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Q/A: Coding for telescopic intraocular lens

Fri, 10 Feb 2012 05:00:00 GMT

Q: An ophthalmologist implanted a telescopic intraocular lens (C1840) that is supposed to be separately payable. Our FI/MAC didn’t pay us and said it processed the claim correctly. Do you have any information about this situation?

A: CMS established new HCPCS code C9732 (insertion of ocular telescope prosthesis including removal of crystalline lens) for calendar year 2012.

According to Transmittal 2386 (January update to OPPS), HCPCS code C1840 (lens, intraocular [telescopic]) is a pass-through category and is separately payable only when reported with new HCPCS code C9732. Review the claim to ensure that you reported both codes. If you did, discuss this with your FI/MAC because there may be a problem in its claims processing system.

Editor’s note: Denise Williams, RN, CPC-H, vice president of revenue integrity services at Health Revenue Assurance Associates, Inc., in Plantation, FL, answered this question.

Tip: ICD-10-CM simplifies meaning of excludes notes

Fri, 10 Feb 2012 05:00:00 GMT

ICD-9-CM contains one type of excludes note with two possible meanings. Nothing in the ICD-9-CM manual tells coders which mean applies, so they must apply logic to determine the meaning.

An excludes note in ICD-9-CM could mean that coders should not use a particular code for a particular condition. Instead coders should look in a different category because they can’t code the two conditions together.

It can also mean that a condition is not included in a particular code. In these cases, coders should assign both codes, if applicable, when patients have both conditions simultaneously.

When coders are looking at the excludes notes, they can become confused. ICD-10-CM will resolve this confusion by instituting two different excludes notes—Excludes1 and Excludes2—to differentiate the meanings.

An Excludes1 note is a pure excludes note. An Excludes1 note indicates that a coder should never use the excluded code with the code above the Excludes1 note. The two conditions cannot occur together.

An Excludes2 note means a condition is not included in the code. An Excludes2 note indicates that the excluded condition is not part of the condition the code represents, but a patient may have both conditions simultaneously. When an Excludes2 note appears under a code, coders may report both the code and the excluded code together when appropriate.

This tip is adapted from “Start preparing for ICD-10-CM: Note differences between ICD-9-CM and ICD-10-CM” on JustCoding.com.

Start date announced for recovery audit prepayment review demo

Thu, 09 Feb 2012 05:00:00 GMT

On November 15, 2011, CMS unveiled three demonstration projects aimed at reducing improper payments in the Medicare program. More than a month later on December 21, CMS held a special open door forum detailing one of the programs: the recovery auditor prepayment review demonstration. As comments and concerns from providers made their way to CMS, news of a delay on two of three of the demos transpired shortly thereafter

Today, CMS announced that both the recovery auditor prepayment review and the prior authorization of power mobility devices (PMDs) demonstration projects are expected to move forward on or after June 1, 2012. The prior authorization of PMDs demonstration was significantly revised as a result of provider and supplier concerns, according to CMS.

For additional information on these demonstrations, click here:

http://go.cms.gov/cert-demos

MPPR to apply for certain diagnostic imaging procedures for Method II CAHs

Wed, 08 Feb 2012 05:00:00 GMT

On January 26, CMS issued a transmittal that implements the multiple procedure payment reduction (MPPR) for physician services for certain diagnostic imaging procedures in critical access hospitals (CAHs). Many facilities may not yet be aware of this implementation so CAHs billing under Method II need to take immediate notice, according to Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc.

Section 1848(c)(2)(K) of the Social Security Act was added into the Affordable Care Act, thus specifying that the Secretary will identify potentially misvalued codes by examining codes that are frequently billed in conjunction with furnishing a single service. As a result of this examination, Medicare is making a change to the MPPR for physician services of certain diagnostic imaging procedures, according to MLN Matters article MM7684.

The release of transmittal R2395 applies the MPPR to physician services of certain diagnostic imaging procedures billed by CAHs that had elected the optional method (Method II) for outpatient billing. Payment made to the CAH for physician services billed on its outpatient claim form using revenue codes 96X, 97X, or 98X is based off of the Medicare Physician Fee Schedule (MPFS) supplemental file, according to the transmittal.

“Although this is good news for patients, since they will pay less out of pocket for the professional fees related to the imaging studies, this change could have a significant impact on CAHs that do a high volume of these services,” says Mackaman. “When looking at the list in attachment 1 (of the transmittal) it is quite lengthy and includes the highest-paying imaging services such as MRIs and CTs with and without contrast, as well as angiography.”

She continues, “A 25% reduction on the lower paying multiple service(s) does not seem like much until you consider how often a hospital provides multiple imaging services during the same session, both for high quality care and for the convenience of the patients. Hospitals should analyze their volume reports, imaging services combinations and payments for those services to anticipate the financial setback to their facilities.”

When the reduction is applied, the remittance advice will show a claim adjustment reason code of 59 (Processed based on the multiple or concurrent procedure rules) and a Group Code of CO (contractual obligation). In addition, deductible and coinsurance are based on the reduced amount, but the 115% add-on after deductible and coinsurance still applies, according to CMS.

The application of the MPPR for diagnostic imaging will apply to the professional fee when multiple services are furnished by the same physician to the same patient in the same session on the same day. Full payment is made for the service that yields the highest payment under the MPFS, and for subsequent services, payment is made at 75%.

Even though the implementation date for the FIs/MACs to begin paying the reduced amount is not until July 2, 2012, the effective date for providers is January 1, 2012. Once the Medicare contractors update their systems to align with this change, hospitals will begin to see the reductions in payments, says Mackaman.

In addition, she added: “It is unclear from the transmittal if contractors will mass adjust claims with dates of service from January 1 forward, so until the claims processing systems are updated hospitals should monitor related transmittals for more information.

“It is not uncommon for CMS to direct contractors to ‘reprocess claims brought to their attention’ and thereby leaving the CAH responsible for resubmitting claims for the proper reimbursement, which would include copayment refunds to their patients as well.”

The current list of codes subject to the MPPR on diagnostic imaging can be found in attachment one of transmittal R2395CP.

Minnesota debt collector sued over stolen medical data

Mon, 06 Feb 2012 20:04:00 GMT

Minnesota Attorney General Lori Swanson filed a lawsuit January 19 against a debt collection agency that she said violated state and federal health privacy laws when it lost a laptop containing patient information from two Minnesota hospitals, according to a press release from the Attorney General’s office.

The unencrypted laptop containing the patient data was stolen from the car of an Accretive Health, Inc. employee in July, while the car was parked in the Minneapolis restaurant district. According to the lawsuit, a screenshot with a patient’s name, date of birth, address, Social Security number, and medical conditions was among the data contained on the laptop.

Accretive Health, Inc., a debt collection agency that is part of a New York private equity fund conglomerate, used the data of more than 23,000 patients to:

Create medical checklists evaluating patients’ physical conditions
Score patients’ risk of hospitalization
Compile per-patient profit and loss statements

Accretive “found a way to essentially monetize portions of the revenue and healthcare delivery systems of some nonprofit hospitals for Wall Street investors, without the knowledge or consent of patients,” according to the lawsuit.

Source: The Office of Attorney General Lori Swanson

Report: Breaches reach 19 million records

Mon, 06 Feb 2012 19:58:00 GMT

Covered entities and business associates reported a total of 385 breaches of unsecured PHI affecting 500 or more individuals since OCR issued the August 2009 interim final breach notification regulation under HITECH, according to a report released by Redspin. This included more than 19 million records.

In its “2011 Breach Report / Protected Health Information,” authors say improvements in healthcare IT security must be measured by the reduction of the number of breach incidents and people impacted.

Redspin also provides specific recommendations for preventive action and corrective measures to reduce the most critical vulnerabilities. The authors hope those recommendations will prompt quicker adoption of electronic health records (EHR). In turn, EHR adoption will improve the cost efficiency, care delivery, and patient outcomes within the U.S. healthcare industry, the authors claim.

Redspin determined that health data breaches in the US increased by nearly 100% in from 2010 to 2011. The data also reveals that 60% of all breaches consist of malicious attacks such as theft, hacking, and insider incidents.

Q/A: New device pass-through categories

Fri, 03 Feb 2012 05:00:00 GMT

Q: Will CMS ever approve any new device pass-through categories?

A: CMS established one new device pass-through category for CY 2012, HCPCS code C1886 (catheter, extravascular tissue ablation, any modality [insertable]).

Under OPPS payment methodology, a pass-through payment for a device includes an offset of the APC payment. When a pass-through code is reported and reimbursed, CMS deducts amount for the procedure the APC payment because payment for devices without pass-through has been included in the calculation of the APC payment.

Finance and billing departments should monitor these payment amounts to ensure appropriate application of this methodology.

Editor’s note: Andrea Clark, RHIA, CCS, CPCH, chairman, CEO, and founder of Health Revenue Assurance Associates, Inc., in Plantation, FL, answered this question.

Tip: Note physician supervision changes

Fri, 03 Feb 2012 05:00:00 GMT

CMS finalized two significant changes to the physician supervision requirements as part of the 2012 OPPS Final Rule.

First, CMS agreed to delay enforcement of physician supervision rules for critical access hospitals (CAH) as well as small and rural hospitals with 100 or fewer beds.

Second, CMS will use the Federal Advisory Panel on Ambulatory Payment Classification Groups (APC Panel) to review supervision levels for outpatient services. These reviews could begin as soon as the winter 2012 APC Panel meeting.

CMS' decision to apply the supervision requirements in 76 Federal Register 74580 §410.27 to all OPPS therapeutic services and all CAH services is particularly interesting. Services to which the requirements will apply include physical, occupational, and speech therapy.

The tip is adapted from “CMS finalizes numerous provider-friendly OPPS changes for CY 2012” in the January issue of Briefings on APCs.

HHS task force: Consider privacy, security with text messages

Mon, 30 Jan 2012 05:00:00 GMT

The government should take a better look at privacy and security concerns before it encourages and helps develop health text messaging and mobile health programs, an HHS task force recommends.

HHS should conduct further research into the privacy and security risks associated with text messaging of health information and establish guidelines for managing such privacy/security issues, according to the task force’s January 26 report.

“The exchange of health information via text messages raises privacy and security issues specific to this medium,” the Text4Health task force wrote in the report. “Text messaging programs may be subject to numerous privacy and security laws, including [HIPAA's] privacy and security rules.”

According to the release, in recent years, mobile health technologies have seen the expansion of:

Health text messaging
Mobile phone apps
Remote monitoring
Portable sensors

These technologies have changed the way healthcare is being delivered in the U.S. and globally, according to an HHS release. According to HHS, the task force was charged with helping identify ongoing initiatives and proposals for the delivery of health information via mobile phones.

Dealing with data breaches

Mon, 30 Jan 2012 05:00:00 GMT

This article by Greg Freeman appeared on the HealthLeaders Media website January 23 and in the January 2012 issue of HealthLeaders Magazine.

You pick up the phone and someone tells you that a laptop containing thousands of patient files was left behind on the morning train. Or you learn that your own employees have been snooping into sensitive patient records for fun and profit. Or you discover that, for some odd reason, patient records have been posted on a completely unrelated public website for anyone to see, and they’ve been there for nearly a year.

Each of these scenarios has played out for some unfortunate healthcare executive, and they hold lessons in how to avoid such disasters, plus the best way to respond to such a crisis. Some of the most notorious HIPAA violations occurred within the UCLA Health System at the UCLA Medical Center, where singer Britney Spears was hospitalized in early 2008.

After the Los Angeles Times reported that employees had been caught perusing Spears’ records with no legitimate reason, the hospital confirmed the HIPAA violations, fired 13 employees, and took disciplinary action against others. It also suspended six physicians.

Demi Moore's medical records redacted

Mon, 30 Jan 2012 05:00:00 GMT

As we’ve been saying all along in HIPAA compliance circles, everyone has privacy rights under HIPAA – even celebrities.

Los Angeles officials planned last week to release an edited record of actress Demi Moore’s 911 call made from her LA home January 23, according to the Los Angeles Times. How will they edit? By removing any personal information about her medical condition and medications.

The Los Angeles City Attorney's office made the recommendation to comply with HIPAA.

Q/A: Reporting negative pressure therapy

Fri, 27 Jan 2012 05:00:00 GMT

Q: The new guidelines for the integumentary system section state that CPT^® codes 15002–15005 are noted to be reportable for surgical preparation of the site, including for negative pressure wound therapy. Please explain how to use these codes when reporting negative pressure wound therapy? This may affect how we report certain wound care services that we provide.

A: The 2012 CPT^® Manual includes a new subheading, “Skin Replacement Surgery” that includes definitions for surgical preparation codes 15002–15005.

The AMA expanded the instructions in 2011 to include negative pressure wound therapy and further defined the instructions for 2012. The 15002–15005 code range denotes the initial preparation of a wound site to create a clean and viable surface for skin graft placement or for negative pressure wound therapy.

CPT codes 15002–15005 may be reported in addition to the codes for skin grafting and negative wound therapy when the intent is for the wound to heal by primary intention. Do not report these codes if a wound is left to heal by secondary intention.

Negative pressure wound therapy, also known as a wound vac, plays an important role in treating wounds. The wound vacuum applies subatmospheric pressure, either continuously or intermittently, to the surface of a wound to promote healing.

CPT code 97605 (negative pressure wound therapy) and CPT code 15002 (preparation of the wound bed) do not trigger a National Correct Coding Initiative (NCCI) Edit triggers. No NCCI instructions prevent reporting the codes together.

The keys to appropriate reporting are to ensure:

Medical necessity is met relative to NCDs or LCDs
Documentation is complete, includes the correct dimensions of the wound, and supports the need for wound preparation
Wound is meant to heal by primary intention

Providers should review the “Skin Replacement Surgery” codes in the 2012 CPT® Manual carefully and ensure that documentation clearly supports the service before assigning any codes in the 15002–15278 range.

Editor’s note: Denise Williams, RN, CPC-H, vice president of revenue integrity services at Health Revenue Assurance Associates, Inc., in Plantation, FL, answered this question.

Tip: Set rates that reflect intent of new codes

Fri, 27 Jan 2012 05:00:00 GMT

CMS expects hospital charges to reflect the relative resources that are required to provide a particular service. Therefore, someone at each hospital must understand new and replaced code changes, determine the intent of the new codes, and work with the appropriate individuals to develop an accurate charge.

Inputting a code in the chargemaster and calling it a day isn’t enough because new codes often represent new combinations even if they don't always represent new services.
If a new code is similar to an existing service, determine how similar (or dissimilar) it is with respect to time, resources, billing units, dosage, and other factors, and then move forward to develop the charge.

Increasingly more new codes represent a combination of existing codes and services. For example, in 2011, the AMA introduced three new combination codes for CT of the abdomen and pelvis. The codes were new, but they did not represent new services; instead they combined two existing services into single codes.

In this example, if the individual who updates the chargemaster simply replaces the old single-service code with a new combination code without reviewing and changing the dollar charge associated with the new code the hospital will continue to bill as if it rendered only a single service, even though the new code represents two services.

The tip is adapted from “Reevaluate charge setting in light of 2012 OPPS final rule” in the January issue of Briefings on APCs.

CMS posts Q4 improper payment figures, top issues by region

Thu, 26 Jan 2012 05:00:00 GMT

Each quarter CMS issues a recovery audit program update that details the total amount of overpayments and underpayments indentified in that quarter. In addition, CMS posts the top recovery auditor issue for each region.

The most recent update, which provides information on the time period July 1, 2011 to September 30, 2011, identifies $277.1 million in overpayments and $76.6 million in underpayments, for a total of $353.7 million in improper payments. These numbers are up from the previous quarter, for which CMS reported $233.4 million in overpayments and $55.9 million in underpayments for a total correction amount of $289.3 million.

For each quarter CMS has issued these reports, the total correction amount numbers have raised dramatically:

October 2009 – September 2010: $92.3 million
October 2010 - December 2010: $94.3 million
January 2011 - March 2011: $208.9 million
March 2011- June 2011: $289.3 million
July 2011 – September 2011: $353.7 million

Perhaps most telling of all the figures, however, is the quarterly difference in the correction amount of the total national program since its inception. The Q3 update lists the total correction amount of the national program at $684.8 million, while the latest report has the amount at $939.4 million. This jump is indicative of the individual recovery auditors ramping up their efforts to identify improper payments nationwide—specifically targeting medical necessity issues, as indicated by the Q4 report:

Region A: Renal and urinary tract disorders (Medical necessity)
Region B: Surgical cardiovascular procedures (Medical necessity)
Region C: Acute inpatient admission neurological disorders (Medical necessity)
Region D: Minor surgery and other treatments billed as inpatient (Medical necessity)

For Region A and D, the top identified issues didn’t change from the Q3 report, but the fact that Region B and C now both identify a medical necessity issue as their top issue truly signifies that the recovery auditors have increased their efforts and focus on issues that may have not been medically necessary for the setting in which they were billed.

To view the Q4 report, click here: http://www.cms.gov/Recovery-Audit-Program/Downloads/FY2011QtrlyReport.pdf

To view the Q3 report, click here: http://www.cms.gov/Recovery-Audit-Program/Downloads/NatProg.pdf

To stay on top of the latest RAC-approved issues in your state, visit the Revenue Cycle Institute website.

Confusing the rebuttal process with the discussion period

Wed, 25 Jan 2012 05:00:00 GMT

The following question and answer is an exchange between a reader and the Revenue Cycle Institute team:

Question: I’m new to handling RAC audits, so I was reading up on the rebuttal process, also known as the “discussion period,” which must be filed within 15 calendar days of the date on the demand letter. I called my RAC (Connolly Healthcare) and was told that the rebuttal letter along with the “stop recoupment” letter should go to my local Medicare administrative contractor (MAC).

The letter we received from Connolly states that we are to notify the “claim processing contractor” and they will review and advise of their decision within 15 days. I’m confusing about who should be receiving the rebuttal letter. When I spoke with Palmetto (our MAC) they were under the impression that I submitted an appeal letter and that they have 60 days to respond. Can you please clarify?

Peeling away the confusion: Split billing guidance

Wed, 25 Jan 2012 05:00:00 GMT

The concept of split billing in both the inpatient and outpatient setting is a hot topic amongst providers as of late, according to Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc.

The guidance for billing in these two settings can both be found within the Medicare Claims Processing Manual, first of which comes in chapter 1, section 70.8.1.

Outpatient split billing

There are a number of prescribed situations where a claim is received for certain services that require the splitting of the single claim into one or more additional claims, according to CMS. Splitting claims is necessary for the following reasons: Proper recording of deductibles, separating expenses payable on a cost basis from those paid on a charge basis, or for accounting and statistical purposes.

According to the manual, expenses incurred in different calendar years cannot be processed as a single claim, so a separate claim is required for the expenses incurred in each calendar year. In addition, Palmetto GBA, a Medicare administrative contractor (MAC), elaborates by stating: “All outpatient claims, SNF claims and non-PPS inpatient claims (e.g. critical access hospitals), which can be billed on an interim basis, should be split at the provider’s fiscal year end and at the calendar year end. It should not be split at Medicare’s fiscal year end unless it corresponds with the provider’s fiscal year.”

Inpatient split billing

For inpatient split billing requirements for the inpatient setting, Trailblazer Health Enterprises, LLC, another MAC, offers a sound summary: Non-PPS providers and providers who are reimbursement through periodic interim payments (PIPs) split-bill their claims at the fiscal year end (FYE), and the days are allocated to the provider year in which they occurred. When services span a non-PPS provider’s FYE for inpatient bills, a provider must submit two claims, the first of which reflects the admission date to the FYE using TOB 112 and status code 30 (still patient). The second claim reflects the first day of the new FY to the discharge date using TOB 115 and the appropriate discharge status code.

Guidance on split billing for inpatient and outpatient services is important to providers since it can prevent delays in payment because they will have to rebill their claims if their outpatient, rural health clinic and swing bed claims cross over calendar years, says Mackaman.

“If providers keep in mind that every calendar year, the patient’s deductibles and coinsurance amounts change for both Part A and Part B services, they can put the split billing process on their radar as part of their annual procedures.”

She continued, “CAHs also need to remember this at the end of their fiscal years for these services as well as their inpatient claims.”

For more information on when to split Part A bills, click here:

http://www.trailblazerhealth.com/Publications/Job%20Aid/WhentoSplitPartABills.pdf

For information on split billing for IPPS hospitals that are paid under the DRG, see section 20.7.2 of the Medicare Claims Processing Manual:

http://www.cms.gov/manuals/downloads/clm104c03.pdf

Atlanta man gets jail time for stealing PHI

Mon, 23 Jan 2012 19:01:00 GMT

A federal judge sentenced an Atlanta man to 13 months in prison January 10 for intentionally accessing a competing medical practice’s computer without authorization in order to send marketing materials to patients, according to a U.S. Attorney’s office release.

Eric McNeal, a 38-year-old IT specialist, accessed the computer owned by A.P.A, a perinatal medical practice in Atlanta and his old employer, according to United States Attorney for the Northern District of Georgia Sally Quillian Yates. After leaving A.P.A. in November 2009, McNeal joined a competing practice located in the same building.

McNeal downloaded the names, telephone numbers, and addresses of A.P.A.’s patients, and then deleted all the patient information from A.P.A.’s system in April 2010. McNeal then targeted those patients with a direct-mail marketing campaign for his new employer, according to federal officials.

Q/A: Reporting molecular pathology codes

Fri, 20 Jan 2012 05:00:00 GMT

Q: Addendum B of the APC updates for 2012 lists the new molecular pathology codes as status indicator E (noncovered service, not paid under OPPS). Our laboratory director has heard that we should report the new codes in addition to the codes that are payable. Can you explain why?

A: Providers use molecular pathology tests to detect the presence of specific genes. Currently, coders report these tests with multiple CPT^® codes to describe the specific testing being performed. Reporting in this manner is sometimes referred to as “stacked” codes.

The AMA created new CPT codes for these tests to reflect the service with a single code for CY 2012, Claims data reflects the stacked codes that historically have been reported for these services. No one-to-one relationship maps the old codes to new codes, so no easy crosswalk between them exists.

Multiple current CPT codes will map to one new code, and one current CPT code will map to several new codes because they are reported for several types of testing. The result is multiple-to-one and multiple-to-multiple mapping that must be considered before payment rates can be determined.

CMS is depending on providers to report both sets of codes to facilitate mapping the new CPT codes to the current cost/pricing information. Assignment of status indicator E should allow this line item to pass through the Integrated Outpatient Code Editor without delaying claims. CMS will not reimburse for the new codes, but reporting in this manner will put the new code on the same claim with current codes for the service. This will allow CMS to analyze the claims with the individual codes and the combination of codes that were reported for future rate-setting under the Clinical Diagnostic Laboratory Fee Schedule. Transmittal 2386 provides the following guidance:

Effective January 1, 2012, under the hospital OPPS, hospitals are advised to report both the existing CPT “stacked” test codes that are required for payment and the new single CPT test code that would be used for payment purposes if the new CPT test codes were active.

Use of the word “advised” suggests this reporting is voluntary. However, providers must carefully consider the future impact if they don’t report both sets of codes. Incomplete and insufficient claims data will be used to determine the payment amount for these services. These molecular pathology tests are complex; if providers don’t report both sets of codes, the resulting payment determination could be insufficient for the services provided. Providers should read the entire section of the transmittal pertaining to reporting these codes.

Note that Transmittal 2386, which was published January 13, replaces Transmittal 2376.

Editor’s note: Andrea Clark, RHIA, CCS, CPCH, chairperson, CEO, and founder of Health Revenue Assurance Associates, Inc., in Plantation, FL, answered this question.

Tip: Corrrectly code image-guided lumbar decompression

Fri, 20 Jan 2012 05:00:00 GMT

Percutaneous image-guided, minimally invasive lumbar decompression witha specially designed toolkit (mild^tm) has been proposed as an ultra-minimally invasive treatment for central lumbar spinal stenosis.

During this procedure, physicians fill the epidural space with contrast medium under fluoroscopic guidance. Using a 6-gauge cannula clamped in place with aback plate, physicians employ single-use tools (e.g., portal cannula, surgical guide, bone rongeur, tissue sculpter, and trocar) to resect thickened ligamentum flavum and small pieces of lamina. Tissue and bone sculpting occurs entirely under fluoroscopic guidance, with additional contrast media added throughout the procedure to aid visualization of the decompression. The process is repeated on the opposite side for bilateral decompression of the central canal.

Report CPT^® category III code 0275T (percutaneous laminotomy/laminectomy [intralaminar approach] for decompression of neural elements) that became effective July 1, 2011, to denote this procedure. This code maps to APC 0280 with a national payment of $3,535.92. Note, however, that automatic CMS coverage is not implied simply because a CPT code with payment exists under OPPS.

The tip is adapted from “This month’s coding Q&A” in the January issue of Briefings on APCs.