CMS Issues Final Home Health PPS Rules and Rate for 2016 - 10-30-2015

CMS has rolled full speed ahead ignoring letters from Senators, members of Congress, and others issuing the Final Home Health PPS Rules and Rates for 2016.  CMS estimates that home health payments will be reduced by 1.4% or $260 million.  The changes include the third year 2.4% reduction for rebasing payments, a .97% reduction for case mix creep, and a 1.4 percent inflation increase.  We will have more emails next week on payment rate specifics.

CMS has also finalized the Home Health Value-Based Purchasing Model.  They have reduced the number of process measures from 10 to 6; have 10 outcome measures; 5 HHCAHPS measures, and reduced the number of reporting measures from 4 to 3.  CMS has made some adjustments to the payment amounts by lowering the first year to a plus or minus 3 percent.  The fifth year will be plus or minus 8 percent. 

If your home health agency is located in Arizona, Florida, Iowa, Maryland, Massachusetts, Nebraska, North Carolina, Tennessee, or Washington you will be required to participate in the model beginning on January 1, 2016.  Actually they have already been collecting data for their base year which will be 2015.

If you are located in one of the 9 states listed above you have 63 days to be ready for HHVPM to begin.  We have two timely One Day Seminars that will give you the information you need to prepare for the changes.  They are titled Winning Strategies – Home Health Value Based Payments.  The first seminar will be held in Louisville, KY on November 10^th.  The second seminar will be held in Orlando, FL on November 17^th.  The seminar topics are:

Understanding the Home Health Value-Based Purchasing Model

How to Succeed Under Home Health Value Based Purchasing

Review of Final Home Health Rules and Rates for 2016

SMART Marketing to Grow and Prosper

 We are pleased to offer $100 per person discount off the current rate because of a sponsorship by TurboQuisine.  The discounted rate including the $100 discount is $269 for the first person and $199 for additional people from the same agency.  

We have a Temporary Link to the Final Rule because the final rule will not be published in the Federal Register until November 5^th.

https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-27931.pdf

We developed a free 10 minute video that could help you to solve 5 major issues impacting your home health agency.  We have always tried to have our clients, seminar attendees and friends to learn to think outside the box.  This video really hits on that point.  Watch the video and let us know your opinion.

For more information please use the following link

https://youtu.be/NeU5PPcrqz4

CMS Establishes New G Codes For Home Health and Hospice - 10/21/2015

On October 16, 2015 CMS issued MLN Matters Number MM9369.  It has added two new codes for RN and LVN/LPN visits.  This will retire the HCPCS code G0154 and replace it with new RN Code G0299 and the new LVN/LPN code G0300 for episodes that begin on or after 1/1/2016.  This change is taking place because of the change in the reimbursement payment amount for the Hospice Service Intensity Add-On payment for skilled visits provided by an RN or MSW in the last seven days of a patients life.

For more information please use the following link

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM9369.pdf

Hospice Should Prepare For New Payment Types and Rates Janaury 2016 - 10/8/2015

The payment system will change beginning January 1, 2016.  The National Routine Home Care Rate for days 1 to 60 will be $183.17 and the National Routine Home Care Rate for days 61+ will be $143.94.  Remember that these rates will be adjusted to the wage index based on where the patient resides.  You will also have to bill RN’s separate from LPN/LVN’s and utilize 15 minute billing increments.  We will certainly have more instructions from CMS regarding hospice billing. 

The new payment rules and rate for 2016 defined a hospice episode of care and how that impact the counting of hospice days.  We recommend you work with your software vendors to ensure they can tract your episodes of care correctly, be able to bill the appropriate code and rate beginning January 1, 2016, and be able to bill the Services Intensity Add-on Payment for the last seven days of a patient’s life.

In case you missed the hospice payment rules for FY 2016 we have attached a link below:

http://www.gpo.gov/fdsys/pkg/FR-2015-08-06/pdf/2015-19033.pdf

US Supreme Court Refuses Stay Overtime Rules - 10/7/2015

On October 6, 2015 the United States Supreme Court Chief Justice John Roberts refused to issue a stay of the Department of Labor (DOL) overtime rules that impact home health workers.  It is expected that the new DOL rules will go into effect on October 13^th.

This rule placed restriction by not allowing home health care workers employed by a third party to qualify for the companionship exemption.  This requires home health agencies to pay overtime for all caregivers paid on an hourly basis and who do not quality as exempt salary employees. 

On September 14^th the DOL stated the ruling would go into effect on October 13, 2015.  They also stated that they would exercise prosecutorial discretion in determining whether to bring enforcement actions through December 31, 2015.  This is not a promise by the DOL not to enforce the rules until that date.  The enforcement is up to the DOL based on how the individual companies have made good faith efforts to bring their compensation programs into compliance with the law.

We recommend you immediately plan to comply with the above ruling.  We do not believe you should wait, since failure to comply could place a substantial financial risk on your company. 

OIG Allows Introductory Visits For Home Health - 10/6/2015

An OIG Advisory Opinion Number 15-12 issued on August 6, 2015 a letter to a home health agency approving their request to furnish non-medical introductory visits.  This visit can only be done after the home health agency has been selected by the patient. Per the letter the Introductory Visits is to facilitate the patient’s transition to home health services in an effort to increase compliance with the post-acute treatment plan.

The Introductory visit is performed by a Liaison of the home health agency.  The Liaison would probably be an LPN.  This visit is limited to the following.  (1) Provide an overview of the home health experience. (2) Give the patient written materials that list the contact information for some of the agencies administrative and clinical employees. (3) Shares pictures of members of the agencies care team who will furnish home health services.

The Liaison does not provide any type of diagnostic or therapeutic services reimbursed by Federal health care programs during the the Introductory Visit, and does not leave any other items or materials with the patient.  This is non covered visit for billing Medicare or Medicaid.

For more information:

http://oig.hhs.gov/fraud/docs/advisoryopinions/2015/AdvOpn15-12.pdf

CMS prohibits contractors from adding new denial reasons on first and second level of appeals 9/15/2015

CMS issued MLN Matters SE1521 limited the scope of review on redeterminations and reconsideratons of certain claims. This impacts claims from physicians, providers including home health & hospice, and suppliers who submit claims to Medicare Administrative Contractors (MACs) for services provided to Medicare Beneficiaries.  It has be published by CMS to inform providers of the clarification CMS has given to MACs and Qualified Independent Contractors (QICs) regarding scope of review for redeterminations (Techmical Direction Letter-15407).  This updated instructions applies to redetermination request received by a MAC or QIC on or after August 1, 2015 and will not be applied retroactively.

For redeterminations and reconsiderations of claims denied following a post-payment review or audit, CMS has instructed MACs and QICs to limited their review to the reason(s) the claim or line item at issued was initially denied.  This means they cannot add additional reasons for denial of claims after the initial denial.  This probably means the denial will now include more reasons for the denial, but it appears to be a step in the right direction.

Link:

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1521.pdf

Home Health Value Based Purchasing Model Demonstration Starts January 1, 2016 - 9/3/2015

The Home Health Value Based Purchasing (HHVP) Model Demonstration will begin on January 1, 2016 in nine states.  The state are Massachusetts, Maryland, North Carolina, Florida, Washington, Arizona, Iowa, Nebraska, and Tennessee.  This demonstration will require all Medicare certified home health agencies in those nine states to participate.  Unfortunately agencies in those states are really participating in the program now, because the base year for the HHVP is 2015.  This will be one of the largest changes ever for home health agency Medicare payments.

Medpac the Medicare Payment Advisory Commission issued comments on August 18, 2015 on the HHVP.  Medpac has been historically critical of home health.  They constantly seem to look for deeper cuts in Medicare reimbursement for home health.  This report actually states it believe that CMS has gone too far on the number of measures in the HHVP.  They recommend CMS reduce the number of measures.  They also would like CMS to focus more on actual scores and focus less on improvement.

The final rules are due to be reported by October 31, 2015.  This may have some changes to the HHVP.  This will only provide a 60 day notice to the home health agencies in the nine states that are required to participate in the program.  We have decided to hold two one day seminars titled “Winning Strategies – Home Health Value Based Payments”.  This seminar will be held on November 10^th in Louisville, KY and November 17^th in Orlando, FL.  We will discuss the final rules and their impact on the home health value based purchasing model, How to succeed under HHVP, Review the final home health rules and rates for 2016, and SMART marketing to grow and prosper.  We hope to see you at one of the seminars.

To view the Medpac Report go to:

http://www.medpac.gov/documents/comment-letters/medpac-comment-on-cms's-proposed-rule-on-the-home-health-prospective-payment-system.pdf?sfvrsn=0

CMS Issues Change Request To Implement Hospice Payments For 2016 - 8/28/2015

CMS issued Change Request 9201 to implement the hospice service intensity add-on payment for hospice social worker and nursing visited provided during the last 7 days of life when provided during routine home care.  In addition, this instruction will implement two routine home care rates, paying a higher rate in the first 60 days of a hospice election and a lower rate for days 61 and later.

Link to Change Request 9201

https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R3326CP.pdf

Electronic Physician Face-To-Face Template - 8/27/2015

CMS published notice for public comment on intention to collect electronic physician face-to-face template.  The template is designed to assist physicians in documentation for the face-to-face encounter necessary for Medicare home health certification.  The template use is voluntary.

The template contains some check boxes and blank space for narratives.  CMS claims it will take physicians 10 minutes to compete compared to the normal paperwork of 15 minutes.  Public comments on the proposed rule are due by October 13^th.

CMS failed in the past to train physicians in face-to-face documentation.  We believe the new template will also fail due to lack of training as well as lack of incentives for physicians to complete the documentation.  Oral arguments were heard on August 6^th on the National Associations of Home Care’s lawsuit regarding face-to-face.  We are hopeful of a favarable decision.  We will keep you informed in future emails.

Federal Register Notice

http://www.gpo.gov/fdsys/pkg/FR-2015-08-12/pdf/2015-19818.pdf

Home Health Face-to-Face Encounter Clinical Templates Download ZIP File

https://www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-10564.html

Court of Appeals Agrees with DOL on Overtime Rules for Companion Services 8/26/2015

On August 21^st the US Court of Appeals in the District of Columbia ruled in favor in the Department of Labor in the lawsuit against the Home Care Association of America.  This allows the DOL to reverse the overtime exemptionand  place new rules on overtime for companions.  It also removes people employed by third parties from the overtime exemption.

We expect an appeal to the US Supreme Court, but have not learned of the Home Care Association of America’s position to such an appeal as of today.  We have not learned of the Department of Labors position on when enforcement of the new regulations will begin.  We will keep you updated in future emails.

To view the court decision please go to:

http://www.cadc.uscourts.gov/internet/opinions.nsf/4F1B05FAF98FCC6E85257EA8004E9BD0/$file/15-5018-1569088.pdf

CMS Extends Home Health Moratoria For Additional 6 Month - 8/4/2015

On July 28, 2015 CMS extended the temporary moratoria on enrollement of new  home health agencies, subunits, and branch location within designated metropolitain areas in Florida, Illinois, Michigan, and Texas for an additional 6 months.  Listed below are the counties by state impacted by this extension:

FL – Metro Miami - Monroe, Miami-Dade

IL – Metro Chicago - Cook, DuPage, Kane, Lake, McHenry, Will

MI – Metro Detroit -Macomb, Monroe, Oakland, Washtenaw, Wayne

TX – Metro Dallas – Collin, Dallas, Denton, Ellis, Kaufman, Rockwall, Tarrant

TX – Metro Houston – Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, Waller

To view the notice please utilize this link:

http://www.gpo.gov/fdsys/pkg/FR-2015-07-28/pdf/2015-18327.pdf

CMS Publishes Final Hospice Payment Rules for 2016 - 8/3/2015

On Friday July 31^st CMS published the Final Hospice Payment Rules for 2016. This includes the changes in the routine home care payment rates based on the length of stay.  They have decided to delay the change in payment for the length of stay from October 1, 2015 to January 1, 2016.  Beginning on October 1^st the base National Routine Home Care payment rate will be $161.89.  Remember this will need to be adjusted for case mix and quality data submission. 

Beginning January 1, 2016 the tier payment scenario will begin.  You will have a National Routine Home Care rate of $186.84 for day 1 to day 60.  The National Routine Home Care rate will be $146.83 for days after day 60.  The new Service Intensity Add-on for the last 7 days of a patient life will also begin on January 1, 2016.  In the proposed rules it stated that patients living in nursing facilities or skilled nursing facilities would not be eligible to the Service Intensity Add-on, but that has been dropped in the final rule

Temporary Link to Final Rule

 https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-19033.pdf

Home Health Value-Based Purchasing Model Review - 7/14/2015

I have spent a week reviewing the Home Health Value-Based Purchasing Model to develop my presentation for our Cutting Edge Home Health Leadership Summit in Maui at the Wailea Beach Marriott Resort and Spa on August 12^th to 14^th.  One of the most difficult parts was to change the techno babble into terms we can all understand.  The presentation explains the state selection process, identifies the nine states that have been selected, the Four Quality Measure categories, the Quality Measures that will be used, the point scoring methodology, and how the scoring will impact home health payments of the agencies selected to participate in the model.  Remember if you are in one of the nine states selected you will required to participate in the demonstration beginning on January 1, 2016.

These are the proposed rules, but I do not expect any major changes in the final rule.  If you are in one of the nine states chosen you are already involved in the demonstration because FY 2015 is the base year for the model.  I recommend you to learn as much about the Home Health Value-Based Purchasing Model as possible.  Even if your state has not been chosen you should know how the model impact home health, because it probably will be the basis for all future home health payments.

We will discuss the Home Health Value-Based Purchasing Model and the Proposed Home Health PPS Rules & Rates for 2016 in detail in two of our sessions at our Cutting Edge Home Health Leadership Summit that will be held at the Wailea Beach Marriott Resort and Spa on August 12^th to 14^th.   We have spoken to the hotel and extended the cutoff for reservation to July 16^th.  This will be the last extension given by the hotel.  Reservations made after this date will be based on hotel availability any could be at a higher rate.  To help home health agencies with the cost of registration we will extend the $1,099 for the first person and $949 for additional person’s registration until July 16^th.   We highly recommend you attend this seminar.  It will give you an opportunity to prepare for the drastic changes that will occur for the home health industry.

To view the rule please go to:

 http://www.gpo.gov/fdsys/pkg/FR-2015-07-10/pdf/2015-16790.pdf

Proposed Home Health LUPA Payment Rates 2016 - 7/10/215

Home Health episodes that have four or less visits are paid a LUPA rate instead of an episode rate.  Listed below are the National LUPA Payment Rates.  Remember these rates will be adjusted for each home health agencies wage index.

Listed below are the LUPA Payment Rates Per Discipline

Discipline	Urban Agencies Submitting Quality Data	Urban Agencies Not Submitted Quality Data
SN	$134.90	$132.26
PT	$147.47	$144.59
OT	$148.47	$145.57
SP	$160.27	$157.14
MSW	$216.23	$212.01
HHA	$61.09	$59.89

Discipline	Rural Agencies Submitting Quality Data	Rural Agencies Not Submitted Quality Data
SN	$138.95	$136.26
PT	$151.89	$148.93
OT	$152.92	$149.94
SP	$165.08	$161.85
MSW	$222.72	$218.37
HHA	$62.92	$61.69

LUPA Episodes are paid a higher rate for the first visit of the episode.  Listed below are the payment rates for the first visit of LUPA episodes

Discipline	Urban Agencies Submitting Quality Data	Urban Agencies Not Submitted Quality Data
SN	$248.90	$244.03
PT	$246.27	$241.47
SP	$260.70	$255.60

Discipline	Rural Agencies Submitting Quality Data	Rural Agencies Not Submitted Quality Data
SN	$256.38	$251.41
PT	$253.66	$248.71
SP	$268.52	$263.27

We will discuss the Proposed Home Health PPS Rules and Rates and the Home Health Value-Based Purchasing Model  in detail in two of our sessions at our Cutting Edge Home Health Leadership Summit that will be held at the Wailea Beach Marriott Resort and Spa on August 12^th to 14^th.   We have spoken to the hotel and extended the cutoff for reservation to July 9^th.  This will be the last extension given by the hotel.  Reservations made after this date will be based on hotel availability any could be at a higher rate.  To help home health agencies with the cost of registration we will extend the $1,099 for the first person and $949 for additional person’s registration until July 9^th.   We highly recommend you attend this seminar.  It will give you an opportunity to prepare for the drastic changes that will occur for the home health industry.

To view the rule please go to:

http://www.gpo.gov/fdsys/pkg/FR-2015-07-10/pdf/2015-16790.pdf

  

Home Health Value-Based Purchasing Demonstration - 7/8/2015

CMS has proposed to begin the Home Health Value-Based Purchasing Demonstration on January 1^st 2016 for all home health agencies in the nine states they have selected.  They divided the 50 states into nine groups.

Group 1 – VT, MA, ME, CT, RI, NH

Group 2 – DE, NC, MD, PA, NY

Group 3 – AL, GA, SC, NC, VA

Group 4 - TX, FL, OK, LA, MS

Group 5 – WA, OR, AK, HI, WY, ID

Group 6 – NM, CA, NV, UT, CO, AZ

Group 7 – ND, SD, MT, WI, MN, IA

Group 8 - OH, WV, IN, MO, NE, KS

Group 9 – IL, KY, AR, MI, TN

They have selected one state from each of the nine groups

Group 1 – Massachusetts

Group 2 – Maryland

Group 3 – North Carolina

Group 4 - Florida

Group 5 – Washington

Group 6 – Arizona

Group 7 – Iowa

Group 8 - Nebraska

Group 9 – Tennessee

CMS will use OASIS data, HHCHAPS data, paid claims data, and four new data elements for scoring.  Each state will be divided into large providers and small providers and their score will compared to their group for their state.  January 1, 2015 to December 31, 2015 will serve as the base year for the providers. 

Scores	Impacts Payment Rates	Impact
1/1/16 to 12/31/16	1/1/18 to 12/31/18	+ or –  5%
1/1/17 to 12/31/17	1/1/19 to 12/31/19	+ or –  5%
1/1/18 to 12/31/18	1/1/20 to 12/31/20	+ or –  6%
1/1/19 to 12/31/19	1/1/21 to 12/31/21	+ or –  8%
1/1/20 to 12/31/20	1/1/22 to 12/31/12	+ or –  8%

Over half of the Proposed Home Health PPS Rules & Rates section related to the New Home Health Value-Based Purchasing Model.  There are numerous rules, regulations, and tables for this section.  Most of us have heard that something is so complicated that it takes a Philadelphia lawyer to explain it to us.  Well these rules will take that lawyer, a statistician, a home health nurse, an accountant and a home health coder to fully explain.  I encourage all of you to read this proposed rule very carefully even if you are not located in one of the chosen states.

We will discuss the Home Health Value-Based Purchasing Model and the Proposed Home Health PPS Rules and Rates in detail in two of our sessions at our Cutting Edge Home Health Leadership Summit that will be held at the Wailea Beach Marriott Resort and Spa on August 12^th to 14^th.   We have spoken to the hotel and extended the cutoff for reservation to July 9^th.  This will be the last extension given by the hotel.  Reservations made after this date will be based on hotel availability any could be at a higher rate.  To help home health agencies with the cost of registration we will extend the $1,099 for the first person and $949 for additional person’s registration until July 9^th.   We highly recommend you attend this seminar.  It will give you an opportunity to prepare for the drastic changes that will occur for the home health industry.

To view the draft form of the rule please go to:

https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-16790.pdf

The rule will be published in the Federal Register on July 10^th.  At that time you will need a new link which we will publish in a future email alert.

Proposed Home Health PPS Rules & Rates for 2016 - 7/7/2015

CMS has issued the Proposed Home Health PPS Rules & Rates for 2016 late Monday July 6^th.  This is the first of several email alerts that we will publish this week on the information contained in the proposed rules & rates for 2016.  Listed below are the factors used to create the 2016 National Standardized 60-Day Episode Payment Rate.

2015 National Base Rate                                                     $2,961.38

Wage Index Budget Neutrality Factor           (Times)      1.0006

Case-Mix Weights Budget Neutrality Factor (Times)      1.0141
Nominal Case-Mix Growth Adjustment      (Times)       0.9828

2016 Rebasing Adjustment                               (Minus)    ($80.95)

Inflation Update 2016                                         (Times)       1.0230

2016 National Standardized 60-Day Episode Rate   $2,938.37

The above rate is the national standardized 60-day episode payment rate.  This rate will be increased by 3% for home health agency patients in rural areas.  This rate will be reduced by 2% for home health agencies that did not submit quality data.  CMS has fully implemented the 2^nd year phase in of the wage index, which must be applied to the labor portion of the national rate.  CMS reduced the case-mix rates by 1.0141%.  They have made some changes to the case-mix point system.  All of the above will impact the actual payment for an individual Medicare Beneficiary Home Health Claim.   CMS also adjusted the LUPA payment rates and the Medical Supply payment rates.  We will discuss more on the Medicare home health payment rates in future email alerts.

CMS has issued proposed rules for the Home Health Value-Based Purchasing Model.  They have divided the 50 states into nine geographic groups.  They have selected nine states to participate in the Home Health Value-Based Purchasing Model Demonstration Program.  Every home health agency in the state chosen must participate, you do not have a choice.  The nine states chosen are Massachusetts, Maryland, North Carolina, Florida, Washington, Arizona, Iowa, Nebraska, and Tennessee.  (The states could change when they publish the final rule, but we do not believe they will make any changes.)  We will discuss more on the Home Health Value-Based Purchasing Model in future email alerts.

We will discuss this proposed rule in detail in our Home Health Update session and have another session on the Home Health Value-Based Purchasing Model at the Cutting Edge Home Health Leadership Summit that will be held at the Wailea Beach Marriott Resort and Spa on August 12^th to 14^th.   We have spoken to the hotel and extended the cutoff for reservation to July 9^th.  This will be the last extension given by the hotel.  Reservations made after this date will be based on hotel availability any could be at a higher rate.  To help home health agencies with the cost of registration we will extend the $1,099 for the first person and $949 for additional person’s registration until July 9^th.   We highly recommend you attend this seminar.  It will give you an opportunity to prepare for the drastic changes that will occur for the home health industry.

To view the draft form of the rule please go to:

https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-16790.pdf

Proposed Home Health Episode Payment Rates 2016 - 7/9/2015

Listed below are the National Standardized 60-Day Episode Payment Amounts.  Remember these rates will be adjusted for each home health agencies wage index and the individual Medicare patients case mix.

Urban Agencies that submit quality data - $2,938.37

Urban Agencies that do not submit quality data - $2.880.92

Rural Agencies that submit quality data - $3,026.52

Rural Agencies that do not submit quality data - $2,967.35

Listed below are Non Routine Supply Payment Rates by Severity Level

Severity Level	Urban Agencies Submitting Quality Data	Urban Agencies Not Submitted Quality Data
1	$14.28	$14.00
2	$51.55	$50.54
3	$141.36	$138.58
4	$210.02	$205.89
5	$323.86	$317.50
6	$557.00	$546.06

Severity Level	Rural Agencies Submitting Quality Data	Rural Agencies Not Submitted Quality Data
1	$14.71	$14.42
2	$53.10	$52.06
3	$145.61	$142.75
4	$216.33	$212.08
5	$333.59	$327.04
6	$573.74	$562.48

We will discuss the Proposed Home Health PPS Rules and Rates and the Home Health Value-Based Purchasing Model  in detail in two of our sessions at our Cutting Edge Home Health Leadership Summit that will be held at the Wailea Beach Marriott Resort and Spa on August 12^th to 14^th.   We have spoken to the hotel and extended the cutoff for reservation to July 9^th.  This will be the last extension given by the hotel.  Reservations made after this date will be based on hotel availability any could be at a higher rate.  To help home health agencies with the cost of registration we will extend the $1,099 for the first person and $949 for additional person’s registration until July 9^th.   We highly recommend you attend this seminar.  It will give you an opportunity to prepare for the drastic changes that will occur for the home health industry.

To view the draft form of the rule please go to:

https://s3.amazonaws.com/public-inspection.federalregister.gov/2015-16790.pdf

The rule will be published in the Federal Register on July 10^th.  At that time you will need a new link which we will publish in a future email alert.