MMA Presents its 19th Annual Practice Education Seminar on Wednesday at Augusta Civic Center
Robert D. Otten, Vice President, Health Policy at the American Medical Association and Kurt Mosely of Merritt Hawkins are two of the more than a dozen faculty for the program. This seminar, being held for the 19th year, will be at the Augusta Civic Center and physicians and practice staff may register to attend via the MMA website at www.mainemed.com. The theme of the seminar this year is What is Expected of Physicians Today and features both plenary sessions and breakout sessions. Nearly one hundred physicians and practice managers are expected to attend. David Howes, M.D., President of Martin's Point Heath Care, will present the keynote talk kicking off the day.
The MMA Practice Education Seminar runs from 8:30 a.m. to 4:15 p.m. and registration is available beginning at 8:00 a.m. The annual seminar provides an opportunity for MMA to present to members and their staffs the practical information that can assist in operating a practice in today's environment and to note the many trends about which physicians should be aware. Registration materials have been mailed to all MMA members and their office staff managers (if known to us).
Mr. Otten is a 25-year employee of the AMA and currently serves as Vice President of the Association's Health Policy Group. Prior to being appointed Vice President in 2006, Mr. Otten served the Association in a number of other capacities including as Director of the Division of Socioeconomic Policy Development. He received his BA and MS degrees in health education, with distinction, from Purdue University. He has written extensively on health care financing and delivery and has published articles in a variety of health policy journals, including the Journal of Health and Hospital Law, the Medical Staff Counselor, and The Journal of Medical Practice Management.
For further information or to discuss exhibit opportunities at the Seminar, call Gail Begin at 622-3374, ext. 210.
Act Now to Help Preserve Medicare Physician Payments!
With the Medicare payment cut for physicians now delayed only until May 31, 2010, Maine physicians need to take action now to advocate that the Congress once and for all repeal the flawed sustainable growth rate (SGR) formula and establish a new payment system that reimburses physicians fairly for the cost of providing services to Medicare recipients. Pushing the payment cut down the road year-to-year and now month-to-month is as unfair to physicians and their Medicare patients as it is financially irresponsible. Each month that passes without repeal adds to the ultimate cost of replacing the formula.
The cost to repeal the formula and freeze payment rates is estimated by the independent Congressional Budget Office (CBO) to be nearly $250 billion. But by 2015, the cost is estimated to be $500 billion. It will never be less costly that it is right now to permanently repeal the formula. Maine Senators Olympia Snowe and Susan Collins are critical to the effort to permanently repeal the formula as it will take sixty votes in the Senate and therefore any solution must have an element of bi-partisanship.
Maine is uniquely unsuited for the payment cut, as we have the oldest population in the country and thus a higher percentage of Medicare patients than other states. And we have a large number of Medicaid patients (MaineCare) and a significant shortage of physicians. While physicians in some other states may simply choose not to accept Medicare patients, that solution is not available in many areas of the state, nor is it the solution most Maine physicians would prefer.
As it is essential that the permanent solution to the SGR be enacted before the May 31st deadline, physicians need to communicate to Senators Snowe and Collins the urgency of the situation and urge them to support legislation that would permanently repeal the sustainable growth rate and replace it with targets similar to those included in the House bill last Fall.
Republicans do not currently support a permanent repeal of the SGR without the cost of such a solution being paid for, as opposed to increasing the already burgeoning federal deficit. Senators Snowe and Collins should be encouraged to find sufficient offsets in the President's budget to pay for the SGR fix.
You can help with this important effort as follows:
1. Communicate with Maine's congressional delegation (Senators Snowe & Collins, in particular) through the AMA's grassroots action center: http://www.ama-assn.org/ama/pub/health-system-reform/repeal-medicare-sgr.shtml.
2. MMA is also participating in a petition drive initiated originally by the Texas Medical Association but now supported by all fifty state medical societies and several national specialty societies. The goal is to deliver a petition with more than a million signatures to members of Congress stating support for a permanent solution to the SGR problem. The petition is available for your signature on line at: http://www.ipetitions.com/petition/meltdown/.
We can't emphasize enough the importance of contacting our influential Senators and encouraging them to help bridge the partisan gap that is making this issue so difficult to resolve.
Democratic leaders in the House and Senate are preparing legislation to be voted on by the House this coming week that is expected to further delay the cut, and perhaps even provide for a small positive update, but it is unlikely to contain a permanent repeal. But even passage of this extension is not a sure thing, particularly in the Senate where Republicans are likely to object to the cost of the package. MMA will be communicating the need to fix this problem with Senators Snowe and Collins, but all MMA members and their staffs should communicate as well. Access to care for Maine's seniors should be emphasized.
The AMA is conducting a survey on the SGR problem and the MMA encourages you to follow this link for more information about the survey and how to access it: http://www.ama-assn.org/ama/pub/advocacy/current-topics-advocacy/practice-management/medicare-physician-payment-reform-regulatory-relief/medicare-sgr-survey.shtml.
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Maine Quality Forum Advisory Council Hears of Plans for Performance Measurement - Public Reporting
The Maine Quality Forum Advisory Council met last Friday morning, May 14th at the offices of the Dirigo Health Agency and heard a series of presentations, including a presentation by MQF Director Josh Cutler, M.D. on Public Law 2009, Chapter 350. Chapter 350 was enacted by the 124th Legislature and requires the Maine Health Data Organization and the Maine Quality Forum to report on hospital and physician quality measures by September of this year. No decision has yet been made regarding the precise data source to use for the reporting and the reporting deadline is likely to be missed, but at some point physicians will need to be aware of the data being used and the services and procedures being measured.
Much of the focus of the discussion was on the possibility of using well-established patient experience surveys for the public reporting, but the expense of using such a survey for all physicians was a concern. Using the primary care case management data from MaineCare would be a possibility as well, although that data only is provided by primary care physicians currently. MMA representatives noted the value of allowing the reporting to be voluntary, similar to the Maine Health Management Coalition's Pathways to Excellence program. It is MMA's position that compelling reporting at the individual physician level would be an undue administrative burden to the already over-burdened practices.
The current reporting on cost and quality can be reviewed at www.healthweb.maine.gov/claims/healthcost and at www.mainequalityforum.gov/
A recent newspaper article by reporter John Richardson on this issue (Maine Sunday Telegram, May 16) stated that the Maine Health Data Organization and the Maine Quality Forum were working to update, improve, and combine the information on prices and quality and that the legislature had set a deadline of September to provide the improved information to Maine consumers.
Dr. Cutler will discuss the options available under the law in his presentation at the 19th Annual Practice Education Seminar this Wednesday in Augusta (see lead article above).
The Advisory Council also received reports on the following initiatives:
- The Beacon Community HIT grant received by Eastern Maine Health Care and other collaborating organizations in the Bangor area;
- Stroke Systems of Care;
- Heart Failure Summit; and
- HIT Updates.
- State Health Plan
The Council, chaired by Robert Keller, M.D., will meet next on Friday, September 10, 2010.
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MMA and OSA Team Up for Free CME in Wells on Friday, June 18
The Maine Medical Association and the State Office of Substance Abuse will present Comprehensive Management of Patients with Acute & Chronic Pain While Preventing Diversion, a three hour CME seminar in Wells on Friday, June 18th. The program will be held from 9:00 a.m. to noon at the Village by the Sea on Rt. 1 (1373 Post Rd.) in Wells. There is no cost for the program.
Faculty for the program include Mark Publicker, M.D., an addiction specialist and Director of the Recovery Center at Mercy Hospital, Daniel Eccher of the Office of Substance Abuse, and Gordon Smith, Esq., Executive Vice President of the Maine Medical Association. Dr. Publicker will share best practices in the areas of pain control, addiction treatment, and prevention. He will also discuss how to manage pain without causing addiction.
Registration materials are available from the MMA office (call 622-3374, ext. 219) or you may register on the MMA website at www.mainemed.com.
The program is made possible through a grant by the Maine Office of Substance Abuse. [return to top]
Workers' Compensation Board Revisits Facility Fee Schedule
Last Fall, the Maine Workers' Compensation Board failed to proceed with revisions to its Rule Chapter 5 dealing with fees that would have established a fee schedule for health care facilities such as hospitals and ambulatory surgical facilities. The obstacle was the business advocates concern that the draft revisions, based upon an analysis by Eric Anderson, an actuarial consultant with Ingenix hired by the Board for assistance with the project. The Board had asked Eric to gather more data and to perform some additional analysis, in particular to compare the proposed base rates with those of private third party payers. Eric presented his latest work at the Board's regular meeting on Tuesday, May 11th. This analysis shows that the proposed base rates in the original rule that never made it through the APA process appear substantially lower than the commercial market standard, at least for hospital inpatient and outpatient services. The Board could not agree on the terms of publishing the rule once again, so members will have to revisit the issue again at their next meeting. [return to top]
National Children's Study to Form Basis of Child Health Guidance, Intervention & Policy
Dr. Laura Blaisdell presented information on the National Children’s Study (NCS) at the recent meeting of the MMA Public Health Committee. The National Children’s Study contract was awarded to the Maine Medical Center (MMC) and the MMC will work with its subcontractors, the University of Southern Maine (USM) and the National Opinion Research Center at the University of Chicago (NORC), and the local research, healthcare, and community partners to conduct all study-related activities in Cumberland County.
The National Children’s Study is examining the effects of environmental influences on the health and development of more than 100,000 children across the United States, following them from before birth until age 21 years. The goal of the Study is to improve the health and well-being of children. The Study defines “environment” broadly and takes a number of issues into account, including:
Natural and man-made environmental factors
Biological and chemical factors
Behavioral influences and outcomes
Cultural and family influences and differences
Researchers are analyzing how these elements interact with each other and what helpful and/or harmful effects they might have on children’s health and development. By studying children through their different phases of growth and development, researchers will be better able to understand the roles these factors play in health and disease. Findings from the Study will be made available as the research progresses, so that the public can benefit from any information as soon as possible.
The Study will also allow scientists to identify differences among groups of people, in terms of their health, health care access, disease occurrence, and other health issues, so that these differences or disparities can be addressed.
The National Children’s Study will be one of the richest information resources available for answering questions related to children’s health and development and will form the basis of child health guidance, intervention, and policy for generations to come. The findings will also inform scientists and the public about how these factors influence adult health.
The Maine NCS Study Team consists of:
Dr. John Bancroft, Principal Investigator
Dr. Nananda Col, Co-Principal Investigator
Dr. Laura Blaisdell, Co-Investigator
Dr. Carol Ewan-Whyte, Study Coordinator
Dr. Lee Lucas, Co-Investigator
Deborah Deatrick, Co-Investigator
Ana Jacobs, Community Liaison
Karen Stowe, Forms Manager
Eva Farina-Henry, Communications
For more information and how to become more involved with the study:
Contact the Maine NCS Team – Eva Farina-Henry at 662-1524 or firstname.lastname@example.org
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AMA Provides Overview of IPAB in Health Care Reform Law
One of the most controversial provisions of the Patient Protection and Affordable Care Act was the establishment of an Independent Payment Advisory Board (IPAB). The AMA is opposed to the current scope and authority of IPAB and the lack of flexibility in its mandate. Modification of the IPAB authority and framework is one of the highest legislative priorities for the AMA in the next session of Congress.
What is the IPAB?
The Patient Protection and Affordable Care Act established a 15-member IPAB to extend Medicare solvency and reduce spending growth through the use of a spending target system and fast-track legislative approval process.
By April 30 of each year—beginning in 2013—the Centers for Medicare & Medicaid Services (CMS) Actuary's Office will project whether Medicare's per-capita spending growth rate in the following two years will exceed a targeted rate. Initially, the targeted rate of spending growth will be based on the projected five-year average percentage increase in the Consumer Price Index for all urban consumers and the Consumer Price Index for all urban consumers for medical care.
Beginning in 2019, the target will be set at the nominal gross domestic product per capita + 1.0 percent. If future Medicare spending is expected to exceed the targets, the IPAB will propose recommendations to Congress and the president to reduce the growth rate. The IPAB's first set of recommendations would be proposed on Jan. 15, 2014.
Spending rate reductions will be established at:
- 0.5 percent in 2015
- 1.0 percent in 2016
- 1.25 percent in 2017
- 1.5 percent in 2018 and beyond
If Congress fails to pass legislation by Aug. 15 each year to achieve the required savings through other policy changes, the IPAB's recommendations will automatically take effect. The IPAB is prohibited from submitting proposals that would ration care, increase revenues, change benefits, modify eligibility, increase Medicare beneficiary cost-sharing (including Parts A and B premiums), or change the beneficiary premium percentage or low-income subsidies under Part D. Hospitals and hospice will not be subject to cost reductions proposed by the IPAB from 2015 through 2019. Clinical labs would be exempt for one year.
Beginning July 1, 2014, the IPAB must also submit an annual report providing information on system-wide health care costs, patient access to care, utilization and quality of care that allows comparison by region, types of services, types of providers, and payers—both private insurers and Medicare. By Jan. 1, 2015, and at least every other year thereafter, the IPAB will submit recommendations to slow the growth in national health care expenditures while preserving or enhancing quality of care. These recommendations could be those that: (1) the secretary of Health and Human Services (HHS) and other federal agencies could implement administratively; (2) may require federal legislation to be implemented; (3) may require state or local government legislation to be implemented; or (4) private entities can voluntarily implement.
Fast-track legislative process
- By Jan. 15 of each year, beginning in 2014, the IPAB must submit a proposal to Congress and the president for achieving Medicare savings targets in the following year.
- If the IPAB fails to submit a proposal to Congress and the president by Jan. 15, the HHS secretary must submit a proposal for meeting the savings targets to the president and the Medicare Payment Advisory Commission (MedPAC) by Jan. 25 of that same year. The president must submit the secretary's proposal to Congress within two days.
- The House and Senate Majority Leader or their designee must introduce the IPAB proposal the same day it is received (or on the first day the chamber is in session). If the proposal is not introduced within five days, any senator or representative can introduce it.
- The proposal must be referred to the Senate Finance Committee and the House Ways and Means and House Energy and Commerce Committees.
- By April 1, the committees of jurisdiction are to complete their consideration of the proposal. Any committee that fails to meet that deadline will be discharged from further consideration.
- Congress cannot consider any bill or amendment that does not meet the IPAB targets or that would repeal or change the fast-track congressional consideration process without a three-fifths vote (60) in the Senate. Non-germane amendments are not permitted.
- The HHS secretary must implement the IPAB proposal on Aug. 15 of the year in which the proposal is submitted. Recommendations regarding the physician fee schedule would take effect on Jan. 1 the following year. If Congress does not pass the proposal before Aug. 15, or if the president vetoes the proposal as passed by Congress, the original IPAB recommendations would take effect. (All policy changes affecting physicians that are not part of the physician fee schedule will be addressed in the regulatory process and will take effect as soon as practicable.)
IPAB board members
The IPAB members are to include:
- Fifteen members appointed by the president, by and with the advice and consent of the Senate; in selecting individuals for nominations for appointments to the board, the president shall consult with: (i) the majority leader of the Senate concerning the appointment of three members; (ii) the speaker of the House of Representatives concerning the appointment of three members; (iii) the minority leader of the Senate concerning the appointment of three members; and (iv) the minority leader of the House of Representatives concerning the appointment of three members
- The HHS secretary, the administrator of CMS, and the administrator of the Health Resources and Services Administration (all of whom will serve ex officio as nonvoting members of the Board)
Qualifications/requirements for IPAB members:
- Appointed members of the IPAB will include individuals with national recognition for their expertise in health finance and economics, actuarial science, health facility management, health plans and integrated delivery systems, health facilities reimbursement, allopathic and osteopathic physicians, other providers of health services, and other related fields who provide a mix of professionals, broad geographic representation, and balance between urban and rural areas.
- IPAB members must include (but not be limited to) physicians and other health professionals, experts in the area of pharmaco-economics or prescription drug benefit programs, employers, third-party payers, individuals skilled in the conduct and interpretation of biomedical, health services, and health economics research, and expertise in outcomes and effectiveness research and technology assessment. Members must also include individuals representing consumers and the elderly.
- Individuals who are directly involved in providing or managing the delivery of Medicare items and services may not constitute a majority of IPAB's membership.
- The president must establish a system for public disclosure by IPAB members of any financial and other potential conflicts of interest.
No IPAB member may be engaged in any other business, vocation or employment. [return to top]
Maine Legislature's HSR Committee Named & First Meeting Scheduled
The legislature's presiding officers have named the members of the Joint Select Committee on Health Care Reform Opportunities & Implementation established by H.P. 1262, http://www.mainelegislature.org/LawMakerWeb/summary.asp?ID=280035507, and the Committee's first meeting is scheduled for this Thursday, May 20th.
The members of the Committee are:
Joint Select Committee on Health Care Reform Opportunities and Implementation
Appointment(s) by the President of the Senate
Sen. Joseph C. Brannigan, Co-chair
168 Concord Street
Portland, ME 04103
Sen. Kevin L. Raye
63 Sunset Cove Lane
Perry, Maine 04667
Sen. Margaret M. Craven
41 Russell Street
Lewiston, ME 04240
Sen. Earle L. McCormick
633 Hallowell Litchfield Road
West Gardiner, ME 04345
Sen. Justin Alfond
134 Sheridan Street
Portland, ME 04104
Appointment(s) by the Speaker of The House
Rep. Sharon Anglin Treat, Co-chair
22 Page Street
Hallowell, ME 04347
Rep. Emily Ann Cain
103 Forest Avenue
Orono, ME 04473
Rep. Patrick S. Flood
56 Wedgewood Drive
Winthrop, ME 04364
Rep. Elizabeth S. Miller
6 Hemlock Lane
Somerville, ME 04348
Rep. Wesley E. Richardson
893 North Pond Road
Warren, ME 04864
Rep. Gary A. Connor
10 Patterson Drive
Kennebunk, ME 04043
Rep. Leslie T. Fossel
P.O. Box 525
Alna, ME 04535
Rep. Adam Goode
303 Hammond St., Apt. 15
Bangor, ME 04401
Rep. Charles Priest
9 Bowker Street
Brunswick, ME 04011
Rep. Linda S. Sanborn
170 Spiller Road
Gorham, ME 04038
Rep. Meredith N. Strang Burgess
155 Tuttle Road
Cumberland, ME 04021
Colleen McCarthy Reid 287-1670
Chris Nolan 287-1635
The draft agenda for the first meeting follows:
Joint Select Committee on Health Care Reform
Opportunities and Implementation
Thursday May 20, 2010
10am to 3pm
Taxation Committee Room 127
1. Welcome and introduction from chairs (chairs)
· Housekeeping items –expense forms
· Introduction of staff
2. Committee member introductions and discussion of goals and priorities (chairs, committee members)
3. Review of joint select committee charge (staff))
4. Overview of federal health care reform law (Joy Johnson Wilson, NCSL)
· State role in implementation
· Timeline for implementation –short-term v. long-term
5. Overview of Maine Health Coverage laws (staff)
6. Lunch Break
7. Update on Executive Branch Planning Activities
· Trish Riley
· Brenda Harvey
· Mila Kofman
8. Committee Discussion and Planning (committee)
· Identification of questions/areas of focus for members
· Organization of workload
· Scheduling future meetings
9. Wrap up (chairs)
The MMA will keep you informed of the work of this Committee through the Maine Medicine Weekly Update and other communications. [return to top]
Not Too Early to Plan for MMA's 157th Annual Meeting, September 10-12, in Bar Harbor
MMA's 157th Annual Meeting will be held in Bar Harbor from September 10-12, 2010. The educational sessions will begin again at Jackson Laboratories on Friday afternoon, September 10th at 1:00 p.m. The theme for this year's meeting is Life Transitions for Patients, Families and Communities and features presentations on aging and related topics, including scientists from Jackson's Center for Aging matched with practicing clinicians. Sunday morning will feature a Gubernatorial Forum with candidates addressing issues related to public health.
Following the Friday sessions at Jackson Laboratories, the Saturday and Sunday morning sessions will be held at the conference center (The Bar Harbor Club) associated with the Harborside Hotel and Marina. The Saturday afternoon CME session is entitled, Transitions in Health - Transitions in Care and will feature a panel moderated by Laurel Coleman, M.D. highlighting some of the challenges faced by patients and health care providers when health status changes.
On Saturday evening, MMA President David McDermott, M.D., M.P.H. will turn the Presidential gavel over to Jo Linder, M.D. The Mary Cushman Humanitarian Award will also be presented during the Annual Banquet.
On Sunday morning, preceding the Gubernatorial Forum, interested attendees will run the 30th Annual Edmund Hardy Road Race. MMA is making an attempt to invite all previous runners to join us for this special anniversary race. Andrew MacLean, Deputy EVP, will once again serve as the Race Director.
Watch for registration materials which will be in the mail to members later this month. Registration will also be available on the MMA website at www.mainemed.com after June 1st. For more information contact Diane McMahon at 622-3374, ext. 216 or via e-mail to email@example.com. For information on exhibiting, contact Lisa Martin at 622-3374, ext. 221 or via e-mail to firstname.lastname@example.org.
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MaineCare Proposes National Criteria for PA on Certain Services
The Maine DHHS has proposed revisions to the MaineCare Benefits Manual (MCBM) Chapters II & III, Section 90, Physician's Services that would apply "industry recognized criteria utilized by a national company under contract." The "national company" apparently is McKesson. The rulemaking notice goes on to state, "In cases where the portal requires that certain criteria be met, and the provider fails to meet those criteria, such services will not be covered or allowed under the MaineCare program." Apparently, there is no avenue for appeal of a denial of coverage on the basis of any other standard other than the McKesson standard, such as a waiver.
The proposal lists the following services that will be covered with prior authorization:
- Out-of-state services;
- Vagus Nerve Stimulation;
- Orthognathic Surgery;
- Breast Reduction and Mastopexy;
- Gastric Bypass, Gastroplasty and Adjustable Gastric Banding;
- Breast Reconstruction; and
- Removal of Excess Skin and Subcutaneous Tissue of Abdomen.
The proposal lists the following services that will be covered "when special criteria are met:"
- Abortion Services;
- Sterilization Procedures and hysterectomies;
- Cochlear Implants;
- Cosmetic Procedures;
- Hyperbaric Oxygen Therapy; and
- Infertility Treatments.
You can find the rulemaking documents and may comment online at: http://www.maine.gov/dhhs/oms/rules/proposed.shtml#id95421.
The comment deadline is Thursday, June 3, 2010. If you would like to share comments with the MMA, please contact Andrew MacLean, Deputy EVP at 622-3374, ext. 214 or by email at email@example.com.
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MaineCare Announces New PA Process for Atypical Antipsychotics
Recent studies show that atypical antipsychotic medications are frequently being prescribed inappropriately. For example, one study noted that of 279,778 patients who received at least one prescription of an antipsychotic in 2007, 60.2% had no record of a diagnosis for an FDA approved indication (http://jama.ama-assn.org/cgi/content/short/303/16/1582). Manufacturers of atypical antipsychotics have been fined large amounts for fraudulent marketing of these products, behavior which has contributed to high rates of inappropriate use. The off label use of these drugs have made them the most costly medication class to MaineCare.
Examples of inappropriate use include prescribing these medications for insomnia, dementia related psychosis, attention deficit disorder, and anxiety disorders. Not only are they expensive, atypical antipsychotics have side effects that include weight gain, diabetes, lipid abnormalities, and potentially irreversible movement disorders such as tardive dyskinesia, amongst others.
Effective July 1, 2010, MaineCare will introduce a prior authorization process for atypical antipsychotics which will apply to all non-psychiatric prescribers. The prior authorization process will require that use of this medication class be in accordance with FDA approval or literature-supported evidence-based best practices. Examples of appropriate utilization includes the treatment of schizophrenia, bipolar disorder, agitation related to autism, and severe behavioral dyscontrol with risk of imminent need to access emergency services such as the emergency room, crisis services, or an inpatient psychiatric facility.
Atypical antipsychotics are also being increasingly utilized in combination with antidepressants to treat patients with major depression. This use will be permitted upon demonstration that a patient has previously tried two distinct antidepressants from two distinct classes (SSRIs, SNRIs, TCAs, bupropion).
This policy will foster appropriate use of these medications resulting in cost savings and improved patient care without imposing an undue burden upon patients and prescribers.
For those who may be interested in what MaineCare may be implementing for cost saving or safety measures, you may attend the Drug Utilization Review Committee meetings. These meetings are held 9 times a year, the second Tuesday of the month, excluding December, July and August from 6-8 p.m. The location is 442 Civic Center Drive at the Office of MaineCare Services.
If you have questions you may contact Goold Health Systems at 1-888-445-0497 or Jennifer Palow, Pharmacy Division Manager at Jennifer.Palow@maine.gov. [return to top]
Red Flags Rule Compliance Date Now is June 1st; Prospects for Further Delay Unclear
The most recent delay in the compliance deadline for the controversial FTC "red flags" rule expires May 31st, meaning that compliance by health care providers is expected June 1st. The AMA has provided some excellent guidance on this subject on the web at: http://www.ama-assn.org/ama/pub/physician-resources/solutions-managing-your-practice/practice-management-center/data-security/red-flags-rule.shtml. [return to top]