Essentially, CMS wants to combine the two tradition-
CMS published a final draft of the proposed
al forms into one usable and easy-to-follow document,
changes on May 25 with the anticipation that these
said Bill Malm, president of Health Revenue Integrity
changes would take effect following the final 60-day
Services in Cleveland, who spoke during the HCPro, Inc.,
comment period and the subsequent approval of the
audioconference “Radiology ABNs: Ensure compliance
final rule.
and appropriate reimbursement” on June 13.
Changes include the:
➤ Combination of the general and lab-test versions
of the ABN (CMS-R-131G and CMS-R-131-L,
respectively) into one universal form
➤ Addition of the 800/MEDICARE phone number
➤ Addition of information regarding the patient’s
right to demand that the provider bill Medicare
“This form could be used by different specialties,
and it would be more user-friendly, with language the
patient can understand,” Malm said. n
Editor’s note: To view a draft of the new ABN, see the sample
ABN on p. 4. To learn more, visit the CMS Web site and click on
the Paperwork Reduction Act of 1995. Then click on PRA Listing
and search for CMS-R-131.
➤ Additional option to allow beneficiaries to pay out
of pocket for the procedure
➤ Additional description of the significance of the
beneficiary’s signature
Insider source
William L. Malm, ND, RN, president, Health Revenue Integrity Services,
Inc., 815 Brick Mill Run, Westlake, OH 44145, 440/331-3312; wmalm.hris@
adelphia.net.
Tackle these topics prior to providing radiology ABNs
Q
A patient came to our facility for preoperative
Ensure compliance and appropriate reimbursement”
chest x-rays three days before surgery for cardiac
on June 13.
bypass. Should we have administered an advanced
beneficiary notice (ABN)?
determine which payer provides coverage for
A First
the patient—Medicare, Medicaid, private, or com-
Most carriers, Balmer said, initially deny the preoperative chest x-ray claim. However, once they receive
a claim with supporting documentation, carriers usually
will reimburse for the exam.
If dealing with a Medicare patient, check the local
mercial. Most insurers consider preoperative x-rays to
coverage determination for the procedure and deter-
be screening exams unless the scan helped surgeons
mine whether the exam meets medical necessity, said
gather information necessary for the operation, said
Bill Malm, president of Health Revenue Integrity
Larry Balmer, chief compliance officer at Radiology
Services in Cleveland, who also spoke during the
Incorporated in Mishawaka, IN. Balmer spoke during
­audioconference.
the HCPro, Inc., audioconference “Radiology ABNs:
> continued on p. 6
For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978/750-8400.
© 2007 HCPro, Inc.
Page Radiology ABNs
Radiology Administrator‘s Compliance & Reimbursement Insider
August 2007
< continued from p. 5
Only the Medicare program uses an ABN form. So,
if Medicaid is the patient’s primary insurer, don’t use an
ABN, said Malm. Consult the state Medicaid carrier to
determine coverage requirements, he added.
However, do not give an ABN to a non-Medicare
prior to the performance of a preoperative x-ray.
Some states allow you to charge a patient for the service if he or she was presented with a choice.
If you suspect that Medicaid won’t cover the preoperative x-ray, document that you informed the patient.
pa­­tient unless specifically required under a contractual
That way, if Medicaid denies the bill, you can bill the
arrangement with the non-Medicare payer, Malm said.
patient directly, Balmer said.
Although ABNs are specific to Medicare, some state
When dealing with situations involving questionable
Medicaid agencies, such as Indiana, require providers to
services and Medicaid, obtain an ABN as a blanket protec-
inform Medicaid patients about potential noncoverage of a
tion, said Malm. n
service. Further, many state groups encourage healthcare
providers to make note in the medical record that the
Insider sources
facility told the patient about his or her fiscal liability.
Larry W. Balmer, CCP, compliance officer, Radiology Incorporated, 620
Edison Road, Suite 110, Mishawaka, IN 46545, 901/516-0818; lbalmer@
rad-inc.com.
Many payers require preauthorization, which precludes the necessity of an ABN. In that case, referring
physicians must obtain permission or “preapproval”
William L. Malm, ND, RN, president, Health Revenue Integrity Services,
Inc., 815 Brick Mill Run, Westlake, OH 44145, 440/331-3312; wmalm.hris@
adelphia.net.
Assess compliance awareness with regular staff reviews
As you develop and implement your compliance
You can get some of your most valuable compliance
plan, look for every opportunity to generate employee
feedback when you sit down face-to-face with your radi-
feedback and reinforce your commitment to compli-
ology technologists and other staff members and discuss
ance. Take the pulse of your organization through con-
their concerns. If you go into each review with a prede-
versations with staff members. Periodic performance
termined set of compliance questions, you’re more likely
reviews (PPR)—those regularly scheduled staff apprais-
to get consistent feedback.
als—provide excellent opportunities to find out what’s
going on.
The Office of Inspector General says radiology manag-
Draft a list of questions and distribute it in a memo
to all staff members who conduct performance reviews.
A memo will instruct reviewers about how to incorpo-
ers should discipline employees who violate compliance
rate the compliance questions into their regular set of
policies and procedures. You need to find out whether
review inquiries.
your employees follow your policies and procedures and
whether those policies and procedures are working first.
For example, do employees have trouble under-
Sample questions
1. Do you keep a copy of our code of conduct
standing your policies and procedures? Do they mis-
and our compliance policies handy? Encourage em­­
takenly believe that those policies and procedures are
ployees to have compliance materials readily available at
unimportant?
their work stations or another easily accessible ­location.
Regular performance reviews are the most direct
route to obtain answers about your compliance program.
Consider creative ways to keep these valuable tools
within easy reach.
For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978/750-8400.
© 2007 HCPro, Inc.
August 2007
Radiology Administrator‘s Compliance & Reimbursement Insider
2. Have you ever consulted our code of conduct or compliance policies? Find out whether your
staff members actually use your compliance resources
Page too difficult to understand and inappropriately complicate the healthcare routine.
When an employee refers to this difficulty, press
in their day-to-day work. The best compliance plan in
him or her for examples of specific procedures and
the world isn’t worth anything if your employees don’t
request a detailed account of how staff members
use it.
attempt to work within the procedure and how he or
If they say they do use these compliance resources,
she deals with the problem. Such input will help you
find out how. Probe further to determine whether they
rewrite your policy and review complex procedures,
use the resources correctly, whether the resources are
making compliance easier throughout the radiology
helpful, or whether employees run into any difficulties
department or facility. n
when using the resources.
3. Are the compliance policies easy to under-
Editor’s note: The above excerpt is from the Radiology
stand? Do they help you do your job? Staff members
Manager’s Handbook: Tools and Best Practices for Business
sometimes believe compliance concerns are simply
Success. For information, visit www.hcmarketplace.com.
Coding corner
Determine the difference between CT and CTA
by Melody W. Mulaik, MSHS, CPC, CPC-H, RCC
scanner and to identify the anatomic region to be evaluated during the ‘with contrast’ portion of the study.”
CTA has become a hot topic for radiology during the
past few years. CTA reimbursement, equipment requirements, and joint venture relationships between cardiolo-
New CT scanners have more advanced technology that
has nearly eliminated the need for calibration images.
Clinical Examples in Radiology (volume one, issue three,
gists and radiologists for the interpretation of CTA have
summer 2005) also states, “When a localizer image is not
generated much discussion in the radiology community.
obtained, it is still appropriate to report the CTA pro-
Coders find it difficult to assign a CTA procedure
cedure codes. In such circumstances, a reduced service
code that accurately represents the service that the radi-
modifier is not required.” This clarification is important,
ologist performed according to the standard definition of
because many organizations have expressed concern that
CTA procedures.
the “without contrast” portion actually refers to diagnostic
By definition, all CTA procedure codes, except
images, contrary to the Coding Clinic definition. The bot-
the category III cardiac codes, include the following
tom line—if the exam occurs without initial noncontrast
­verbiage: “without contrast material(s), followed by
images, this does not change the code assignment.
contrast material(s) and further sections, including
image postprocessing.”
Determining postprocessing
Radiology coders and administrators face another
Coding by definition
According to the AHA Coding Clinic for HCPCS (vol-
challenge, as well. Despite the fact that the radiologist,
or radiology technologist, documents the procedure
ume five, number one, first quarter 2005), “the por-
in the report, the administrator or coder must ensure
tion of the CTA exam referred to as ‘without contrast
that the required “postprocessing” was performed and
material(s)’ represents the images taken to calibrate the
> continued on p. 8
For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978/750-8400.
© 2007 HCPro, Inc.
Radiology Administrator‘s Compliance & Reimbursement Insider
Page Coding corner
August 2007
< continued from p. 7
Understanding common confusions
­properly documented in that report.
Imaging postprocessing refers to two-dimensional (2-
The most frequent coding mistake arises from CT
D) and/or three-dimensional (3-D) reconstruction(s) of
scans to evaluate for pulmonary embolism. Coding these
the CT data set acquired during the imaging process. The
as CTs or CTAs depends on the actual procedures that the
2-D reformatted images can be created in multiple planes
radiologist performed and documented.
(e.g., sagittal), then interpreted, annotated, and archived
If the radiologist performed the CT specifically for
as hard-copy and/or electronic files. The radiologist typi-
the purpose of viewing the pulmonary vessels and he
cally evaluates 3-D or volume-rendered reconstructions
or she performed image postprocessing (sagittal, coronal,
in multiple projections. The 3-D reformatting requires
2-D, 3-D, or multiplanar reconstructions), then it meets
extensive effort from the radiologist, who typically per-
the definition of a chest CTA (71275).
forms the processing on a separate workstation. The CPT
However, many CT scans that evaluate for pulmo-
Manual lists separate procedure codes for 3-D render-
nary embolism are not CTAs. They are simply CTs. The
ing (76376 and 76377); however, do not assign these in
radiologist must perform and document the image post-
addition to the CTA codes, because the CTA procedure
processing in order to bill for a CTA.
codes already include the work that these codes define.
CT imaging of an anatomic region is not always
Discuss the “CT Pulmonary Embolism” protocol
with radiologists and technologists to ascertain what
considered CT angiography, even if the primary concern
process they follow. Do not assign the procedure code
involves the blood vessels. The key distinction between
based on protocols, but by understanding the nuances
CT and CTA is that CTA includes image postprocessing,
of the actual procedure. Such awareness allows you to
such as maximum-intensity profile or 3-D renderings. A
provide feedback to the radiologist, if documentation is
CTA study includes:
inadequate, to ensure correct coding for the performed
➤Acquisition of localizing images (if necessary)
procedure. n
➤Acquisition of contrast-enhanced images
➤Reformatting of those images (postprocessing)
Editor’s note: Mulaik is copresident of Coding Strategies,
➤Interpretation of both the axial source images and
CodingStrategies.com.
the reconstructed images
RACRI Subscriber Services Coupon
❏ Start my subscription to RACRI immediately.
Options:
No. of issues Cost
Total
❏ Print & Electronic 2 yr 24 issues of each $448 (RACRIPE) $48.00
Order online at
www.hcmarketplace.com.
Sales tax
Be sure to enter source code
N0001 at checkout!
Grand total
Your source code: N0001
Name
Shipping
❏ Print & Electronic 1 yr 12 issues of each $249 (RACRIPE) $24.00
(see tax information below)*
For discount bulk rates, call toll-free at 888/206-6554.
*Tax Information
Inc., in Powder Springs, GA. Contact her at Melody.Mulaik@
Please include applicable sales tax. Electronic subscriptions are
exempt. States that tax products and shipping and handling: CA,
CO, CT, FL, GA, IL, IN, KY, LA, MA, MD, ME, MI, MN, MO, NC, NJ, NM,
NY, OH, OK, PA, RI, SC, TN, TX, VA, VT, WA, WI, WV. State that taxes
products only: AZ. Please include $27.00 for shipping to AK, HI, or PR.
Title
Organization
Address
City State Phone
Fax
ZIP
E-mail address
(Required for electronic subscriptions)
❏ Payment enclosed.
❏ Please bill me.
❏ Please bill my organization using PO #
❏ Charge my: ❏ AmEx
❏ MasterCard
❏ VISA
Signature
(Required for authorization)
Card # Expires
(Your credit card bill will reflect a charge to HCPro, the publisher of RACRI.)
Mail to: HCPro, P.O. Box 1168, Marblehead, MA 01945 Tel: 800/650-6787 Fax: 800/639-8511 E-mail: [email protected] Web: www.hcmarketplace.com
For permission to reproduce part or all of this newsletter for external distribution or use in educational packets, contact the Copyright Clearance Center at www.copyright.com or 978/750-8400.
© 2007 HCPro, Inc.