February 22, 2019 – Federal and State Issues
Thomas J. Madejski, MD
February 22, 2019
Volume 22 Number 8
Last week your MSSNY leadership and staff attended the AMA National Advocacy Conference in Washington, D.C. We enjoyed presentations from a number of elected officials, HHS Secretary Alex Azar, various media personalities and AMA content experts about the many issues affecting our patients and our practices. The highlight of the meeting was the Nathan Davis Awards dinner, Tuesday night. Nathan Davis, a MSSNY member from Broome County helped to found the AMA in 1857. I was proud to accept an award for our longstanding MSSNY member Dr. Richard Izquierdo for his work to improve the healthcare of his patients in his underserved community.
Doc Izquierdo is a trailblazer whose efforts have resulted in the creation of a healthcare system that focuses on treatment of the underserved, and was a pioneer in improving the educational system to improve recruitment of minority students into healthcare fields.
On the Hill
Tuesday and Wednesday were spent on the Hill meeting with our elected representatives and staff to discuss the many current issues under discussion. We were happy to visit the offices of Senate Majority Leader Schumer, Senator Gillibrand, Rep. Elise Stefanik, Rep. Paul Tonko, Rep. Brian Higgins, Rep. Elliott Engel, and Rep. Joe Morelle among others. We reviewed legislative proposals for fixing some of the flaws in the ACA, Medicare funding, current activities to combat the opiate crisis, and challenges related to marijuana. There was uniform support to changing marijuana from Schedule I to Schedule II, to support high quality research to address the many questions regarding its medicinal use and safety concerns with expanding access to marijuana in some of the states. MSSNY is very supportive of efforts to better define the medicinal properties of various cannabis derived products for treatment of various conditions. That research should also answer the many questions about safety and consequences of chronic use for patients, and inform decisions on non-medicinal use.
Expanded Marijuana Use for Recreational Purposes
Subsequently, Governor Cuomo’s Council and other staff briefed the New York State Legislature on their proposal to expand medicinal and adult recreational use. Many questions remain in regard to promoting increased use of marijuana and related hemp products both medicinally, and as a lifestyle choice. MSSNYs concern relates to a paucity of data on long term efficacy and risks associated with chronic use. Last week JAMA Psychiatry published a meta-analysis raising concerns about increased depression and suicide rates in association with marijuana use.
Societal mental health issues and teenage and young adult suicide is a major issue throughout the country. Emerging concerns regarding increasing marijuana usage among youth should give us pause before making it more accessible to society in general, even with the protections in the Governor’s proposal. States with adult use programs have higher rates of child and adolescent use.
We should work with the Governor’s Office and the Legislature to address any disparities in the application of the law to minor users of marijuana. We should urge our Federal representatives to reschedule marijuana to allow high quality, large population studies of this complex moiety to inform us on its proper place in the compendium of treatments available for our patients. That research should also help to determine whether it is safe for long term use and made available more widely for non-medicinal purposes. Federal action would also help to protect our children, teens, and young adults from the effect of legalization in neighboring states and countries.
Join me in Albany March 6th to help your fellow physicians inform our representatives on these many important topics.
Primum, non nocere!
Comments? email@example.com; @mssnytweet; @TomMadejski
Thomas J. Madejski, MD
Join Us For: MSSNY’s Annual “Physician Advocacy Day” (3/6)!
Physician leaders from across New York State will be coming to Albany on March 6, to advocate for their profession and their patients. Will you be joining them?
With nearly 40 newly elected legislators in Albany, the need for physician advocacy and grassroots involvement is greater than ever. It’s vital for physicians to forge new relationships, as well as strengthen existing relationships to ensure the physician community’s message is heard about policies that could impact patient care.
Please plan to participate in MSSNY’s “Physician Advocacy Day” that will be held on Wednesday, March 6th in the Lewis Swyer Theatre in the Egg located at the Empire State Plaza, Albany NY. Click here to register!
Join Us To Urge Your Legislators To:
- Proceed very cautiously on paradigm shifting proposals such as legalization of recreational marijuana (proposed in the State Budget) and creating a single payor health insurance structure.
- Reject proposed unfair cuts to physicians treating patients covered by both Medicare and Medicaid;
- Reject proposals that would add prior authorization burdens for care provided to Medicaid patients;
- Support legislation to reduce excessive health insurer prior authorization hassles that delay patient care.
- Reduce the high cost of medical liability insurance through comprehensive reforms.
- Preserve opportunities for medical students and residents to become New York’s future health care leaders.
A brief informal luncheon to which members of each House are invited to speak with their constituents will follow the morning program. County medical societies will be scheduling afternoon appointments for physicians to meet with their elected representatives. If you have any questions/comments, please contact Carrie Harring at firstname.lastname@example.org.
Physicians Urged to Oppose $80/Dual Eligible Patient Cut
Physicians are urged to continue to contact their state legislators to oppose a proposal in the 2019-20 Executive Budget that would significantly cut payments that Medicaid makes to physicians to cover the Medicare Part B deductibles of their patients covered by both Medicare and Medicaid. You can send a letter in opposition to this harmful proposal by clicking here. You can read MSSNY’s memo of opposition to the Legislature here.
While the exact cut for each physician would depend on the physician’s patient mix and services provided, we estimate that the cut would be $80 per patient. That is because the 2019 Medicare Part B deductible is $185, and studies show that on average Medicaid only pays 56% of the Medicare fee schedule in New York.
Given that there are hundreds of thousands of patients in New York who are “dually eligible”, for practices that see a large number of dual eligible patients, this will have a profound impact. For example, if a physician’s patient mix includes 500 such dual eligible patients, which could certainly be the case for many types of specialty physicians, it would cut payments by $40,000 per year – funds that could go toward upgrading electronic health records, hiring additional staff to allow for more time with patients, upgrading facilities or other medical equipment.
In past years, physicians have had to absorb significant cuts from Medicaid for the care that they provide to their senior and disabled patients covered by both Medicare and Medicaid, making it much harder for these physicians to deliver community-based care. Please urge your legislators know how unfair this cut is. Please urge them to oppose balancing the state budget on the backs of dedicated community physicians seeking to deliver quality care to their patient. (AUSTER)
Governor Releases “30-Day” Budget Amendments That Could Cause Significant Medicaid Cut
Late last week, Governor Cuomo provided the State Legislature with his “30-day amendments” to the Executive Budget proposal that was formally introduced on January 15. While staff is continuing to review the entire proposal, there are major implications for the health care sector that are designed to close a $2.3 Billion budget gap for FY 2019-20. Of significant concern is a proposal that would impose an across the board Medicaid cut to all covered Medicaid providers totaling $190 million. This could translate to a per service cut to physicians and other health care providers of approximately 0.8%.
Moreover, there were significant cuts to hospitals and nursing homes announced including the proposed elimination of a scheduled $550 million increase in Medicaid payments that had been announced in late 2018. Furthermore, the Governor proposed a revised version of an “opioid tax” on manufactures and distributors that had been approved by the State Legislature as part of last year’s Budget, but had been struck down by the courts. The governor has also proposed re-convening the Medicaid Redesign Team (MRT) that had met in the early years of the Cuomo Administration to arrive at ways to increase quality care delivery and produce savings for the system. Please remain alert for further updates on these issues. (AUSTER)
NYS DOH Sends Letter To Physician Regarding Opioid Prescribing
The New York State Department of Health, Bureau of Narcotic Enforcement, has sent a letter to physicians and institutions apprising them that, effective April 1, 2018, legislation was enacted that no opioids shall be prescribed to a patient initiating or being maintained on opioid treatment for pain which has lasted more than three months or past the time of normal tissue healing, unless the medical records contains a written treatment plan that follows generally accepted national professional or governmental guidelines.
This requirement does not apply for patients who are being treated for cancer that is not in remission, in hospice or end of life care, or whose pain is being treated as part of palliative care practices. MSSNY took no position on this measure as it was consistent with the CDC’s Chronic Pain guidelines, and was an improvement from an earlier version that would have required a written treatment plan for pain lasting longer than 30 days. A copy of the letter from BNE is here. Information on the CDC’s Chronic Pain Guidelines is here. (CLANCY)
NYS DOH Issues Emergency Regulations On PTSD, Substance Abuse And Opioid Use Disorder
This week the NYS DOH re-issued emergency regulations adding PTSD, substance abuse and opioid use disorder to the list of conditions to be treated by marijuana consistent with statutes enacted in 2018 authorizing medical marijuana to treat these conditions. DOH had previously issued an emergency regulation on this subject last October.
MSSNY has opposed adding these conditions to the list of medical conditions that a physician and/or other health care provider can certify a patient for use of marijuana. However, importantly, these updated emergency regulations now require that any provider making a recommendation for marijuana for the treatment of opioid use disorder must have a DATA 2000 waiver. This regulation appears to limit when marijuana can be used and assures that only those who have appropriate training can make the decision. A copy of the emergency regulations can be found on pages 7-9 at the NYS State Register.
MSSNY remains concerned about using marijuana for substance or opioid use disorders. A recent JAMA article highlights the concern of substituting marijuana in place of buprenorphine. The Jama article concluded “For the opioid addiction crisis, clearly efficacious medications such as methadone and buprenorphine are under prescribed. Without convincing evidence of efficacy of cannabis for this indication, it would be irresponsible for medicine to exacerbate this problem by encouraging patients with opioid addiction to stop taking these medications and to rely instead on unproven cannabis treatment. (CLANCY)
Galef Introduces Legislation To Enable Greater Communication Between Physicians & Patients
Assemblywoman Sandy Galef has introduced legislation (A5909) that would exclude a statement by a physician indicating apology or regret as an admission of liability in malpractice lawsuits. Under current law, physicians open themselves up to malpractice liability if and when they express their condolences to patients and/or their families when there is a negative medical outcome – even if there has been absolutely no wrongdoing on the physician’s behalf.
At least thirty-six states have passed similar legislation. Enactment of this measure would allow physicians to provide the apology or validation that families and patients often state they hope for by preventing these statements from being used as admissions of guilt in legal proceedings. Further, research has shown that in those states with apology laws, malpractice cases are solved 20% faster and average claims payment amounts are lower. (AVELLA)
Registration Now Open For Veterans Matters CME Webinars February 28th and March 14th
The Medical Society of the State of New York is proud to announce two NEW Veterans Matters webinars scheduled for February and March 2019. These webinars are: The Special Mental Health Needs of Women Veterans on Thursday, February 28th at 7:30am and Military Culture: Everything Physicians Need to Know About Veterans as Patients on March 14th at 7:30am.
Veterans Matters: The Special Mental Health Needs of Women Veterans
When: Thursday February 28, 2019 at 7:30am – Register here
Faculty: Col. Malene Ingram, MD (US Army Reserves)
- Review how the increased role of women in the military has impacted their mental health.
- Describe mental health concerns unique to women veterans and how to identify and treat them.
- Identify the barriers that women veterans face in getting the specific care they need.
Veterans Matters: Military Culture: Everything Physicians Need to Know About Veterans as Patients
When: Thursday, March 14 2019 at 7:30am – Register here
Faculty: Lt. Col Lance Allen Wang, & Marcelle Leis, CM Sgt (Ret)
- Describe the unique aspects of military culture and how they impact patients who are veterans.
- Explain the Dwyer Peer-to-Peer program as a resource to assist veteran patients re-acclimating from a group to an individual mentality.
- Review and identify resources to improve physician’s ability to fully treat veterans who are transitioning back into civilian life.
Additional information or assistance with registration can be obtained by contacting Sarah Humes at email@example.com or (518)465-8085
The Medical Society of the State of New York is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to provide continuing medical education for physicians.
The Medical Society of the State of New York designates this live activity for a maximum of 1.0 AMA/PRA Category 1 credits. Physicians should claim only the credit commensurate with the extent of their participation in the activity. (HUMES, HOFFMAN)
Registration Now Open For Medical Matters: Disaster Medicine: Every Physician’s Second Specialty on March 27th at 7:30 am
The Medical Society of the State of New York will conduct a webinar entitled, “Disaster Medicine: Every Physician’s Second Specialty” on March 27, 2019 @ 7:30am.
Register now for:
Medical Matters: Disaster Medicine: Every Physician’s Second Specialty
Wednesday, March 27th @ 7:30am
Faculty: Lorraine Giordano, MD, FACEP, FAADM
- Identify core preparedness competencies every physician should know
- Explore essential elements of preparedness plans for staff, patients, and family
- Describe available courses, resources and organizations to obtain disaster preparedness education and training
The Medical Society of the State of New York is accredited by the Accreditation Council for Continuing Medical Education (ACCME) to provide continuing medical education for physicians.
The Medical Society of the State of New York designates this live activity for a maximum of 1.0 AMA/PRA Category 1 credits™. Physicians should claim only the credit commensurate with the extent of their participation in the activity.(HOFFMAN, CLANCY)
Dr. Ardis Hoven’s Two Grandchildren Killed in Car Accident in Lexington KY
Dr. Ardis D. Hoven, an AMA Past President and Chair of the Board, a friend of MSSNY and a friend of Dr. Madejski, lost her two grandchildren, 17 year-old Neo and 15 year-old Roan, in a car accident on Sunday morning in Lexington, Kentucky, Ardis’ hometown. Please keep Dr. Hoven and her family in your thoughts and prayers.
FDA Head Warns Feds May Intervene if States Don’t Strengthen Vaccine Laws
FDA commissioner Scott Gottlieb said that the federal government may have to take action if states don’t strengthen their laws on vaccine exemptions, CNN reports.
Seventeen states allow families to choose not to vaccinate their children based on personal beliefs. Forty-seven states allow religious exemptions.
NYU to Offer Free Tuition to NYU Winthrop, a LI Medical School
New York University said Tuesday that its new three-year medical school on the campus of NYU Winthrop Hospital in Mineola will offer free tuition, matching the commitment made at its Manhattan campus. The university said it received preliminary accreditation from the Liaison Committee on Medical Education on Feb. 12 and plans to recruit its first students, to start in July.
The timing differs from most medical schools, which already may be delivering decisions to applicants. But Dr. Steven Shelov, dean of the NYU Long Island School of Medicine, said he still expects the school’s tuition-free program to draw thousands of applicants for its 24 initial slots. That number eventually will rise to 40 students per class.
For students to graduate in three years, the medical school will cut certain activities, such as weeks-long periods that allow students to travel to interview for residency programs and independently study for board exams. Instead, students will have conditional acceptance to primary care residency programs at NYU Winthrop, and group study for licensure exams will be part of the curriculum.
Preference for admission will be given to students who say they will train and practice in the New York metro area, the school said. Students who want to apply to residencies in other locations will be allowed to do so, but Shelov said he expects those students to be exceptions. The school tailored the curriculum for a career in primary care, with less focus on topics that would be applicable to future physician scientists and subspecialists. (Crains, 2/20)
Have You Seen an Increase in Automatic Down Coding of Your Visit Codes?
MSSNY has heard from a few members that they have been subjected to automatic down coding of their evaluation and management visit codes. Has this affected you or your practice? If so, please send an email to Regina McNally. Please use DOWN CODING in the subject line. Do not include any patient information; but do include the plan name, the code you billed and the code the plan reduced it to. In addition, please let us know if you filed an appeal with a copy of the medical record and what the result was, if any. Send your email to at firstname.lastname@example.org.
Physicians Have Concerns about Legalized Recreational Marijuana
New York physicians still have “significant concerns” with the executive budget proposal to legalize recreational marijuana, says Dr. Thomas Madejski, president of the Medical Society of the State of New York.
In a statement released Feb. 15, Madejski said that although a recent legislative public hearing “provided valuable insight,” there are several questions that need to be answered to alleviate physicians’ concerns, including how to keep marijuana out of children’s hands, especially as youth are using e-cigarettes are at an unprecedented pace. “The recently announced report from the CDC that 2018 saw the largest single-year increase in youth tobacco ever recorded—driven by adolescents who reported using e-cigarettes—is alarming,” Madejski said. “How will we ensure that legally purchased cannabis doesn’t get into the hands of children, similar to e-cigarettes?”
He said physicians also are concerned about a possible increase in drugged driving as a danger to pedestrians and other drivers. Madejski called for the continued review of data on public health implications from other states that have legalized marijuana and more research on the efficacy of marijuana for treating a range of health conditions. “We look forward to continued constructive discussion with the Legislature and the governor’s office on this issue,” he said. —Crains 2/19.
Sexual Harassment “Train the Trainer” FREE Webinar on March 20 at 12 noon
The Impact on the Healthcare System and the Medical Profession
When: March 20, 2019
The issue of sexual harassment in the workplace has been the center of a staggering amount of media attention and of a surge in litigation activity. Consistent with this momentum, New York State recently mandated that all employers are required to have a sexual harassment policy containing specified criteria in place by October 9, 2018, and to conduct sexual harassment prevention training by October 2019. (New York City requirements are slated to take effect in April 2019.)
The issue of sexual harassment takes on particular significance for the healthcare industry, because there is an established nexus between disruptive behavior, which includes sexual harassment, and adverse patient outcomes and medical errors. For those individuals who are unable to participate in the webinar at that time, MSSNY will be placing a recorded version of that webinar on the MSSNY website to facilitate access to the webinar for MSSNY members.
By the conclusion of the “Train the Trainers” webinar, you will know how to teach your employees:
- How to identify the more subtle forms of sexual harassment.
- The impact of sexual harassment on the quality of care and the victim.
- Practical advice on how to diminish and prevent sexual harassment at your practice.
- How to respond to sexual harassment in the workplace.
- Guidelines on how to comply with statutory mandates relating to sexual harassment.
Garfunkel Wild offers individual or group training, on-site or off-site training, as well as webinar modules that can serve to satisfy this new statutory mandate for your employees. If you would like to set up a personal training, please contact Andrew L. Zwerling at 516-393-2581 or email@example.com.
Extortion Scam Targeting DEA Registrants
DEA is aware that registrants are receiving telephone calls and emails by criminals identifying themselves as DEA employees or other law enforcement personnel. The criminals have masked their telephone number on caller ID by showing the DEA Registration Support 800 number. Please be aware that a DEA employee would not contact a registrant and demand money or threaten to suspend a registrant’s DEA registration.
If you are contacted by a person purporting to work for DEA and seeking money or threatening to suspend your DEA registration, submit the information through “Extortion Scam Online Reporting” posted on the DEA Diversion Control Division’s website, Extortion Scam Online Reporting
For more information contact:
Locate DEA Field Office for your area – https://apps.deadiversion.usdoj.gov/contactDea/spring/fullSearch
Registration Service Center – 1-800-882-9539
Email – DEA.Registration.Help@usdoj.gov
Physician Employment, Acquisition of Physician Practices Continue to Increase
A new study by PAI analyzes eighteen months of data – between July 2016 and January 2018 – during which hospitals acquired 8,000 medical practices, and an additional 14,000 physicians left private practice in favor of employment. This continued an ongoing trend that earlier PAI-Avalere research documented for the period between July 2012-July 2016, which witnessed an intense increase in hospital acquisitions and growth in physician employment.
The cumulative study period – from July 2012 through January 2018 – saw a dramatic, sustained trend of physicians leaving independent practice to enter into employment arrangements with hospitals and health systems. Over the full 5 ½- year study period, the number of hospital-acquired physician practices increased from 35,700 in 2012 to more than 80,000 in 2018. Forty-four percent of U.S. physicians were employed by hospitals or health systems by January 2018, compared to just one in four in July 2012.
These latest cumulative findings highlight striking changes in health care delivery, marked by consolidation between the hospital and physician sectors in every region of the country.
- Throughout this period, hospitals aggressively pursued acquisitions of physician practices, growing from 35,700 hospital-owned practices in July 2012 to 80,000 in January 2018. This 128 percent growth represents more than doubling in the number of hospital-owned practices nationwide.
- Physician employment increased overall by more than 70 percent, growing from 94,700 employed physicians in mid-2012 to 168,800 employed physicians in January 2018, with increases in every six-month time period measured over five-and-a-half years.
- All regions of the United States saw an increase in hospital-owned practices, with a range of total increase from 91 percent to 303 percent by region.
New Resources for 2019 Program Year for Promoting Interoperability Programs
CMS is currently updating the Promoting Interoperability Programs website to include new resources for the 2019 program year. Below are resources that are now available online:
- Promoting Interoperability Program landing page: Includes a general overview of the Medicare and Medicaid Promoting Interoperability Programs and important deadlines for the 2019 program year.
- 2019 Program Requirements for Medicare: Provides an overview on reporting requirements for the Medicare Promoting Interoperability Program in 2019.
- Fiscal Year 2019 Inpatient Prospective Payment System (IPPS) and Medicare Promoting Interoperability Program Overview Fact Sheet: Provides an overview of the changes that were finalized for the Medicare Promoting Interoperability Program in the IPPS Final Rule for the 2019 program year.
For More Information
For more information on the Promoting Interoperability Program reporting requirements for 2019, please visit the Promoting Interoperability Programs website. Additional information for the Medicare and Medicaid Promoting Interoperability Programs for 2019 will be posted on the Promoting Interoperability Programs website in the coming weeks.
Two Programs at the HOD You Don’t Want to Miss!
Protect Your Patients, Your Practice, and You!
Thursday, April 11, 2019, 3:00 – 4:00 pm, Grand Ballroom D/E, Westchester Marriott, Tarrytown
Join us at the OMSS Annual Meeting for an interactive presentation by Garfunkel Wild on Medical Records, including the impact on records of the controlled substances “epidemic,” what to consider when emailing and texting, dealing with non-compliant patients, additional areas of exposure from EMRs, and what to include in a telemedicine record.
Business meeting to follow, 4:00 – 6:00, Putnam Room
Click here to view flyer.
Friday, April 12, 2019, 5:00 – 6:30 pm, Grand Ballroom B, Westchester Marriott, Tarrytown
A panel presentation at the Women Physicians Caucus on Pay, Promotions and Career Advancement in Academic Medicine, Private Practice and Organized Medicine. Gender imbalance in medicine and academic sciences still exists. Hear three women physicians who have achieved significant leadership positions describe their own pathways, provide advice on how to achieve success, and show how to overcome gender bias, gender pay gaps and system-wide barriers to career advancement. Learn how to achieve success in your career!
Click here to view flyer.
Register for one or both programs at firstname.lastname@example.org.
Doctors Without Borders: Put Your Ideals into Practice!
On Thursday, March 14th, 2019 you are invited to join Doctors Without Borders/Médecins Sans Frontières (MSF) for a recruitment information session in the Bronx, NY. This is your opportunity to meet our recruitment team and learn about how you can join our pool of dedicated aid workers. We’re currently recruiting for a variety of medical and non-medical positions. Register here.
Study: Lower Mortality Rates Associated With Greater Number of Physicians
Reuters (2/18) reports that “mortality rates are lower in American communities with more primary care physicians than in areas of the country with fewer doctors, a study suggests.
The “number of primary care physicians rose from 196,014 in 2005 to 204,419 in 2015, the study found.” However, “because of disproportionate losses of providers in rural areas, the average number of primary care physicians for every 100,000 people in the population declined from 46.6 to 41.1 during the same period.” Further, “each 10 additional primary care physician per 100,000 people was associated with a 51.5 day increase in life expectancy, the study also found.” The study was published in JAMA Internal Medicine.
September 11th Compensation Fund Running Low on Money
The AP (2/16) reported that “the compensation fund for victims of 9/11 is running out of money and will cut future payments by 50 to 70 percent, officials announced Friday.” Almost “40,000 people have applied to” the September 11th Victim Compensation Fund, a “federal fund for people with illnesses potentially related to being at the World Trade Center site, the Pentagon or Shanksville, Pennsylvania, after the 2001 terror attacks there, and about 19,000 of those claims are pending.” Almost $5 billion of the $7.3 billion fund has already been awarded, but “fund officials estimate it would take another $5 billion to pay pending claims and the claims that officials anticipate will be submitted before the fund’s December 2020 deadline.
“Im/Migrant Workers Conference: Health Barriers and Solutions” at University of Rochester
University of Rochester School of Medicine, Flaum Auditorium
This Saturday 2/23/19, 9am-3pm
Student Registration: Free
General Public: $5.00
CME credit (4.5 credits): $13.00
Register here: https://urmcimmigrantworkerconference.brownpapertickets.com
Registration fee inclusive of breakfast & lunch.
Conference Website: https://ursmdmwc.wordpress.com
Office Rental 30 Central Park South.
5th Ave Medical Office for Share
Rare Find — Great Office Share
Are You Trying to Lease Your Medical Office or Sell Your Medical Practice? Trying to Sell New or Used Medical Equipment?
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Pediatrician BC, P/T
Seeking motivated, enthusiastic pediatrician for P/T position in solo practice in Long Island. Coverage will increase over time. Great opportunity for those seeking part time hours in an established practice. Fax resume to 516-858-2389.
Physician Wanted to Help Shape the Future of Primary Care
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Interested? Learn more and apply today at www.98point6.com/pcc
CALL FOR RATES & INFO. CHRISTINA SOUTHARD: 516-488-6100 ext. 355