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policy manuals. Rogers helped develop most, if not all, of
petitioner's policy manuals.
During 1989 and 1990, there was a nursing shortage. Rogers
worked with an advertising firm to develop a recruitment plan to
help petitioner's clients recruit adequate staffs. Rogers
developed the per-visit method of compensation for nurses and
recommended its use to petitioner's clients, which increased the
availability of nurses.
Rogers also suggested developing the Alpha Information
System, a clinical system that provides documentation and
assistance to the clinician providing the services and reduces
paperwork. The use of the Alpha Information System enhances the
quality of patient care by allowing the nurse to spend more time
on patient care and less time on documentation and ensures
accuracy. There were no other computer systems like it in the
home health care industry in 1990. Rogers drew the schematics
about how home health care works for petitioner's computer
programmers, who then developed the system.
Petitioner's clients have to attend Medicare preexit and
exit conferences to determine whether Medicare agrees with the
amounts the clients were reimbursed for. At preexit conferences
Medicare informs the client of proposed adjustments and items
that may be disallowed. At exit conferences, the clients present
explanations for the items Medicare proposed to adjust. If an
item is disallowed, the client has to reimburse Medicare what
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