Chiropractic Services and

CERT Documentation

Presented by: Provider Outreach and Education (POE) May 2015

Webinar Protocol

• Cannot register with WebEx using mobile device

– Must use desktop or laptop

• When entering & throughout webinar – muted lines

• Presentation emailed 3 days before webinar – check spam from registrations@noridian.com

– Will resend with CEU

– Adobe PDF format (with printing instructions)

• Webinar conclusion

– Asking questions? Use “raise/lower hand” figure

– MUTE phones – never place on HOLD

Updated

May 2015 2

Using WebEx During Webinar

Participants •Option to ask a question at end of webinar •Use the raise/lower hand feature •Once question answered, lower hand

Chat NEW INSTRUCTION •Do NOT add additional attendees to webinar •Additional attendees must be added to the initial registration to qualify for CEU

Q/A CLOSED •Until last 30 minutes of webinar •Type question in box and send to all panelists, not host •Keep questions to topic/previous slides

Updated

May 2015 3

Continuing Education Unit (CEU)

• When registering, add all additional attendees – First and last names

– Not accepting added attending names in CHAT

• Attend entire workshop

• Take short polling survey

• Pops up after closing out of webinar

• CEU emailed 3 days after presentation – Earn 1.5 CEUs today

– No password or index number needed

– All attendees use CEU certificate • Certificate of Attendance no longer available

Updated

May 2015 4

Webinar Questions and Answers

• During the last 30 minutes of presentation – Q/A section opened

– Questions pertinent to webinar slides

– Address Q/A to “all panelists”; not to host directly

• Pertinent Q/As not addressed in material – Posted to webpage

• Q/As posted to Noridian Education website – 30 business days from webinar date

• Need questions urgently answered? – Call your Provider Contact Center

Updated

May 2015 5

May 2015 6

DISCLAIMER

This information release is the property of Noridian Healthcare Solutions, LLC. It may be freely distributed in its entirety but may not be modified, sold for profit or used in commercial documents.

The information is provided “as is” without any expressed or implied warranty. While all information in this document is believed to be correct at the time of writing, this document is for educational purposes only and does not purport to provide legal advice.

All models, methodologies and guidelines are undergoing continuous improvement and modification by Noridian and CMS. The most current edition of the information contained in this release can be found on the Noridian website at http://www.noridianmedicare.com and the CMS website at http://www.cms.gov

The identification of an organization or product in this information does not imply any form of endorsement.

CPT codes, descriptors, and other data only are copyright 2014 American Medical Association. All rights reserved. Applicable FARS/DFARS apply.

Objective

• To increase knowledge of Chiropractic

billing and coverage guidelines

• To highlight Medical Review (MR) and

CERT audit results

• To decrease claim submission errors

May 2015 7

Agenda

• LCD

• Medical Necessity

• Documentation Guidelines

• Advance Beneficiary Notice of

Noncoverage (ABN)

• CERT Review Program

• Reminders & Resources

May 2015 8

ACRONYM DESCRIPTION

ABN Advance Beneficiary Notice of Non Coverage

CERT Comprehensive Error Rate Testing

CR Change Request

DME Durable Medical Equipment

IOM Internet Only Manual

MLN Medicare Learning Network

MPFS Medicare Physician Fee Schedule

MSP Medicare Secondary Payer

SOAP Subjective, Objective, Assessment, Plan

May 2015 9

Chiropractic LCD

Chiropractic Policy- LCD

• Local Coverage Determination (LCD) policy

– Very important that all Chiropractors read!

• JE #L33518

– https://med.noridianmedicare.com/web/jeb/policies/lcd/active

• JF #L24288

– https://www.noridianmedicare.com/partb/coverage/active.html

May 2015 11

Chiropractic Policy- LCD

• When appropriate, Noridian medical staff

completes pre-payment review

– Providers identified with data analysis/audits

May 2015 12

Chiropractic Policy – JE B

May 2015 13

Chiropractic Policy – JF B

May 2015 14

Medical Necessity

Medicare Coverage

• Medical Necessity

– Title XVIII of the Social Security Act, Section

1862 (a)(1)(A) clarifies no payment may be

made for any expenses incurred for items or

services not reasonable and necessary for the

diagnosis or treatment of illness or injury or to

improve the functioning of a malformed body

member

May 2015 16

Medical Necessity

• Demonstrate significant health problem of neuro-musculoskeletal condition

– Statement of ‘pain’ is insufficient

– Pain location must be described • Whether particular vertebra capable of producing pain

– Direct therapeutic relationship to patient’s condition

• Reasonable expectation of recovery

– Arrest/retard deterioration in condition

– Within reasonable and predictable period of time

May 2015 17

Medical Necessity

• Treatment of the spine, limited specifically by manual manipulation (use of hands), to correct a subluxation

– Demonstrated by x-ray or physical exam

– Hand held devices allowed • Controlled manually

• Medicare does not allow additional payment for device

• No other diagnostic/therapeutic service covered when furnished/ordered by chiropractic physician

– Thermography, pro-adjuster electric devices, neurocalcometer not covered

May 2015 18

Utilization Guidelines

• Chiropractic manipulation service only

reimbursed once per day

• The frequency and duration of chiropractic

treatment

– must be medically necessary

– based on the individual patient’s condition and

response to treatment

• Medical necessity determines visits/no set

number of visits

May 2015 19

Excluded Chiropractic Services

• Beneficiary responsibility

• May bill patient without billing Medicare – Acupuncture

– Counseling/education

– Dietary advice/nutritional supplements

– Lab or other diagnostic tests

– Physical therapies (exercise, ultrasound, traction)

– Office visits

– Supplies (pillows or vitamins)

– Supportive (bracing, orthopedic)

– X-rays

May 2015 20

Documentation Guidelines

Documentation-Medical Necessity

• Requirements apply whether subluxation demonstrated by x-ray or physical exam

– Applies to initial visit and subsequent visits

– Both participating/nonparticipating providers

• Document either a or b:

a) List exact bones involved • C2, L5, etc.

b) Area/region, if it implies only certain bones • Lumbo-sacral

• Sacro-iliac

May 2015 22

Documentation-Subluxation

• X-ray should be taken no more than

– 12 months prior to initiation of treatment or

– 3 months following initiation of treatment

• Previous CT scan and/or MRI acceptable

• Also maintained by referring physician

• Enter x-ray date - Item 19 (narrative)

– E.g. 2/20/15

– “x-ray date” verbiage optional

May 2015 23

• Physical Examination: – If subluxation is demonstrated by physical exam,

the medical record must include 2 of the following

4 criteria (either #2 or #3 is required): 1 Pain/tenderness evaluated in terms of location, quality, and

intensity

2 Asymmetry/misalignment identified on a sectional or

segmental level

3 Range of motion abnormality (change in active, passive,

and accessory joint movements resulting in an increase or

decrease of sectional or segmental mobility)

4 Tissue, tone changes in the characteristics of contiguous or

associated soft tissues, including skin, fascia, muscle and

ligament

Documentation-Subluxation2

19 May 2015

Documentation – Initial Visit

• Patient history – Chief complaint

– Patient symptoms why seeking chiropractic treatment

– Has patient had prior chiropractic treatments

• Symptoms are direct relationship to subluxation level

• Present illness may include: – Mechanism of trauma

– Quality, character and intensity of problem/symptoms

– Frequency and duration of symptoms

– Aggravating or relieving factors of symptoms

– Prior interventions or treatments, including medications

– Secondary complaints

May 2015 25

Documentation – Initial Visit 2

• Family history (if pertinent)

• Past health history may include: – General health statement

– Prior illness(es)

– Surgical history

– Prior injuries or traumas

– Prior chiropractic care

• Physical exam – Clearly document treatment given on day of visit

– What was adjusted

May 2015 26

Documentation – Initial Visit 3

• Diagnosis – Primary diagnosis must be subluxation

• Head, Cervical, Thoracic, Lumbar, Sacral or Pelvic

– Secondary diagnosis comes from Chiropractic Policy

• Category I, II or III

– List primary/secondary for each region treated/billed

• Treatment plan – Initial treatment date

– Therapeutic modalities – education and exercise training

– Level of care recommended – duration/frequency of visits

– Specific measurable goals achieved with treatment • Objective measures to evaluate treatment effectiveness

May 2015 27

May 2015 28

Documentation – Subsequent Visits

• History – Review of chief complaint and systems

– Changes since last visit

• Physical exam – Exam of spine area involved in diagnosis(es)

– Patient condition assessment of change from last visit

– Treatment effectiveness evaluation

• Document treatment details on day of visit – What specifically was adjusted

– Clearly document treatment necessity

– Progress towards goals

May 2015 29

Documentation – Subsequent Visits 2

• Even if diagnosis is the same as last visit – document each time

– Word “same” is not acceptable

– If diagnosis changes from prior visit • Explain if it relates to past history and how

– If new diagnosis, redo P.A.R.T./S.O.A.P. notes

• Is new diagnosis due to a new injury?

– Add Initial Treatment Date (ITD) to Item 14

• Discharge when no further progress (ABN)

May 2015 30

May 2015 31

Active vs. Maintenance

Treatment

Active/Corrective Treatment

• Goal driven

• Treatment plan

• Individualized

• Usually short term

• Measurable progress towards goals

• When providing active/corrective treatment, must append AT modifier

– CPT codes (98940 – 98942)

May 2015 33

Maintenance Therapy

• Maintenance services: – Preventive

– Promote health

– Prolong or enhance quality of life

– Maintain/prevent deterioration

• When further clinical improvement cannot be expected from continuous ongoing care – Treatment is considered maintenance therapy

when chiropractic treatment is supportive, not corrective

– Not covered by Medicare, but must bill

May 2015 34

Maintenance Therapy 2

• Mandatory Claim Submission – Requires providers to bill Medicare, even if service

might deny (98940, 98941 or 98942)

• Do not append AT modifier

• Bill with additional diagnosis (optional) – V57.9 (unspecified rehabilitation procedure)

• Obtain ABN – see next section – Append GA modifier

• Never bill AT and GA modifiers together on same line – Possibly has patient under active treatment, but feels

Medicare may deem as not medically necessary

May 2015 35

Claim Requirements

Mandatory Claims Submission

• Providers must submit Medicare claims for

covered or potentially covered services

– Providers may not charge for this paperwork

• Bill direct only for non-covered/statutorily-

excluded services

• If beneficiary requests, providers must bill

Medicare for non-covered services

– MSP claims may require prior to processing

May 2015 37

Claim Requirement Highlights

• Item 14 – Date of Initial Treatment/ exacerbation of existing condition

– 12/01/13 – Patient seen for neck and back pain

– 03/01/14 – Recurrence visit after time lapse

– ITD for this course of treatment is 03/01/14

• Item 17/17B – Referring/ordering physician’s name/NPI (if necessary)

– Physician assuming order responsibility

• Item 19 – X-ray as documentation of subluxation

– 6-digit or 8-digit x-ray date with optional verbiage

– Descriptions – e.g. specific subluxation level

May 2015 38

Claim Requirement Highlights 2

• Item 21 – Diagnosis

– No decimals or descriptions

– Must be to highest level of specificity

– Up to 12 diagnoses on paper claim

• Each region billed requires both diagnoses

– Subluxation(s)/regions listed as primary diagnosis

– Resulting disorders (conditions) listed as secondary

diagnosis(es)

• Check the Chiropractic policy

May 2015 39

Manipulation Codes

98940 CMT; spinal, one to two regions

98941 CMT; spinal, three to four regions

98942 CMT; spinal, five regions

98943 – noncovered Extraspinal, one or more regions

Primary Diagnosis Codes

739.0 Head

739.1 Cervical

739.2 Thoracic

739.3 Lumbar

739.4 Sacral

739.5 Pelvic

Select secondary diagnosis from Category I, II or III 40

Secondary Diagnosis Code

• Reflect mandatory secondary diagnosis

– Neuromusculoskeletal condition for treatment

Category

Treatment

Example:

Chief Complaint

Secondary

Diagnosis

I Short Term Tension Headache 307.81

II Moderate Back Strain 847.0

III Longer Post Laminectomy 722.81

41 May 2015

Payment Inquiries

Questions Answers

Can a PAR Chiropractor

use a sliding payment

scale?

•Cannot collect more than PAR allowed for

98940-98942

•Medicare fee schedule can be lower than

private insurer; but never higher

Can a Chiropractor use

a 30% discount, if

patient pays cash at

time of service?

• Yes, if 98940-98942 involved and practice

has same discount to all other insured

•https://www.noridianmedicare.com/shared/

partb/bulletins/2012/281_oct/Medicare_Que

stions_Unrelated_to_Specific_Claims_.htm

May 2015 42

Advance Beneficiary Notice of

Noncoverage (ABN)

What is an ABN?

• Written notice that health care provider

gives to Medicare beneficiary prior to

service/procedure rendered

– Provider believes Medicare will not pay for

some or all Medicare Fee for Services

– If claim denied medical necessity, ABN

indicates beneficiary is financially responsible

• Used for Maintenance Therapy visits

May 2015 44

Revised CMS ABN (CMS-R-131)

• Dated March 2011

• CMS form available

• http://www.cms.gov/Me

dicare/Medicare-

General-Information/

BNI/ABN.html

• 100-02, Chapter 15, Section 40

May 2015 45

ABN 2

• ABN must

– State specific procedure and estimated cost

– Specific reason why provider believes Medicare likely to deny payment

– Signed/dated by beneficiary before procedure/service performed

• Cannot change ABN form except to

– Copy on provider letterhead

– Personalize sections A, B, C, D, E, F & H

May 2015 46

ABN Header

• Blank A – Notifier’s name, address and telephone #

• Blank B – Beneficiary’s name as listed on Medicare card

• Blank C – Internal identification number (patient account)

• Cannot use Medicare or social security number

May 2015 47

ABN Body

•Write out specific service

•Enter frequency and/or duration

•Enter detailed reason Medicare may not pay __________________

•Enter reasonable charge (within $100)

Service

Service

Service

May 2015 48

ABN Options

May 2015 49

•Provider not permitted to make this selection

ABN Option #2 Clarification

• Only Maintenance Therapy (98940 – 98942)

– Not for covered AT treatments

– Should be rare; not with every patient

– Be careful; if patient decides later they want

Medicare billed and timely filing not met, provider

must refund patient and is out Medicare monies

– Beneficiary or his/her representative must choose

one of the three options listed

• Patients MUST make decision (not provider)

50 May 2015

ABN Information/Signature

51 May 2015

ABN Billing Modifiers

GA Expect Medicare will deny item/service as not reasonable and necessary

•Signed ABN is on file – beneficiary liability

GX Used to report when voluntary ABN issued for a non-covered or

statutorily excluded service

•May be used with GY – beneficiary liability

GY Item/service is non-covered (excluded) from Medicare program

•No ABN needed

•Auto-denied by Noridian – beneficiary liability

GZ Expect Medicare will deny item /service as not reasonable /necessary

•Signed ABN not given prior for maintenance therapy

•No change to provider financial responsibility

•CO = Contractual Obligation

May 2015 52

Extended Course of Treatment

• Single ABN (up to one year) acceptable:

– ABN identifies all items/services and duration of

period of treatment

– No changes to treatment

– Services are not added/deleted after treatment

• ANY changes require new ABN

• Each visit, patient’s sign or initial back of ABN

original and date

– Not CMS requirement - Noridian advisement

May 2015 53

Voluntary ABN

• For services that are statutorily excluded:

– Acupuncture

– Counseling/education

– Dietary advice/nutritional supplements

– Lab or other diagnostic tests

– Physical therapies (exercise, ultrasound, traction)

– Office visits

– Supplies (pillows or vitamins)

– Supportive (bracing, orthopedic)

– X-rays

54 May 2015

Medical Review (MR)

Medical Review (MR) Audit Results

• Documentation missing patient’s name and date of service

• Missing or illegible signatures

• Illegible documentation

• Documentation supported Maintenance therapy

• No response to request for documentation

• Insufficient or absent documentation:

36 May 2015

Medical Review (MR) Audit Results2

• Claims billed from 2 to 4 regions not

supported by documentation

• If billing 2 regions, must report 2

primary/secondary diagnoses

– Documentation MUST support multiple levels

• Need time line (short, moderate, long

term), matching diagnosis(es) and

documentation

May 2015 57

MR Documentation Concerns

• Careful with software-generated documentation

– Some notes include identical entries for different

patients/ different dates of service

• Be careful with check-off sheets

– Difficult to read; lack findings; too generic

– Lack enough space to list specific information

• Non-encounter specific repetitive entries not

containing policy required components

• Whichever documentation style used, must

include required elements for medical necessity

May 2015 58

•Repetitive software

does not provide

encounter specific

documentation

results

•Example shows

Subjective/Objective

EXACTLY the same

and NOT PAYABLE

•Monies recouped

59 May 2015

Documentation Tips

• Complete and legible

• Clearly identify medical necessity

• Utilize standard abbreviations

• Include plan of treatment

• Computerized documentation may not provide individualized information

– Detail specific date of service elements

– Clarify which services necessary

– Documentation supports each level/date billed

May 2015 60

Documentation Tips 2

• Documentation needs S.O.A.P notes

– Subjective

– Objective

– Assessment

– Procedure/Plan

• Computerized documentation caution

– Cannot reflect same notes and change patient name

• May also use P.A.R.T notes

May 2015 61

Documentation – Signatures

• Handwritten or electronic signature accepted

• Must be signed prior to billing

• Stamp signatures not acceptable

– Exception for physical disability

– CR 8219 dated June 18, 2013

• Physicians/NPPs can not add late signatures

– Except short delay during transcription

– Use signature authentication process

May 2015 62

Documentation – Signatures 2

• Signature Attestation statement (if needed) – Must be signed/dated by medical record entry author

– Contain appropriate beneficiary information

– Include with requested documentation only

• JE states – https://med.noridianmedicare.com/web/jeb/cert-

reviews/signature-requirement-q-a

• JF states – https://www.noridianmedicare.com/partb/claims/cert/in

dex.html

• CR 6698 Signature Guidelines – http://www.cms.gov/transmittals/downloads/R327PI.pdf

May 2015 63

Maintaining Records

• Providers required to maintain records

– CMS suggests 6 years from initial date of

service or state requirement (if longer)

• Existing requirements

– Record retention considered part of normal

business practice

– 42 Code of Federal Regulations (CFR)

Section 424.516(d) and 45 CFR, Section

164.316(b)(2)

May 2015 64

Comprehensive Error Rate

Testing (CERT)

CERT Process

• Livanta-CERT Documentation Contractor

– Requests documentation for selected claims

• Advance Med- CERT Review Contractor

– Reviews submitted CERT documentation

forwarded by Livanta

May 2015 66

CERT – JE Home Page

May 2015 67

CERT - JF Home Page

May 2015 68

Top Errors Affecting Part B

Service Type

2013 Report 2014 Report

Improper Payment

Rate

Improper Payment

Rate

Hospital Based E/M - Initial 28.3% 31.3%

Hospital Based E/M - Subsequent 18.2% 20.7%

Critical Care E/M 22.9% 29.2%

Chiropractor Services 51.7% 54.1%

Ambulance Services 6.7% 12.4%

May 2015 69

Insufficient Documentation

• Chiropractor Claims

– Chiropractic treatment plan

– Documentation insufficient to support billed

service

70 May 2015

CERT Error Examples

• CERT requested documentation

– Missing initial/subsequent treatment plans

– No new injury reported

– Missing initial/subsequent treatment plan

documentation in patient medical record

– Deemed not reasonable and necessary

– Treatment plan records were never sent to

CERT

May 2015 71

CERT Error Examples 2

• With multiple DOS – Missing documentation to support initial visit, patient

history and treatment plan

– Daily notes not legible - unable to interpret abbreviations

– Documentation that cannot be deciphered does not support medical necessity

• Noridian requested copies of initial visit and evaluation – Received typewritten treatment plan – no signature

• Missing provider signature attestation document

– Received “altered” duplicate documentation • With addition of provider signature

• Documentation fails medical necessity requirements

May 2015 72

CERT Error Examples 3

• Missing items in progress note and treatment notes – Evaluation, plan of treatment including past health history

– Quality and character of symptoms/problems

– Onset date, intensity, frequency and prior symptoms

– Aggravating/relieving factors, interventions, treatments, medications, secondary complaints supporting treatment

• Documentation “injuries related to shoveling snow” – Mechanism of trauma – not a complaint

• Statement “recommended treatment “as needed basis” – “Return PRN” is not a treatment plan – too vague

– Manipulative services rendered must have direct therapeutic relationship to patient’s condition

May 2015 73

CERT Error Examples 4

• Multiple DOS reviewed – Areas for CMT never documented

– No treatment plan

– Whatever therapy was given appears to be maintenance

• Inappropriate/invalid ABNs given – Service is always listed as “an adjustment” with no rationale

given for why service will be denied

– No prices listed advising beneficiary of liability amounts

• Missing additional manipulated spine regions – Billed 98941 – 3 to 4 regions

– Documentation supported 1 to 2 regions

• Missing initial evaluations and treatment plan

May 2015 74

CERT Error Examples 5

• 98941 billed – submitted documentation

included signed progress notes; but missing:

– Initial evaluation and initial treatment plan

– Received unsigned typed progress notes

• Noridian requested initial evaluation; initial

treatment plan and signature attestation

– Requested documentation never received

• Service not meeting medical necessity

– LCD documentation requirements not met

May 2015 75

CERT Audit Reminder

• If CERT post pay audit contractor requests

– Fax timely all specific records/documentation

• Send to CERT contractor timely with:

– Chief complaint/Plan of Care

– Chart/Treatment notes

– Proof of medical necessity

– Referring/Ordering physician notes (if any)

– Documentation must support CPT level

May 2015 76

CERT Documentation

Checklists

• Guidance for audit request responses

• CERT requests

– https://med.noridianmedicare.com/web/jeb/cer

t-reviews/cert/checklists

– Chiropractic Documentation

May 2015 77

Reminders & Resources

http://www.roadto10.org/

Small Physician’s Route to ICD-10

CMS No Cost Tool

– Overview of ICD-10

– Specialty References

– BUILD your personal action plan

– Webcasts , Events and FAQs

– Quick References & Template Library

May 2015 79

Resources

• CMS (IOM) Medicare Benefit Policy

Manual

– http://www.cms.gov/Manuals/IOM/

– Publication 100-02, Chapter 15,

• Section 30.5, Chiropractic Coverage

• Section 240.1, Chiropractic Services-General

– Publication 100-04, Chapter 12, Section 220

– Publication 100-08, Chapter 3, Section 3.3.2.4

May 2015 80

Chiropractic Booklets http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-

MLN/MLNProducts/downloads/Chiropractors_fact_sheet.pdf

May 2015 81

October 2013

Review Programs Guide

• Medicare Claim Review Programs Booklet – January 2014

– Current April 2015

• Includes MR, CCI, MUE, CERT & RA

– http://www.cms.gov/M

LNProducts/download

s/MCRP_Booklet.pdf

May 2015 82

CMS ABN Guide

• August 2014

– http://www.cms.gov/MLN

Products/downloads/ABN

_Booklet_ICN006266.pdf

May 2015 83

Fourth Edition

Incentive Program Resources

• PQRS Website – http://www.cms.gov/Medicare/Quality-Initiatives-Patient-

Assessment-Instruments/PQRS/

• Medicare EHR Incentive Programs – http://www.cms.gov/Regulations-and-

Guidance/Legislation/EHRIncentivePrograms/

• Value Based Modifier (VBM) – http://www.cms.gov/Medicare/Medicare-Fee-for-Service-

Payment/PhysicianFeedbackProgram/ValueBasedPaymentModifier.html

• Frequently Asked Questions (FAQs) – https://questions.cms.gov/

• American Chiropractic Association (ACA) – http://www.acatoday.org/patients/index.cfm

May 2015 84

Sign Up – Part B Medicare News!

• Receive most recent Noridian/CMS news – Tuesday/Friday

– Simple/quick signup

– Regulation/policy updates

– Payment/reimbursement

– Workshop/educational event notices

– Noridian hours of availability/related notifications

JF

JE

May 2015 85

Endeavor Online Provider Portal

• Free to providers with Internet – Beneficiary Eligibility

– Claim Status including Reviewer Comments

– Payment Floor / Prior Checks Issued

– Single Claim / Entire Remittance Advice

– Reopening & Redetermination Submission

– Appeal Status

• Additional resources include – Self-Paced tutorial for Part B

– System availability alerts on the Medicare website

– User Manual; valuable, many screen images and guides

– Workshops and presentations

• Eligibility “Main Menu” page next slide

May 2015 86

Noridian Likes Website Feedback!

•Provide constructive/complimentary feedback to continue Noridian website growth and improvement

May 2015 87

CEU Process Reminder

• When registering, add additional attendees

– First and last names

– No longer accepting names in CHAT

• Attend entire workshop

• Take short polling survey

– After closing out of webinar

• CEU emailed 3 days after presentation

– Earned 1.5 CEUs today

– No password or index number needed

88 May 2015

Updated

Thank You!

What Questions Do You Have?