Introductory Medicaid Financial Training
for School Based Health Services
State of West Virginia
Department of Health and Human Resources
Bureau for Medical Services
Date: July 2012
Agenda
•
Overview of Program Changes
•
Medicaid Administrative Claiming Overview
•
Introduction to the Cost Settlement Process
•
Introduction to Financial Reporting
•
Financial Reporting Data Elements
•
MAC Calculation Process
•
Cost Settlement Process
•
RMTS Impact on Reimbursement
•
Important Dates
Overview of Program Changes
Overview of Program Changes
•
In response to CMS questions, West Virginia is implementing a new
reimbursement methodology for school based services, effective July 1,
2012.
•
Effective for dates of service beginning July 1, 2012, school based providers
will be reimbursed using a cost based reimbursement methodology.
•
School based providers will be required to participate in a Random Moment
Time Study and complete an annual cost report as part of the new
methodology.
•
•
School based providers will still need to submit FFS claims for services rendered
throughout the year.
In addition to the changes for the direct services, West Virginia will also be
implementing a Medicaid Administrative Claiming (MAC) program to capture
additional funds for activities performed in support of the Medicaid program.
Medicaid Administrative Claiming (MAC)
Overview
What is the MAC Program?
•
•
The MAC program offers reimbursement for the costs of the administrative
activities, such as outreach, that support the Medicaid program.
The administrative activities fall into several categories:
• Medicaid Outreach;
• Facilitating Medicaid Eligibility Determination;
• Transportation Related to Medicaid Services;
• Translation Related to Medicaid Services;
• Program Planning, Policy Development, and Interagency Coordination
Related to Medicaid Services;
• Medicaid-Related Training;
• Referral, Coordination and Monitoring of Medicaid Services.
MAC Overview
•
LEAs participating in the MAC program are required to submit financial
information on a quarterly basis, which includes:
• Salary and benefit costs for those staff members listed on the Random
Moment Time Study (RMTS)
• Staff that are 100% federally funded should not be included on the RMTS or
within the quarterly financial submission process.
• Costs may be included for Direct Service and Administrative Only cost pools.
• Staff Travel
• Costs for specific staff related travel, examples include: mileage and
conference related travel expenses.
MAC Overview
•
LEAs participating in the MAC program are required to submit financial
information on a quarterly basis, which includes (continued):
• Staff Professional Dues and Fees
• Report by service the total costs for professional dues and fees associated with
the staff listed in the Quarterly Financial Report.
• Materials & Supplies
• Materials & Supplies must be identified as used by the staff for which they are
included:
• Materials & Supplies can be identified using a “reasonable allocation method.”
• Some methods include – headcount or FTE.
Introduction to the Cost Settlement Process
Introduction to the Cost Settlement Process
•
Effective July 1, 2012, WV DHHR/BMS will implement a cost based
reimbursement methodology for school-based service providers.
•
This means that payments received for dates of service on or after July 1,
2012 will be subject to the cost reimbursement methodology.
•
Any payments received for dates of service prior to July 1, 2012 will not be
subject to a cost reimbursement and cost settlement process.
Note: The cost report effective date is DATE OF
SERVICE DRIVEN, not date of payment driven.
Introduction to the Cost Settlement Process
What is cost based reimbursement?
•
•
A cost based reimbursement methodology determines the actual cost of
delivering SBHS medical services to special education students.
Cost based reimbursement ensures that LEAs are reimbursed their costs for
the delivery of medical services and that the Medicaid agency is not
reimbursing providers more than cost.
How will cost based reimbursement impact LEAs?
•
•
In order to identify the costs of delivering Medicaid school-based services,
LEAs will participate in an annual cost settlement process.
The cost settlement process will include the submission of an annual
Medicaid Cost Report.
Introduction to the Cost Settlement Process
So what does the cost settlement process mean for LEAs?
•
LEAs will complete an annual Medicaid cost report.
• The Medicaid cost report calculates the actual costs of providing
Medicaid covered health related services and will be compared to
Medicaid reimbursement received.
Introduction to the Cost Settlement Process
How does the SBHS cost settlement process pertain to the MAC program
and the RMTS?
•
The SBHS cost settlement process directly links to both the MAC quarterly
financial submissions and the RMTS.
• Some cost data may be aggregated by the Medicaid Cost Reporting
and Claiming System (MCRCS) for information submitted quarterly,
which includes:
• Salary and benefit cost data for direct medical service providers.
• The RMTS is used to determine on average how much time direct
medical service providers spend delivering direct medical services.
• This percentage is called the “direct medical percentage” and is
used to calculate direct medical service costs.
Introduction to the Cost Settlement Process
Overview of Medicaid Allowable Costs and Cost Report Data
Elements
•
Medicaid Allowable Costs included in the yearly Medicaid Cost Report must :
• Include costs related to Special Education students;
• Relate to a direct medical service, specifically those included in the
approved State Plan:
•
•
•
•
•
•
•
•
•
Audiology and Speech-Language Therapy Services;
Occupational Therapy;
Physical Therapy;
Psychological Services;
Nursing Services;
Health Needs Assessment and Treatment Planning;
Care Coordination Services;
Personal Care Services; and
Specialized Transportation Services
• Tie back to an individual Special Education student’s IEP.
Introduction to Financial Reporting
15
Introduction to Financial Reporting
Reporting Requirements
• Quarterly Financial Submissions are required for the MAC program.
• The Quarterly Financial Submissions are necessary to calculate
MAC reimbursement.
• The Cost Report must be submitted annually for cost reconciliation
and cost settlement.
• The cost report is the key component in calculating cost
settlement for LEAs.
Introduction to Financial Reporting
The MAC and Cost Settlement calculations require various financial
and statistical data elements, reported quarterly and/or annually.
Data Element
Quarterly
(MAC)
Annually
(Cost Settlement)
Direct Service Salaries
X
X
Direct Service Benefits
X
X
Administrative Salaries
X
Administrative Benefits
X
Transportation Salaries
X
Transportation Benefits
X
Direct Service Contract
X
Administrative Contract
X
17
Introduction to Financial Reporting
The MAC and Cost Settlement calculations require various financial
and statistical data elements, reported quarterly and/or annually.
Data Element
Quarterly
(MAC)
Annually
(Cost Settlement)
Direct Service Materials and Supplies
X
Direct Service Depreciation
X
Administrative Non-Personnel
X
Transportation Non-Personnel
X
Transportation Depreciation
X
Medicaid Eligibility Ratio
X
IEP Ratio
X
One Way Trip Ratio
X
Specialized Vehicle Ratio
X
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Financial Reporting Data Elements
19
Salary Costs
Salary costs for eligible Administrative, Direct Service, and
Transportation staff:
Salaries






Regular wages or extra pay
Paid time off (e.g., sick or annual leave)
Overtime
Bonuses or longevity
Stipends
Cash bonuses and/or cash incentives
Note: Salaries are those payments from which payroll taxes are deducted.
The reported salaries should be the total gross earnings for the
individual as paid by the LEA for the reporting period.
LEAs are required to report gross expenditures and then properly
reduce expenditures for funds paid from other federal funding
sources.
Benefit Costs
Benefit costs for Eligible Administrative, Direct Service, and
Transportation Staff:
Benefits
 Employer-paid health/medical, life, disability, or dental insurance
premiums,
 Employer-paid child day care for children of employees,
 Retirement contributions,
 Worker’s compensation costs
Note: Report the expended amounts paid by the LEA which are directly
associated with each staff member by type of employee benefit.
LEAs are required to report gross expenditures and then properly
reduce expenditures for funds paid from other federal funding
sources.
Salary and Benefit Costs
Direct Service Salaries and Benefits
•
Direct Service salaries and benefits are reported on a quarterly basis for
MAC and annually for cost settlement.
•
Only salary and benefit costs for staff included on the Staff Pool List are
eligible for SBHS cost reimbursement.
Administrative Salaries and Benefits
•
Administrative salaries and benefits are reported on a quarterly basis for
MAC only.
•
Only salary and benefit costs for staff included on the Staff Pool List are
eligible for MAC reimbursement.
Salary and Benefit Costs
Transportation Salaries and Benefits
•
Transportation salaries and benefits are included on the annual cost report.
•
Eligible specialized transportation service providers include:
•
•
•
•
Bus Drivers
Bus Attendants
Mechanics
Substitute Drivers.
•
Transportation providers do not participate in the RMTS.
•
If a provider assists with transportation services in addition to performing a
direct service to special education students in a school setting, their
salaries and benefits should NOT be included under transportation; they
need to participate in the RMTS to be eligible for reimbursement.
Contracted Staff Costs
Contract Costs for Eligible Administrative and Direct Service Staff:
Contracted Staff Costs
 Total Costs of contracts for the applicable contracted staff
Note: The reported costs should be the total costs for the individual as paid
by the LEA for the reporting period. Contracted staff costs include
compensation paid for all services contracted by the LEA for an individual
who delivered any SBHS services to Medicaid and/or non-Medicaid clients.
LEAs are required to report gross expenditures and then properly
reduce expenditures for funds paid from other federal funding
sources.
Contracted Staff Costs
Direct Service Contracted Staff
•
Direct Service contracted staff costs are included on the annual cost report.
•
•
These costs include amounts paid by LEAs to contractors for the provision of direct
medical services.
The only costs that can be submitted are direct costs incurred by the LEA to
purchase services from a non-LEA employed direct medical service provider.
•
These are costs incurred for the benefit of, or directly attributable to, a specific service.
Administrative Contracted Staff
•
Administrative contracted staff are included on the quarterly financial submission
for MAC.
•
•
These costs include amounts paid by LEAs to contractors for the provision of MAC
eligible services.
Admin staff are contracted per service and invoiced accordingly throughout the
school year.
RESAs will need to develop rates for direct service and administrative
staff to be billed to LEAs for direct and administrative services.
Direct Service Materials and Supplies Cost
Direct Medical Service Material and Supply costs
• CMS has approved a very limited list of direct medical service material and
supply costs.
• Only those items included within the approved list can be reported on the
Medicaid cost report.
• Examples include: battery testers, hearing aid stethoscopes, electronic suction
unit, wheelchair, blood glucose meter, etc.
• These costs are only collected and reported annually on the Medicaid cost report.
• Direct Medical Service Material and Supply Costs applicable only to General
Education students should not be reported on the cost report.
Direct Service Depreciation Costs
Depreciation costs for Approved Direct Medical Service Materials
and Supplies
• Allowable depreciation expenses for direct medical services include OMB-A87 allowable methodologies, including pure straight-line depreciation.
• Straight-line depreciation method is a method of calculating the depreciation of
an asset which assumes the asset will lose an equal amount of value each year.
• The annual depreciation is calculated by dividing the purchase price by the
estimated useful life of the asset.
Direct Service Depreciation Costs
Depreciation costs for Approved Direct Medical Service Materials
and Supplies (cont.)
• If a single direct medical service material and supply cost exceeds $5,000,
then the item should be depreciated.
• Only those items included within the approved list can be reported on the
Medicaid cost report.
• These costs are only collected and reported annually on the Medicaid cost
report.
Direct Service Depreciation Costs
Depreciation costs for Approved Direct Medical Service Materials
and Supplies (cont.)
• Example: A wheelchair is purchased by an LEA for $6,000 on July 1, 2012
and has a useful life of 5 years.
• How does the LEA identify what the useful life is of a wheelchair?
• The useful life of a wheelchair is estimated by the LEA.
• The LEA may use industry standards in order to report the useful life
of a wheelchair.
• If the LEA does not have a fixed asset ledger that reports the useful
life of an asset, an LEA may consult the "Estimated Useful Lives of
Depreciable Hospital Assets", published by the American Hospital
Association (AHA).
Direct Service Depreciation Costs
Depreciation costs for Approved Direct Medical Service Materials
and Supplies (cont.)
• Example: A wheelchair is purchased by an LEA for $6,000 on July 1, 2012
and has a useful life of 5 years.
• How does the LEA calculate the depreciation cost of the wheelchair?
• Depreciation cost is calculated by dividing the acquisition cost of
$6,000 by the estimated useful life of 5 years.
• This results in a calculated depreciation cost of $1,200 for state
fiscal year 2013 (July 1, 2012 to June 30, 2013).
Direct Service Depreciation Costs
Depreciation costs for Approved Direct Medical Service Materials
and Supplies (cont.)
• Example: A wheelchair is purchased by an LEA for $6,000 on October 1, 2012
and has a useful life of 5 years.
• How does the LEA calculate the depreciation cost of the wheelchair?
• The Medicaid cost reimbursement and settlement process was
effective July 1, 2012, so this requires the LEA to prorate the expense.
• This is accomplished by dividing the annual allowable expense of
$1,200 by the number of months in the fiscal year or 12 in this
case. $1,200/12 = $100 per month.
• The $100 per month cost is then multiplied by 9, which is the
number of months the wheelchair was in use for the reporting
period (July 1, 2012 to June 30, 2013).
Direct Service Depreciation Costs
Depreciation costs for Approved Direct Medical Service Materials
and Supplies (cont.)
• Example: A wheelchair is purchased by an LEA for $6,000 on October 1,
2012 and has a useful life of 5 years.
• How does the LEA calculate the depreciation cost of the wheelchair?
• Therefore, the final allowable depreciation cost would be $900
in this example ($100 of depreciation cost per month * 9
months = $900).
• For the remaining 4 years of the useful of the wheelchair, the
allowable depreciation cost would be $1,200 per year.
Administrative Non-Personnel Costs
Materials & Supplies
• Materials & Supplies must be identified as used by the staff for which they
are included.
• Materials & Supplies can be identified using a “reasonable allocation
method.”
• Some methods include – headcount or FTE
• Please do not include any other costs used by direct medical service
providers to deliver services to each individual student.
Staff Travel
• Costs for specific staff related to travel for trainings.
• Examples include:
• Mileage to trainings
• Conference related travel expenses
Staff Professional Dues and Fees
• Report by service the total costs for professional dues and fees associated
with the staff listed in the Quarterly Financial Report.
Transportation Non-Personnel Costs
Approved Specialized Transportation Non-Personnel costs
•
CMS has approved a list of specialized transportation non-personnel
costs, including:
•
•
•
•
•
•
•
•
•
Lease or Rental Costs
Insurance Costs
Maintenance and Repair Costs
Fuel and Oil Costs
Major Purchases under $5,000
Contract Costs – for transportation services and transportation equipment
Only those items included within the above categories can be
reported on the Medicaid cost report.
These costs are only collected and reported annually on the Medicaid
cost report.
Costs can be reported as either specialized transportation only or not
specialized transportation only.
34
Transportation Depreciation Costs
Depreciation costs for Approved Specialized Transportation
Non-Personnel Costs
• Depreciation for specialized transportation assets follows a similar
process as that for the depreciation of direct medical service materials
and supplies.
• If a single specialized transportation non-personnel item cost exceeds
$5,000, then the item should be depreciated.
• These costs are only collected and reported annually on the Medicaid
cost report.
• Costs can be reported as specialized transportation only or not
specialized transportation only.
35
Medicaid Eligibility Ratio (MER)
Medicaid Eligibility ratio
•
For many of the MAC activities performed by LEA personnel, the costs
associated with these activities are only reimbursable to the extent they are
allocable to the Medicaid enrolled population.
• These activities will be adjusted by the Medicaid Eligibility Ratio.
•
The MER is calculated as the Total Number of Medicaid students divided by
the Total Number of Students.
MER
Ratio
=
Total Number of Medicaid Eligible Students
Total Number of Students
IEP Ratio
Individualized Education Program (IEP) Ratio
• The IEP ratio is calculated and reported annually on the Medicaid SBHS
Cost Report.
• The IEP Ratio is the total Number of Medicaid Eligible Special Education
Students With a Prescribed Direct Medical Service in their IEP divided by
the Total Number of ALL Special Education Students With a Prescribed
Direct Medical Service in their IEP.
IEP
Ratio
Total Number of Medicaid Eligible Special Education
Students With a Prescribed Direct Medical Service in their
IEP
=
Total Number of ALL Special Education Students
With a Prescribed Direct Medical Service in their
IEP
IEP Ratio
Individualized Education Program (IEP) Ratio
•
The purpose of the IEP ratio is to allocate direct medical service costs to the
Medicaid program.
•
•
In other words, it is used to determine Medicaid’s portion of direct medical service
costs incurred by LEAs for the provision of SBHS direct medical services.
DHHR/BMS and PCG are responsible for calculating the numerator and LEAs
are responsible for reporting the denominator.
•
•
The denominator must reflect the number of children enrolled in Special Education
with a Prescribed Medical Service (billable under the SBHS program) in the IEP.
The denominator must be from the December 1st student count for special
education students that receive medical services each fiscal year.
One Way Trip Ratio
One Way Trip Ratio
• The One Way Trip Ratio is calculated and reported annually on
the Medicaid SBHS Cost Report.
• The One Way Trip Ratio is the total Number of Medicaid One Way
Trips divided by the Total Number of ALL One Way Trips.
• A Medicaid one-way trip is defined as a trip in which a Medicaid enrolled
student who has specialized transportation services in their IEP and
received another Medicaid-covered service provided by the LEA on the
day of the trip. The numerator will be completed by PCG based on paid
claims data.
• The purpose of the One Way Trip ratio is to allocate specialized
transportation costs to the Medicaid program.
• In other words, it is used to determine Medicaid’s portion of specialized
transportation costs incurred by LEAs for the provision of SBHS
specialized transportation services.
39
Specialized Transportation Ratio
Specialized Transportation Vehicle Ratio
• The Specialized Transportation Vehicle ratio is used when a LEA can not
discreetly break out their specialized transportation costs from their
general transportation costs.
• The Specialized Transportation Ratio is the Total Number of Vehicles
used for Special Education Transportation Purposes divided by the Total
Number of ALL Vehicles used for Transportation Purposes.
• The ratio is calculated and reported annually on the Medicaid SBHS Cost
Report.
• The ratio is applied to those costs identified as “not specialized
transportation only”.
40
MAC Calculation Process
MAC Calculation Process
The MAC calculation is completed on a quarterly basis and is not
subject to an annual cost reconciliation and settlement process.
An example of the MAC calculation is shown below:
Calculation
Step
Financial Reporting Element Description
Value
A
MAC Eligible Salary Costs (net of federal funds)
$300,000
B
MAC Eligible Benefit Costs (net of federal funds)
$75,000
C
Contract Costs of Administrative Service Providers (net of
federal funds)
$10,000
D
Administrative Non-Personnel Costs (net of federal funds)
$8,000
E
Total Administrative Service Costs
(net of federal funds)
(Sum of Steps A through D)
$393,000
42
MAC Calculation Process
MAC calculation (Continued):
Calculation
Step
Financial Reporting Element Description
Value
E
Total Administrative Service Costs (net of federal funds)
(Sum of Steps A through D)
$393,000
F
Administrative Service % (from RMTS)
G
Step E times Step F
H
Indirect Cost Rate
I
Step G times Step H
$22,598
J
Medicaid Eligibility Rate
12.00%
K
Step J times Step I
$2,712
J
Net Administrative Claim
(Step K times 50% (FFP Rate))
$1,356
5.00%
$19,650
1.15
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Cost Settlement Process
Cost Settlement Process
Now that we know about the required data elements, how do the
pieces fit together?
Cost Settlement for Direct Services:
Calculation
Step
A
B
Cost Report Element Description
Salary Costs of Direct Service Providers
(net of federal funds)
Calculation
Step
Benefit Costs of Direct
Service Provider
(net of federal funds)
Value
$900,000
$100,000
C
Direct Medical Service Material & Supply Costs
(net of federal funds)
$65,000
D
Direct Medical Service Material & Supply Depreciation Costs (net
of federal funds)
$24,530
E
Total Direct Service Costs
(net of federal funds)
(Sum of Steps A through D)
$1,089,530
Cost Settlement Process
Cost Settlement for Direct Services (Continued):
Calculation
Step
Cost Report Element Description
Value
E
Total Direct Medical Service Costs
(net of federal funds)
F
Direct Medical Service % (from RMTS)
G
Step E time Step F
$708,195
H
Direct Service Contract Costs
(net of federal funds)
$100,000
I
Step G plus Step H
$808,195
J
Indirect Cost Rate
K
Step I times Step J
L
Individualized Education Program (IEP) Ratio
M
Total Direct Services Medicaid Eligible Costs
(Step K times Step L)
$1,089,530
65.00%
1.15
$929,424
50.00%
$464,712
Cost Settlement Process
Cost Settlement for Transportation:
Calculation
Step
Cost Report Element Description
Value
A
Salary Costs of SBHS Specialized Transportation Service
Providers (net of federal funds)
$225,000
B
Benefit Costs of SBHS Direct Specialized Transportation
Providers (net of federal funds)
$65,000
C
Specialized Transportation Non-Personnel Cost (net of
federal funds)
$45,000
D
Special Transportation Non-Personnel Depreciation Cost
(net of federal funds)
$14,000
E
Total Specialized Transportation Service Costs
(net of federal funds)
(Sum of Steps A through D)
$349,000
47
Cost Settlement Process
Cost Settlement for Transportation (Continued):
Calculation
Step
Cost Report Element Description
Value
E
Total Specialized Transportation Service Costs
(net of federal funds)
(Sum of Steps A through D)
$349,000
F
Indirect Cost Rate
G
Step E times Step F
H
Specialized Vehicle Ratio
I
Step G times Step H
J
One Way Trip Ratio
48.00%
K
SBHS Medicaid Eligible Specialized Transportation Cost
(Step I times Step J)
$61,647
1.15
$401,350
32.00%
$128,432
48
Cost Settlement Process
Now that we know how the SBHS Medicaid Direct Medical Service
and Specialized Transportation Costs are calculated, how is the
settlement determined?
Calculation
Step
Cost Report Element Description
Value
A
SBHS Medicaid Eligible Direct Service and
Specialized Transportation Cost
$526,359
B
SBHS Medicaid Interim Payments Received
$395,745
Cost Report
Element #
See Step M for Direct
Service and Step K for
Specialized
Transportation
(Received through traditional billing process)
C
Medicaid Cost Settlement Gross Amount
$130,614
State Share at 27.96%
$36,520
Federal Share at FY 2013 FMAP Rate of
72.04%
$94,094
(Federal Share based on FFP Rates published by the
US Department of Health and Human Services)
D
Payment Due to LEA (Federal Share Only)
$94,094
49
RMTS Impact on Reimbursement
• As was shown through the MAC and Cost Settlement Calculation
Examples, the RMTS plays an integral role in determining a LEAs
final reimbursement.
• When participants do not respond to moments or when responses
are not appropriate, it may have an adverse effect on the
reimbursement of the LEA.
• The example on the following page assumes all non-RMTS factors
remain constant.
• A 15% decrease in the Direct Services Percentage from RMTS results in a
decrease in Direct Medical Services Medicaid Eligible Costs by $93,972 (20%).
Calculation Step
RMTS Impact on Reimbursement
Calculation
Step
Cost Report Element Description
Original
Value
Updated
Value
Variance
E
Total Direct Medical Service Costs
(net of federal funds)
$1,089,530
$1,089,530
$0
F
Direct Medical Service % (from RMTS)
Calculation Step65.00%
50.00%
(15.00%)
G
Step E time Step F
$708,195
$544,765
($163,430)
H
Direct Service Contract Costs
(net of federal funds)
$100,000
$100,000
$0
I
Step G plus Step H
$808,195
$644,765
($163,430)
J
Indirect Cost Rate
1.15
1.15
0
K
Step I times Step J
$929,424
$741,480
($187,944)
L
Individualized Education Program
(IEP) Ratio
50.00%
50.00%
0.00%
M
Total Direct Services Medicaid
Eligible Costs
(Step K times Step L)
$464,712
$370,740
($93,972)
Important Dates
• Official submission of the State Plan scheduled for the end of July.
• State Plan effective July 1, 2012.
• RMTS begins again on October 1, 2012.
• This will be the first quarter used in determining MAC and cost
reimbursement for direct services.
• Quarterly Financial Submissions
• The first quarterly financial submission will be due mid-February.
• Annual Cost Report Submission
• The first annual cost report submission will be due by December 31,
2013.
54
Important Dates -Cost Report Training
Quarterly Financial Submission Training
• October / November 2012
This training will provide:
• A Medicaid Cost Reporting and Claiming System (MCRCS) Demonstration
for quarterly financial submissions.
• In-depth detail on each component of submitting the quarterly financial
submission for MAC in MCRCS.
• Details on the MAC eligible costs to be included in the quarterly financial
submissions.
55
Important Dates -Cost Report Training
Annual Cost Report Submission Training
• Fall 2013
This training will provide:
• Detailed instructions for submitting the Annual Medicaid Cost Report.
• MCRCS demonstration for annual cost report submission.
• Details on eligible costs to be included in the annual cost reports.
56
Contacts
Public Consulting Group
WVSBHS@pcgus.com
1-877-908-1745
Joseph Weber
Katherine Deptula
Lauren Rodrigues
Kenneth Cheung
Leslie Tremberth
Questions?
Public Consulting Group, Inc.
148 State Street, Tenth Floor, Boston, Massachusetts 02109
(617) 426-2026, www.publicconsultinggroup.com
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