Osteopathic Medical Oncology and Hematology, P.C. - Page 5




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          patient visit, petitioner's staff prepares a physician's                    
          statement known as a "charge sheet", which is the document from             
          which petitioner's billing department generates its bills.  The             
          charge sheet specifically lists the type, amount, and cost of               
          chemotherapy and other drugs administered, and the type and cost            
          of all professional services rendered.  The charge sheets are               
          specific as to the particulars of chemotherapy treatments so as             
          to comply with the guidelines of Medicare and the private                   
          insurance industry.  Petitioner submits the charge sheets                   
          directly to Medicare or other responsible party, and petitioner             
          bills its patients for the copayments or other charges not                  
          covered by insurance.                                                       
               Medicare and private insurers analyze on an item-by-item               
          basis whether to reimburse the charges shown on the charge                  
          sheets.  The dollar amount reimbursed for a drug administered to            
          a patient is ascertained by reference to the average wholesale              
          price (AWP) of the units in which the drug is packaged and sold             
          wholesale, which AWP is published annually with quarterly                   
          updates.  Generally, the reimbursement amount for drugs equals              
          the AWP times the units used, with rounding up to the next whole            
          unit of a drug when billing for administration of a partial unit.           
               It is common industry practice to charge for all medical               
          services provided even when the health care provider anticipates            
          it will not be paid in full for all charges.  The standard charge           





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