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Compliance News

 2010

Federal Register’s Financial Conflict of Interest Notice of Proposed Rule Making

The Department of Health and Human Services (HHS or the Department) and the HHS Public Health Service (PHS), proposes to amend its regulations on the Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought and Responsible Prospective Contractors. Since the promulgation ofthe regulations in 1995, biomedical and behavioral research and the resulting interactions among Government, research institutions, and the private sector have become increasingly complex. This complexity, as well as a need to strengthen accountability, have led to the proposal of amendments that would expand and add transparency to investigator disclosure of significant financial interests, enhance regulatory compliance and effective institutional oversight and management of investigators’ financial conflicts of interests, as well as NIH’s compliance oversight. Click here for more


Interview with James G. Sheehan, New York State Medicaid Inspector General

Introduction by Health Care Compliance Association CEO Roy Snell:

The Board's role in regulatory and compliance oversight is coming under scrutiny more than any other time in our history. This role is important and can't be taken lightly. It weighs heavily on the minds of countless Board members. Many Board members are looking for guidance on how to fulfill this obligation and to do so efficiently. James G. Sheehan is one of the most knowledgeable leaders in this field. In the following interview, Jim shares his thoughts and ideas regarding the Board's role in the oversight of compliance programs. For more click here


Obama Administrations Healthcare Fraud Summit Webcast

Attorney General Eric Holder and Secretary Kathleen Sebelius, Secretary of the Department of Health and Human Services

Video requires Real Media

Webcast of Morning Session
Webcast of Evening Session


[Federal Register: January 21, 2010 (Volume 75, Number 13)]
[Notices]              
[Page 3525-3539]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr21ja10-106]  

UNITED STATES SENTENCING COMMISSION
 
Sentencing Guidelines for United States Courts

AGENCY: United States Sentencing Commission.

ACTION: Notice of proposed amendments to sentencing guidelines, policy statements, and commentary. Request for public comment, including public comment regarding retroactive application of any of the proposed amendments. Notice of public hearing.

Click here for more

 2009

CMS Medicare Learning Network - Guidance on Using Internet-based Provider Enrollment, Chain and Ownership System (PECOS)

Click here


HHS Rescinds Medicaid Regulations

HHS Secretary Kathleen Sebelius today announced that the administration will rescind all or part of three Medicaid regulations that were previously issued and delay the enforcement of a fourth regulation. 

for more click here               Click here for HHS press release


Combating Fraud, Waste, and Abuse in Medicare and Medicaid

Testimony of:
Daniel R. Levinson, Inspector General, Office of Inspector General,
U.S. Department of Health and Human Services
to the US Senate Special Committee on Aging
May 6, 2009

Click here


Testimony on Capitol Hill Supports Compliance Programs

On April 22, 2009, Lewis Morris, Chief Counsel, Office of Inspector General
Department of Health and Human Services and New York State Medicaid Inspector General James G. Sheehan each promoted the use of compliance programs as a means to thwart waste, fraud and abuse in Federal Health Care Programs during testimony before the Senate Subcommittee on Federal Financial Management, Government Information, Federal Services, and International Security.

While outlining ways in which the government could effectively combat fraud, waste and abuse in Federal health care programs, Morris stated “Requiring health care providers and suppliers to incorporate integrity safeguards and tools into their organizations is an essential component of a comprehensive antifraud strategy.  In many sectors of the health care industry, such as hospitals, compliance programs are widespread and often very sophisticated; other sectors have been slower to adopt internal compliance practices.  Compliance programs benefit industry stakeholders by improving their business practices, by fostering early detection and correction of emerging problems, and by reducing the risk that they will become the subject of a fraud prosecution.”  For Mr. Morris’ complete testimony click here

Specifically recommending compliance programs as an effective means to combat health care fraud, New York State Medicaid Inspector General James G. Sheehan stated “We need to move to a system which makes program integrity a major goal of oversight, investigative, and prosecutive efforts.
 
“First, require and support effective corporate compliance programs and professional compliance officers.  New York requires by law that larger providers have an effective compliance program, with eight elements.  The Medicare program suggests model compliance programs.  We want health care providers to identify and resolve issues themselves; the best already do.” For Mr. Sheehan’s complete testimony, click here


  Inspector General's "Open Letter to Health Care Providers"
Announced March 24, 2009

On March 24, 2009 the U.S. Department of Health and Human Services Office of Inspector General (OIG) released an Open Letter refining the OIG’s Self-Disclosure Protocol. Click here for the letter.  Click here for a summary

 2008

New ‘Red Flag’ Requirements for Financial Institutions and Creditors Will Help Fight Identity Theft

Identity thieves use people’s personally identifying information to open new accounts and misuse existing accounts, creating havoc for consumers and businesses. Financial institutions and creditors soon will be required to implement a program to detect, prevent, and mitigate instances of identity theft.  Click here for more


   Fact Sheet: Department of Justice Efforts to Combat Health Care Fraud and Abuse

WASHINGTON, May 28 /PRNewswire-USNewswire/ -- The Department of Justice, in cooperation with the Department of Health and Human Services, has guided the enforcement efforts of the national Health Care Fraud and Abuse Control Program (HCFAC) since its inception in 1997. The program was designed to coordinate federal, state and local law enforcement on cases of health care fraud and abuse as part of the Health Insurance Portability and Accountability Act (HIPAA). Today, the Department's efforts to investigate and prosecute the individuals and companies who commit health care fraud are as strong as ever, thanks in large part to the Department's many components working closely with partners at the Department of Health and Human Services, and state and local law enforcement.

Click here for more


CMS Announces Demo to Encourage Greater Collaboration and Improve Quality

The Centers for Medicare & Medicaid Services (CMS) announced on May 16, 2008 a new demonstration for hospitals to test the use of a bundled payment for both hospital and physician services for a select set of episodes of care to improve the quality of care delivered through Medicare fee-for-service. For more:
http://www.hcca-info.org/Content/NavigationMenu/ComplianceResources/
ComplianceNews/CMS_DemoEncourageCollaborationQualityBundledHospitalPayments.pdf


2008-2009 Office of Medicaid Inspector General Work Plan

New York State Office of the Medicaid Inspector General, SFY 2008-2009 OMIG Medicaid Work Plan. Click here for more


An Open Letter to Health Care Providers, April 15, 2008

from Daniel R. Levinson, Inspector General

Since the inception ofthe Office ofInspector General (DIG) Provider Self-Disclosure Protocol (SDP) in 1998, DIG has encouraged the health care provider community to help ensure the integrity ofthe Federal health care programs by voluntarily disclosing self-discovered evidence ofpotential fraud. In this spirit of collaboration, we have responded to the provider community's suggestions in the past for ways to improve the SDP. In my 2006 Dpen Letter, for example, I encouraged providers to disclose improper arrangements under the physician self-referral (Stark) law (42 U.S.C. § 1395nn) and committed to settling liability under DIG's authorities generally for an amount near the lower end of the damages continuum, i.e., a multiplier ofthe value of the fmancial benefit conferred.

Click here for more


“Driving for Quality in Long-Term Care: A Board of Directors Dashboard”

Government-Industry Roundtable

A Report on the Office of Inspector General and Health Care Compliance Association Roundtable on Long-Term Care Board of Directors’ Oversight of Quality of Care


Survey Results: Top Risk Areas in Research Compliance

Research Billing, Effort Reporting, and Conflicts of Interest topped the list of Risk Areas identified by Health Care Compliance Association Research Compliance Conference attendees. The survey was conducted by HCCA following the conference with approximately 85 responses. For more, click here (PDF).

 2007

OIG Work Plan for FY 2008

On September 25, the U.S. Department of Health and Human Services Office of Inspector General released its Work Plan for Fiscal Year 2008


Department Of Justice Files Complaint Against Ex-Tenet General Counsel

On September 18, 2007, the government announced it had filed a complaint alleging that the former general counsel of Tenet Healthcare Corporation violated the False Claims Act, the Justice Department announced today.  The suit contends that in 1997 and 1998, Christi Sulzbach submitted false certifications to the Department of Health and Human Services which allowed Tenet to bill Medicare for millions of dollars in claims that it was not entitled to receive.  click here for the complaint.


August 21, 2007 – CMS Announces Start of Participant Recruitment for Post Acute Care Payment Reform Demonstration

The Centers for Medicare & Medicaid Services (CMS) announced the start of participant recruitment for the Post Acute Care Payment Reform Demonstration (PAC-PRD). Participating providers include acute care hospitals and four post-acute care (PAC) settings -- Long Term Care Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Skilled Nursing Facilities (SNFs), and Home Health Agencies (HHAs). Click here for more 


August 1, 2007 – CMS: Payment Reforms for Inpatient Hospital Services in 2008

The Centers for Medicare & Medicaid Services (CMS) today issued a final rule that takes significant steps toimprove the accuracy of Medicare’s payment under the acute care hospital inpatient prospective payment system (IPPS),while providing additional incentives for hospitals to engage in quality improvement efforts…….The rule implements a provision of the Deficit Reduction Act of 2005 (DRA) that takes the first steps toward preventing Medicarefrom giving hospitals higher payment for the additional costs of treating a patient who acquires a condition (including an infection) during a hospital stay.Already the feature of many state health care programs, the DRA requires hospitals to begin reporting secondary diagnosesthat are present on the admission of patients, beginning with discharges on or after October 1, 2007. Beginning in FY 2009, caseswith these conditions would not be paid at a higher rate unless they were present on admission. In order to improve the reliability of care inthe nation’s hospitals, the rule identifies eight conditions, including three serious preventable events (sometimes called “never events”) that meet the statutory criteria.CMS will work to add an additional 3 conditions to the list next year.

To read more on this rule issued please click this URL for the IPPS regulation:

http://www.cms.hhs.gov/AcuteInpatientPPS/Downloads/CMS-1533-FC%20TABLE.pdf 


July 31, 2007 – CMS Increases Payments to Inpatient Rehabilitation Facilities for FY 2008

Inpatient rehabilitation facilities (IRFs) will receive approximately $6.4 billion in payments from Medicare in fiscal year (FY) 2008, under a rule announced today by the Centers for Medicare & Medicaid Services (CMS). The rule will update payment rates and modify payment policies for services furnished to Medicare beneficiaries for discharges occurring on or after October 1, 2007, through September 30, 2008. The rule's provisions are estimated to increase Medicare payments to approximately 1,220 IRFs in FY 2008 by approximately $150 million. For more information please refer to the CMS IRF PPS web site which is http://www.cms.hhs.gov/InpatientRehabFacPPS/.


July 19, 2007 – CMS Announces New Proposed Clinical Research Policy The Centers for Medicare & Medicaid Services (CMS) announced today the reopening of its clinical trial policy (CTP) national coverage determination (NCD) and is releasing a proposed decision memorandum for public comment.  The public comment period will last for 30 days and a final decision will be released 60 days after that. Click here for more

Details of the proposed coverage policy are available at the CMS coverage website at http://www.cms.hhs.gov/mcd/viewdraftdecisionmemo.asp?id=210.


July 16, 2007 - CMS REVISES PAYMENT STRUCTURE FOR AMBULATORY SURGICAL CENTERS AND PROPOSES POLICY AND PAYMENT CHANGES FOR HOSPITAL OPPS

The Centers for Medicare & Medicaid Services (CMS) today issued a final rule revising the payment system for services furnished to people with Medicare in ambulatory surgical centers (ASCs) to better align payments for similar services furnished in a hospital outpatient department (HOPD) or a physician’s office.  CMS also issued a proposed rule that would update Medicare payment for services in HOPDs under the Outpatient Prospective Payment System (OPPS) and would set new payment rates for ASCs under the revised system effective for services in calendar year (CY) 2008. Click here for more.

For the text of the ASC final revised payment system rule see http://www.cms.hhs.gov/ASCPayment/

For the text of the combined OPPS/ASC proposed rule, see:

            http://www.cms.hhs.gov/HospitalOutpatientPPS/HORD/list.asp


OIG: Fiscal Year 2006 Annual Report of the State Medicaid Fraud Control Units (MFCU)


June 2007 - Corporate Responsibility and Health Care Quality:
Resource for Health Care Boards of Directors
Click here

MEDICAID INTEGRITY PROGRAM

As presented by
Kimberly Brandt
Director
Program Integrity Group
Centers for Medicare and Medicaid Services
at the 2007 Compliance Institute, April 24, 2007

The Future of Medicaid Regulation and Enforcement

Kimberly Brandt, Director of Program Integrity, CMS
Brian Flood, Inspector General, Texas HHSC
Frank Sheeder, Partner, Jones Day

Lunch presentation Tuesday April 24, 2007 Compliance Institute.


March 2007 - CMS provided additional guidance to State Medicaid Directors on the "Employee Education" provisions found in Section 6032 of the Deficit Reduction Act of 2005(DRA). Section 6032 of the DRA requires entities that receive $5 million or more in Medicaid funds per year to have and disseminate certain policies and information to their employees, contractors, and agents. The guidance is effective immediately and covers 71 separate questions.  This is the guidance that States will use as they impose requirements on providers.  CMS also provided a summary of the Federal False Claims Act prepared by the Department of Justice.

 2006

OIG Reports More Than $38 Billion in Savings and Recoveries for FY 2006: 
Press Release


OIG Work Plan for FY 2007

On September 25, the U.S. Department of Health and Human Services Office of Inspector General released its Work Plan for Fiscal Year 2007


Essential links to

August 23, 2006 -Proposed Rule - Hospital Outpatient Prospective Payment System

Federal Register
Vol. 71, No. 163
Wednesday, August 23, 2006
Hospital Outpatient Prospective Payment System and CY 2007 Payment Rates; CY 2007 Update to the Ambulatory Surgical Center Covered Procedures List; Ambulatory Surgical Center Payment System and CY 2008 Payment Rates; Medicare Administrative Contractors; and Reporting Hospital Quality Data for FY 2008 Inpatient Prospective Payment System Annual Payment Update Program--HCAHPS[supreg] Survey,SCIP, and Mortality

Centers for Medicare and Medicaid Services – Hospital Outpatient PPS:Hospital Outpatient PPS Overview links: http://www.cms.hhs.gov/HospitalOutpatientPPS/01_overview.asp

Hospital Outpatient Regulations and Notices http://www.cms.hhs.gov/HospitalOutpatientPPS/HORD/list.asp#TopOfPage

Regulation No. CMS-1506-P
Title Proposed Changes to the Hospital Outpatient PPS and CY 2007 Rates;
Year 2007

Medicare Program: Proposed Changes to the Hospital Outpatient PPS (OPPS) and CY 2007 Rates; Proposed CY 2007 Update to the ASC Covered Procedures List; and Proposed Changes to the ASC Payment System and CY 2008 Payment Rates

http://www.cms.hhs.gov/HospitalOutpatientPPS/HORD/itemdetail.asp?filterType=none&filterByDID=-99&sortByDID=3&sortOrder=descending&itemID=CMS1185569

Draft AHA/AHIMA Guidelines with Suggested CMS Revisions


June 2006 - The Government Accountability Office report on a year-long study of not-for-profit health systems’ compensation, benefits and governance

Click here for report


MEDICARE NEWS

FOR IMMEDIATE RELEASE                          
CMS Office of External Affairs
April 12, 2006                                                             

CMS PROPOSES PAYMENT AND POLICY CHANGES FOR ACUTE CARE HOSPITAL SERVICES TO INPATIENTS

The Centers for Medicare & Medicaid Services (CMS) today issued a notice of proposed rulemaking that would begin the transition to the first significant revision of the Inpatient Prospective Payment System (IPPS) since its implementation in 1983.  When fully implemented, which is planned to occur by fiscal year (FY) 2008 and potentially earlier, the revised IPPS would improve the accuracy of payment rates for inpatient stays by basing the weights assigned to Diagnosis Related Groups (DRGs) on hospital costs rather than charges, and adjusting the DRGs for patient severity.

The estimated market basket increase of 3.4 percent in FY 2007 would increase payments to acute care hospitals by $3.3 billion.  Over 1000 hospitals in rural areas would see an average increase of 6.7 percent.

 “The hospital payment reforms we are proposing today will mean payments for hospital inpatient services will more accurately reflect the costs of providing the services,said CMS Administrator Mark B. McClellan, M.D., Ph.D. We are taking important steps to make payments fairer to hospitals and to assure beneficiary access to services in the most appropriate setting.

“This proposed rule will be shaped by the public comment process,” Dr. McClellan added. “We look forward to comprehensive feedback from hospitals, suppliers, and other stakeholders that will help to refine and improve the final version of the rule.”

The proposed changes reflect recommendations from the Medicare Payment Advisory Commission (MedPAC), and respond to some Congressional concerns that the existing system may create incentives for certain hospitals to “cherry-pick” more profitable cases.  The reforms will significantly affect payments to specialty hospitals – hospitals that typically are owned, in whole or in significant part, by physicians who serve as referral sources.  The growth in specialty hospitals has been slowed temporarily by statute or regulation since the Medicare Modernization Act was signed in December 2003.

CMS is considering a two-step process of transformation.  The first step, set out in the proposed rule, would assign weights to DRGs based on hospital costs, rather than hospital charges.  This would eliminate biases in the current DRG system arising from the differential markup hospitals assign for ancillary services among the DRGs.  The new DRG weights would go into effect October 1, 2006.

A second step, currently scheduled for FY 2008, would replace the current 526 DRGs with either the proposed 861 consolidated severity-adjusted DRGs or an alternative severity adjusted DRG system developed in response to the public comments CMS is soliciting on this issue. CMS is also considering ways of improving recognition of severity in the current DRG system by FY 2007.  When the two steps are fully implemented, hospitals can expect more accurate payment for their services.

CMS is proposing to increase the outlier threshold for FY 2007 to $25,530, up from $23,600 in 2006.  This proposed increase is based on data suggesting a consistent pattern of inflation in hospital charges which affect hospital cost-to-charge ratios used in determining eligibility for outlier payment.  The proposed FY 2007 threshold is expected to keep aggregate hospital outlier payments within the target of 5.1 percent of total payments under the IPPS.

In addition to accurate payment for existing technologies, CMS is committed to ensuring that Medicare beneficiaries have rapid access to new technologies by providing for temporary add-on payments for appropriate technologies.  In order to be eligible for additional reimbursement, a product must be:

  1. New – that is, less than two to three years old;
  2. Expensive – that is, it must meet a defined cost threshold in relation to the underlying DRG; and
  3. A substantial clinical improvement for the Medicare patient population.

CMS has received three applications for new technology add-on payments in FY 2007.  CMS is soliciting comments on whether these technologies meet the criteria for the temporary add-on payments.  CMS is also proposing to continue new technology payments for two of the three technologies that were approved for payment in FY 2006.

The proposed rule will be published in the April 25, 2006Federal Register.  Comments will be accepted until June 12, 2006, and a final rule will be published later this year.


April 6, 2006 - Lewis Morris, Chief Counsel to the Inspector General, before the Subcommittee on Health of the U.S. House Committee on Ways and Means on issues regarding health care information technology. Click here for more.


February 8, 2006 - Deficit Reduction Act of 2005, Signed by President Bush
“This new law contains a number of provisions about which compliance professionals must be aware.  It will also require providers to modify some aspects of their compliance programs and, in particular, the education element that is one of the seven components of an effective compliance program. The compliance-related provisions become effective January 1, 2007. The Act requires entities that receive more than $5 million in Medicaid reimbursement to include their compliance program information in employee training.” From an article written by Frank Sheeder and to be published in the March issue of Compliance Today.

Chapter 3 (page 69) -- ELIMINATING FRAUD, WASTE, AND ABUSE IN MEDICAID of the “Act” (See SEC. 6032, page 70, EMPLOYEE EDUCATION ABOUT FALSE CLAIMS RECOVERY to review the Employee Education Provisions of the “Act”)

Deficit Reduction Act of 2005 
(Medicaid begins on page 51, Medicaid Fraud & Abuse see page 69)

 



Related Files
The State Medicaid Director letter (Adobe PDF File)
DOJEfforts to Combat Health Care Fraud and Abuse (Adobe PDF File)
CMS press release 5/16/08 (Adobe PDF File)
NY 08-09 OfficeMedicaidInspectorGeneralWorkPlan (Adobe PDF File)
An Open Letter to Health Care Providers, April 15, 2008 (Adobe PDF File)
Government-Industry Roundtable 1/30/08 (Adobe PDF File)
HCCA Executive Committee Comments to US Sentencing Commission
HCCA Cover Letter: HCCA Executive Committee Comments to US Sentencing Commission (Adobe PDF File)
HCCA Executive Committee Comments (Adobe PDF File)
OIG Work Plan for FY 2008 (Adobe PDF File)
DRA 6032 Employee False Claims FAQ (Adobe PDF File)
OIG: Fiscal Year 2006 Annual Report of the State Medicaid Fraud Control Units (MFCU) (Adobe PDF File)
Corp. Responsibility and Health Care Quality: Resource for Health Care Boards of Directors (Adobe PDF File)
Employee Education About False Claims Recovery: FAQ (Adobe PDF File)
False Claims Act (FCA) Provisions (Adobe PDF File)
Additional Guidance to State Medicaid Agencies, section 6032 of DRA of 2005 (Adobe PDF File)
Security Guidance for Remote Use of Electronic Protected Health Information (Adobe PDF File)
Annual Medicare Contractor Provider Satisfaction Survey Press Release (Adobe PDF File)
Annual Medicare Contractor Provider Satisfaction Survey Sample (Adobe PDF File)
Annual Medicare Contractor Provider Satisfaction Survey (Adobe PDF File)
OIG's OEI Report - Prescription Drug Plan Sponsors’ Compliance Plans (Adobe PDF File)
State Plan Under Title XIX of the Social Security Act (Adobe PDF File)
HHS Semiannual Report to Congress 4/06 to 9/06 (Adobe PDF File)
Medicare – Diabetes Updates 11/22/06 (Adobe PDF File)
Deficit Reduction Act of 2005 (Adobe PDF File)
OIG Work Plan for FY 2007 (Adobe PDF File)
OIG Advisory Opinion No. 06-09 (Adobe PDF File)
Federal Register, Hospital Outpatient Prospective Payment (Adobe PDF File)
Lewis Morris, Chief Counsel to OIG, Subcommittee on Health to U.S. House on health care IT (Adobe PDF File)
DRAFT Visit Guidelines for Hospital Outpatient Care (Adobe PDF File)
New ‘Red Flag’ Requirements for Financial Institutions and Creditors Will Help Fight Identity Theft (Adobe PDF File)
Inspector General’s “Open Letter to Health Care Providers” Announced March 24, 2009 (Adobe PDF File)
OIG's “Open Letter to Health Care Providers” Announced March 24, 2009 Summary (Adobe PDF File)
Statement of Lewis Morris, Chief Counsel, OIG, DHS (Adobe PDF File)
Statement Of James G. Sheehan, Medicaid Inspector General, NY, OIG (Adobe PDF File)
US v. Christi R. Sulzbach_Complaint (Adobe PDF File)
Combating Fraud, Waste, and Abuse in Medicare and Medicaid (Adobe PDF File)
HHS Rescinds Medicaid Regulations (Adobe PDF File)
Proposed Amendments to US Sentencing Guidelines (Adobe PDF File)
Case of two nurse whistleblowers in TX (Adobe PDF File)
Interview with James G. Sheehan, New York State Medicaid Inspector General (Adobe PDF File)
Federal Register’s Financial Conflict of Interest Notice of Proposed Rule Making (Adobe PDF File)

Related Links
October, 2003 - Press Release on the Report on Recommendations to Sentencing Guidelines For Organizations
October, 2003 - Report on Recommendations to Sentencing Guidelines For Organizations


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SERVER_NAME=hcca-ww1.hcca.internal
SERVER_PORT=80
SERVER_PORT_SECURE=0
SERVER_PROTOCOL=HTTP/1.1
SERVER_SOFTWARE=Microsoft-IIS/6.0
WEB_SERVER_API=
Client Variables:
cfid=9225522
cftoken=22447672
hitcount=1
lastvisit={ts '2010-07-20 11:12:04'}
pausetrans=0
timecreated={ts '2010-07-20 11:12:04'}
urltoken=CFID=9225522&CFTOKEN=22447672
Cookie Variables:
CFID=9225522
CFTOKEN=22447672
Session Variables:
admin=False
administrator=False
adminsectionlist=
alldynamic=N
bebroadcastemail=Array (0)
bebulkemailauditid=0
bememberid=
browser=Unknown
browserversion=0
cfid=9225522
cftoken=22447672
chapter=
cm=Struct (13)
cmbordercolor=#D1CDBB
cmcurrentfolderid=
cmeditorredirecturl=
cmfolderdisplay=
cmfoldersectiondisplay=
cmnavcontentgroupind=N
cmsavetemplatepath=
cmsectiondisplay=
cmsuperadminflag=
cmsurftoeditcontentid=0
cmsurftoeditreturnurl=
cmtextonlytemplate=False
cmwebsitekey=
committee=
companymaster=false
companymembershipnum=
companyname=
contactid=0
coregistrant=Array (0)
cpinvitegroupmembers=Array (0)
debug=False
emailaddress=
faqflag=
firstname=
fontface=verdana
fontsize=2
geformsubmitted=false
headersize=3
imismemberid=
initialized=True
interestcategorylist=
jbcompany=Struct (0)
jbpreview=Struct (0)
jbsearch=Struct (0)
lastname=
location=Struct (8)
loggedin=0
member=Struct (18)
memberid=0
membershipflag=false
membertype=
message=
ol=Struct (2)
platform=Windows
publicresultsflag=
questiondisplaylimit=
redirect=
redirectfrom=
registrationpage=
rowcolor1=ccffff
rowcolor2=ccffcc
sc=Struct (3)
scadmincomponentcodelist=
screturnmessage=Click here to continue.
securitygrouplist=
sessionid=IMIS_HCCA_9225522_22447672
shoppingcart=Array (0)
staff=Struct (13)
surveydate=
surveyid=0
surveyreporttemplate=
surveyresponse=0
surveyresponseid=0
surveyreviewquestionlist=
surveytakenlist=
surveytype=
sy=Struct (20)
templatepath=/AM/Template.cfm?Section=Compliance_News
title=
urltoken=CFID=9225522&CFTOKEN=22447672
username=
URL Parameters:
CONTENTID=9786
FUSEFLAG=1
SECTION=Compliance_News
TEMPLATE=/CM/ContentDisplay.cfm
Debug Rendering Time: 31 ms