THE WELCH COMPANY
440 Davis Court #1602
San Francisco, CA 94111-2496
415 781 5700
rodwelch@pacbell.net
S U M M A R Y
DIARY: October 9, 2007 02:27 PM .......;
Rod Welch
Jullin called to advise CMS reviewing Kaiser's right to make referrals.
1...Summary/Objective
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CONTACTS
SUBJECTS
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0403 -
0403 - ..
0404 - Summary/Objective
0405 -
040501 - Follow up ref SDS 6 0000, ref SDS 4 0000.
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040507 - ..
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0407 -
0408 - Progress
0409 -
040901 - Jullin called to follow up her call last week on 071003. ref SDS 3
040902 - BZ40
040904 - ..
040905 - Jullin advised that she received the letter to Lee requesting advice
040906 - from CMS on clinical trials, which was submitted on 071002.
040907 - ref SDS 2 KA5J She printed the letter and about 50 pages of
040908 - references that explain Kaiser has applied CMS guidance on Medicare
040909 - law incorrectly to avoid payment for Millie's care. ref SDS 2 OY4Q
040911 - ..
040912 - On 071006 Paula reported that Kaiser received from CMS the letter to
040913 - CMS on 071002. ref SDS 5 Z87L Today, Jullin did not report having
040914 - sent the letter on 071002 to Paula at Kaiser.
040915 -
040916 - [On 071010 Millie received a letter from Paula dated 071006
040917 - saying Kaiser's MCRC unit received a "request" from Millie
040918 - dated 071001 to appeal a Kaiser determination on a Kaiser
040919 - determination of insurance coverage for treatment at UCSF,
040920 - ref SDS 7 TH8L; since Millie has not submitted a request nor
040921 - any document to Kaiser dated 071001, the inference is that
040922 - Kaiser received from CMS the letter to CMS on 071002 and
040923 - executed on its own Kaiser processes to construct a claim on
040924 - Millie's behalf. ref SDS 7 O94J
040926 - ..
040927 - Jullin indicated her CMS office has been assuming Senior Advantage
040928 - patients can only self-refer. CMS interprets Medicare law to bar
040929 - doctors from prescribing treatment patients need in clinical trials,
040930 - and making referrals, which Kaiser's Senior Advantage EOC section 2
040931 - says doctors must perform, reviewed on 070927. ref SDS 1 WU6M Jullin
040932 - has submitted this question to CMS research department, as set out in
040933 - the letter to CMS on 071002. ref SDS 2 OY4Q
040934 -
040935 - [On 071012 research on clinical trial legal authority.
040936 - ref SDS 8 VV5M
040938 - ..
040939 - [On 071029 called Jullin for progress on CMS research begun
040940 - on 071009. ref SDS 9 FR4Y
040942 - ..
040943 - [On 071029 Jullin advised CMS preparing written response to
040944 - letter to CMS dated 071002 on statutory autority for payment
040945 - responsibility when patient self-refers for treatment in a
040946 - clinical trial, and distinguished from when the doctor
040947 - prescribes treatment in a clinical trial. ref SDS 9 WP7O
040949 - ..
040950 - [On 071030 Paula confirmed that the date of 071001 in Kaiser's
040951 - letter dated 071006 and received on 071010 was mistake, since
040952 - Kauser framed an appeal for Millie based on the letter to CMS
040953 - dated 071002 which CMS sent to Kaiser. ref SDS 10 V26V
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