Date
PARA WEEKLY
UPDATE For Users
Improving T he Businessof HealthCare Since 1985 May 16, 2018 NEWS FOR HEALTHCARE DECISION MAKERS
IN THIS ISSUE QUESTIONS & ANSWERS - Surgeon Billing For Arthroscopy Procedures - MUE 86235 - Implant HCPCS - Prometheus IBD JULY 1, 2018 HCPCS UPDATES -- CLINICAL LAB AND DRUGS
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The number of new or revised Med Learn (MLN Matters) articles released this week. All new and previous Med Learn articles can be viewed under the type "Med Learn", in the Advisor tab of the PARA Dat a Edit or . Click here.
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USING PARA'S SHARE OF COST WIDGET CMS PROPOSES FOUR RULES FOR FY19 RURAL HOSPITAL PROGRAM GRANTS AVAILABLE: - Partnerships With Native Americans - MultiPlan Rural Health Outreach TELEHEALTH CHARGING & CODING
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The number of new or revised Transmittals released this week. All new and previous Transmittals can be viewed under the type "Transmittals" in the Advisor tab of the PARA Dat a Edit or . Click here.
Administration: Pages 1-36 HIM /Coding Staff: Pages 1-36 Providers: Pages: 2,6-7,14,30 PDE Users: Pages 5,7-12,25,27 Surgical Svcs: Pages 2,6,32 Laboratory Services: Page 8 Pharmacy: Page 8
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- Finance Departments: Pages 27,29,33,35 - Rural Healthcare: Page 13 - Behavioral Health: Page 11 - Telehealth: Page 14 - Hospice Care: Page 12 - Inpatient Rehab: Page 12
© PARA Healt h Car e An alyt ics CPT® is a r egist er ed t r adem ar k of t h e Am er ican M edical Associat ion
PARA Weekly Update: May 16, 2018
SURGEON BILLING FOR ARTHROSCOPY PROCEDURES
Can you explain the proper method for billing of Medicare's professional fee for arthroscopic procedures 29827, 29823, 29824 and 29826?
Yes. This is in follow-up to your request for an explanation of Medicare?s professional fee payment for four arthroscopic surgical procedures on the same right shoulder -- 29827, 29823, 29824, and 29826. The DOS was late 2017. (Please note that the PARA system default shows 2018 rates, the user has to change the year to 2017 to get the rates in effect on that DOS.) Attached is a PARA paper that discusses multiple procedure discounts on professional fees.
The highest valued pro fee of the four procedures was 29827, per the Calculator HCPCS report:
An arthroscopy procedure uses an endoscope, so Medicare?s process for adjudicating claims falls under the special multiple endoscopic procedures section of the Medicare Claims Processing Manual, Chapter 12 ? note that the reference to field 21 refers to the multiple procedure indicator 3:
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PARA Weekly Update: May 16, 2018
SURGEON BILLING FOR ARTHROSCOPY PROCEDURES
https://www.cms.gov/Regulations-and-Guidance/ Guidance/Manuals/Downloads/clm104c12.pdf ?If Field 21 contains an indicator of ?3,? and multiple endoscopies are billed, the special rules for multiple endoscopic procedures apply. Pay the full value of the highest valued endoscopy, plus the difference between the next highest and the base endoscopy. Access Field 31A of the MFSDB to determine the base endoscopy.? To find ?Field 21? and ?Field 31A?, we checked the PARA Data Editor ?Professional Fee? search on the Calculator tab. This offers both the multiple procedure indicator and the endoscopic base code. Only procedure 29826 has an indicator of 0, meaning that it is not discounted when combined with other procedures. For the other three procedures, 29823, 29824, and 29827, the multiple procedure indicator is 3, with a base endoscopic procedure code of 29805:
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PARA Weekly Update: May 16, 2018
SURGEON BILLING FOR ARTHROSCOPY PROCEDURES
The rate of payment for the base code, 29805, was $446.55 in 2017:
Therefore, Medicare pays as follows: 29527 Full reimbursement @ MPFS 29823 $589.67 ? 446.55 = 29824 $635.50 ? 446.55 = 29826 Full reimbursement @ MPFS
$1,008.56 $ 143.12 $ 188.95 $ 168.07
These rates match the remittance (PHI redacted):
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PARA Weekly Update: May 16, 2018
MUE 86235
We have a claim from Managed Health Services Ambetter that shows processed successfully per the claim remarks. However, there wasn't any payment made on CPT速 86235. It states that service units exceed maximum/medically unlikely edits. I did check PARA for the units allow to bill and it showed 10 for that CPT速. We are wondering if I should resubmit the claim with one line for the CPT速 with the total charge amount for 10 units and the rest non-covered? I have attached a copy of the UB claim form as well as the EOB from MHS.
An sw er : I have attached our paper on resolving MUE edits for your reference. The MUE Adjudication Indicator (MAI) informs providers whether the MUE is a date-of-service or line-item edit. For CPT速 86235, the MAI is 3 ? that represents a Date of Service edit that cannot be avoided by breaking the units onto separate lines.
We also checked the Medicare NCCI Edit Manual to see if there was an explanation for this particular edit, but it is not mentioned.
https://apps.para-hcfs.com/para/Documents/ Q&A_Resolving_MUE_Edits_edited.pdf
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PARA Weekly Update: May 16, 2018
IMPLANT HCPCS
We have a patient encounter that was coded 54660. He had bilateral testicular prostheses implanted. HCPCS code C2622 (penile prosthesis) was used by the OR with a quantity of two. We have an edit stating that obviously only one can be billed. We do not think the above code is the correct one to use for testicular prosthesis. Do you know what is the correct HCPCS code is for the implant itself? We agree, C2622 (prosthesis, penile, non-inflatable) is not the appropriate HCPCS to report for testicular implants required for the surgery 54660 (insertion of testicular prosthesis (separate procedure)). Some ?device-dependent? surgical procedures will not pass billing edits if a device code is not present. Medicare created HCPCS C1889 (Implantable/insertable device for device intensive procedure, not otherwise classified) to satisfy the billing edit in cases where there is not an appropriate HCPCS to describe the implant. Reporting C1889 will enable the claim to pass billing edits in such cases. In this case, billing two units of C1889 should resolve the problem. The MUE for C1889 is 2:
Device-dependent HCPCS are those for which Medicare deems that more than 40% of the OPPS reimbursement for that code is attributed to device cost. The list of device-dependent HCPCS is provided in Addendum P of the 2018 OPPS Final Rule. Procedure 54660 is on the device-intensive list because it has an implant expense of 43.13% (as listed on the Addendum P), which exceeds Medicare?s 40% threshold for ?device-dependent? surgical procedures. Therefore, in this case, we recommend reporting C1889 for the implants.
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PARA Weekly Update: May 16, 2018
PROMETHEUS IBD
MolDx Prometheus IBD testing is not covered per LCD L37539 from a revision dated 3/19/2018. The Group 1 codes for the IBD panel are 81479, 82397, 83520 and 86140. The 86140 is a C Reactive protein (inflammatory CRP, not the high sensitive (86141) that is covered in some cardiovascular risk LCDs.) Now that this code is part of the IBD panel, our LIS is flagging us to get an ABN signed. Is this needed or is an ABN only needed when it is part of the Promethus IBD panel? Answer: The LCD isn?t clear on this point, but it starts with a strong statement: ?This is a non-coverage policy for the Prometheus IBD sgi Diagnostic test.? This does not appear to be conditional as to the panel, but it does not clearly identify any component test as the target, only the product as provided by Prometheus. Since we can?t be sure, we recommend obtaining an ABN for any and all 86140 testing, whether part of the Prometheus IBD panel or not. If the hospital obtains an ABN, Medicare will pay for the test if they deem it to be covered (i.e. for other diagnosis.) It might be wise to obtain an ABN for a test that is not part of the Prometheus IBD panel, and check the Medicare reimbursement to learn whether or not it was covered. Alternately, you may wish to submit your question to the MAC to clarify their position on this point. Medicare publishes draft LCDs in an attempt to obtain stakeholder input and answer questions ? that comment period ended and the LCD is now final. Although I?m not sure they?ll take questions now that the comment period is over, the MAC contact on the proposed LCD was: Ella Noel, D.O., FACOI 1717 West Broadway Madison, WI 53713 policycomments@wpsic.com By the way, Prometheus offers billing support, including a letter that (like an ABN) explains insurance coverage issues to patients, at the link below: https://www.prometheuslabs.com/Healthcare Professionals/BillingSupport.aspx Finally, to help our clients anticipate new coverage determinations, PARA provides a list of draft LCDs every month. Most of the LCD?s published in the past year have been for molecular diagnostics. You may want to see if there are any new coverage determinations in process that interest you, and which are still open to comment or questions. The latest list of draft LCDs is attached; we cover this as a regular agenda item in our monthly Revenue Integrity meetings. There are different stages in LCD development -- if the LCD draft status is A, then the final LCD is already in place, it is listed simply to publish the previous version and the comment start and end date. 7
PARA Weekly Update: May 16, 2018
JULY 1, 2018 HCPCS UPDATES -- CLINICAL LABS & DRUGS
edicare has added new HCPCS to the Clinical Lab Fee Schedule and new drug HCPCS to the Medicare Physician Fee Schedule. The new Proprietary Laboratory Analyses (PLA) codes are covered under the ClinLab fee schedule have each been assigned a retroactive date ? claims can be processed as of July 2, 2018. All the new test codes are ?contractor priced? until pricing decisions are finalized in July of 2018.
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PARA Weekly Update: May 16, 2018
JULY 1, 2018 HCPCS UPDATES -- CLINICAL LABS & DRUGS
The following new drug HCPCS were announced; all of which are Medicare Physician Fee Schedule Status E ? "Excluded from physician fee schedule by regulation. These codes are for items and/or services that CMS chose to exclude from the fee schedule payment by regulation. No RVUs or payment amounts are shown and no payment may be made under the fee schedule for these codes. Payment for them, when covered, continues under reasonable charge procedures.?
These codes are for items and/or services that CMS chose to exclude from the fee schedule payment by regulation.
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PARA Weekly Update: May 16, 2018
USING PARA'S SHARE OF COST WIDGET
The issue of price transparency has gained increasing importance in the healthcare industry due to the proliferation of medical options and the rise of consumerism. Under current law, hospitals are required to make public a list of their standard charges. CMS plans to increase the accessibility to this information by specifically requiring hospitals to publicly post their standard charges online. That's where PARA can help. PARA?s Patient Share of Cost Widget provides a solution that enables patients and consumers the ability to generate quotes on the hospitals top procedures. It is a web-based system that allows the patient to determine their share of cost for healthcare services. -
Promote pricing transparency Provide accurate estimates prior to service Reduce patient dissatisfaction directed at the provider Increase self-pay collections while decreasing bad debt
For Inf or M or e mat io n Cont PARA act your A Exec ccount ut ive
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PARA Weekly Update: May 16, 2018
CMS PROPOSES FOUR RULES AFFECTING FY19 PAYMENTS
The Centers For Medicare And Medicaid Services has proposed four new rules that will affect Fiscal Year 2019 Medicare payment policies and rates for a variety of programs. PARA brings you important links and information about each of these proposed rules.
Inpatient Psychiatric Facility: FY 2019 Payment & Quality Reporting Updates Comments accepted until June 26, 2018 CMS Fact Sheet (Click Here)
Skilled Nursing Facility: FY 2019 Payment & Quality Reporting Updates Comments accepted until June 26, 2018 CMS Fact Sheet (Click Here)
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PARA Weekly Update: May 16, 2018
CMS PROPOSES FOUR RULES AFFECTING FY19 PAYMENTS
Inpatient Rehabilitation Facility: FY 2019 Payment & Quality Reporting Updates Comments accepted until June 26, 2018 CMS Fact Sheet (Click Here)
Hospice: Proposed Updates To The Wage Index And Payment Rates for FY 2019 Comments accepted until June 26, 2018 CMS Fact Sheet (Click Here)
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PARA Weekly Update: May 16, 2018
RURAL HOSPITAL PROGRAM GRANTS AVAILABLE
Rural hospitals and clinics face their own set of unique and burdensome challenges when it comes to program development, cash management and maintaining volume. That's why it's great when they can get some assistance from external funding sources. At PARA, we've found an excellent source of funding opportunities for rural healthcare facilities. Here are some examples.
Strategic Prevention Framework -- Partnerships With Native American Tribes - Provides up to $2,260,000 to address underage drinking and up to two more substance abuse prevention priorities such as marijuana, cocaine and opioids. - Application Deadline: July 6, 2018
Here's the link:
MultiPlan Rural Health Outreach Grant - Awards funding up to $7,500 to hospitals serving rural areas to develop community outreach programs that encourage new services or reach new populations. - Application Deadline: June 15, 2018
Here's the link
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
Effective January 01, 2018, following the issuing of the CY 2018 final rule, CMS announced the Telehealth Originating Site Facility Fee payment amount in addition to other Telehealth policy changes. Facility Fee : The Telehealth originating site facility fee may be claimed using HCPCS code Q3014.
The CY2018 Telehealth originating site facility fee:
https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/ Downloads/MM10393.pdf
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
A facility may qualify as an ?originating site? for Telehealth services under Medicare if the facility is located in one of the following defined areas and the beneficiary resides within one of the following two areas: 1. HPSA ? Rural Health Professional Shortage Area 2. County outside of a Metropolitan Statistical Area (MSA) Originating sites authorized by law to render Telehealth services are: 1. The office of a physician or practitioner 2. Hospital 3. Critical Access Hospital (CAH) 4. Rural Health Clinic (RHC) 5. Federally Qualified Health Center (FQHC) 6. Hospital-based or CAH-based Renal Dialysis Centers (including satellites); Independent Renal Dialysis Facilities are not eligible originating sites 7. Skilled Nursing Facilities (SNF) 8. Community Mental Health Centers (CMHC) The revenue code used to bill Telehealth facility service is 0780:
Professional Fees: Distant site practitioners who may furnish and receive payment for covered Telehealth services (subject to state law) are: 1.Physicians 2.Nurse practitioners (NP) 3.Physician assistants (PA) 4.Nurse - Midwives 5.Clinical nurse specialists (CNS) 6.Certified registered nurse anesthetists (CRNA) 7.Registered dietitians or nutrition professionals 8.Clinical psychologists (CP) and Clinical social workers (CSW)** **Note: CPs and CSWs cannot bill for psychiatric diagnosis interview examinations with medical services or medical evaluation and management services under Medicare guidelines. These practitioners may not bill or receive payment for CPTÂŽ codes 90792, 90833, 90836, and 90838.
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
The full list of HCPCS which may be reported for Telehealth professional services is provided later in of this paper. POS code 02 for Telehealth: POS 02 is effective for Telehealth services beginning January 01, 2017, to indicate the billed service was furnished as a Telehealth service from a distant site.
Critical Access Hospitals (CAH) which have elected to bill under Method II, may bill for the distant-site outpatient physician Telehealth services on the UB04/837i claim type. Modifiers: Providers are required to append a modifier to HCPCS codes reported on the claim to indicate whether the technology used was interactive (modifier GT) or ?store and forward? (modifier GQ). Effective January 01, 2018, GT modifier has been eliminated for all providers, except CAH Method II Providers. For CAH Method II providers, the GT modifier is still required.
Services furnished to inpatients - there are several special HCPCS codes defined for use in reporting inpatient Telehealth services:
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
State coverage for Telehealth Services: There are 48 states that currently cover Telehealth services in the Medicaid Program. The 48 states include the District of Columbia. There are currently 32 states that have some form of reimbursement for Telehealth Services, that include the District of Columbia as well. The link provided below links with an interactive map so you can identify your state as it relates to Telehealth services that may or may not be available: http://www.ncsl.org/research/health/state-coverage-for-telehealth-services.aspx
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
A link and excerpts from the Medicare Claims Processing Manual regarding billing the professional fee at the distant site are provided below: https://www.cms.gov/Regulations-and-Guidance/Guidance/ Manuals/Downloads/clm104c12.pdf 190.6 - Payment Methodology for Physician/Practitioner at the Distant Site (Rev. 3586, Issued: 08-12-16, Effective: 01-01-17, Implementation: 01-03-17) 1. Distant Site Defined The term ?distant site? means the site where the physician or practitioner, providing the professional service, is located at the time the service is provided via a telecommunications system. 2. Payment Amount (professional fee) The payment amount for the professional service provided via a telecommunications system by the physician or practitioner at the distant site is equal to the current fee schedule amount for the service provided at the facility rate. Payment for an office visit, consultation, individual psychotherapy or pharmacologic management via a telecommunications system should be made at the same facility amount as when these services are furnished without the use of a telecommunications system. For Medicare payment to occur, the service must be within a practitioner?s scope of practice under State law. The beneficiary is responsible for any unmet deductible amount and applicable coinsurance. 3. Medicare Practitioners Who May Receive Payment at the Distant Site (i.e., at a site other than where beneficiary is) As a condition of Medicare Part B payment for telehealth services, the physician or practitioner at the distant site must be licensed to provide the service under state law. When the physician or practitioner at the distant site is licensed under state law to provide a covered telehealth service (i.e., professional consultation, office and other outpatient visits, individual psychotherapy, and pharmacologic management) then he or she may bill for and receive payment for this service when delivered via a telecommunications system. If the physician or practitioner at the distant site is located in a CAH that has elected Method II, and the physician or practitioner has reassigned his/her benefits to the CAH, the CAH bills its regular A/B/MAC (A) for the professional services provided at the distant site via a telecommunications system, in any of the revenue codes 096x, 097x or 098x. All requirements for billing distant site telehealth services apply. 190.6.1 - Submission of Telehealth Claims for Distant Site Practitioners (Rev. 3586, Issued: 08-12-16, Effective: 01-01-17, Implementation: 01-03-17) Claims for telehealth services are submitted to the contractors that process claims for the performing physician/practitioner?s service area. Physicians/practitioners submit the appropriate HCPCS procedure code for covered professional telehealth services with place of service code 02 (Telehealth) along with the ?GT? modifier (?via interactive audio and video telecommunications system?). By coding and billing the ?GT? modifier with a covered telehealth 18
PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
procedure code, the distant site physician/practitioner certifies that the beneficiary was present at an eligible originating site when the telehealth service was furnished. By coding and billing the ?GT? modifier with a covered ESRD-related service telehealth code, the distant site physician/practitioner certifies that 1 visit per month was furnished face-to-face ?hands on? to examine the vascular access site. Refer to section 190.3.4 of this chapter for the conditions of telehealth payment for ESRD-related services. In situations where a CAH has elected payment Method II for CAH outpatients, and the practitioner has reassigned his/her benefits to the CAH, A/B/MACs (A) should make payment for telehealth services provided by the physician or practitioner at 80 percent of the MPFS facility amount for the distant site service. In all other cases, except for MNT services as discussed in Section 190.7- A/B MAC (B) Editing of Telehealth Claims, telehealth services provided by the physician or practitioner at the distant site are billed to the A/B/MAC (B). Physicians and practitioners at the distant site bill their A/B/MAC (B) for covered telehealth services, for example, ?99245 GT.? Physicians?and practitioners?offices serving as a telehealth originating site bill their A/B/MAC (B) for the originating site facility fee. Definitions for Telehealth Services 1) Asynchronous Telecommunications ? Medical information is stored and forwarded to be received at a later time by a physician or healthcare practitioner at a distant site. This medical information is reviewed without the patient being present. This is also known as ?store and forward? telehealth or non-interactive communication. 2) Interactive Audio and Video Telecommunications, Interactive Audio and Visual Transmissions, Audio-Visual Communications Technology ? Medical information is communicated in real-time with the use of Interactive Audio and Video Communications equipment. The real-time communication is between the patient and a distant physician or health care specialist who is performing the service. The patient must be present and participating throughout the communication. 3) Originating Site ? The location of a patient at the time the service is being furnished via a telecommunications system. 4) Telehealth ? Telehealth services are live, interactive Audio and Visual Transmissions of a physician-patient encounter from one site to another using telecommunications technologies. They may include transmissions of real-time telecommunications or those transmitted by store-and-forward technology. 5) Telemedicine ? Telemedicine services are medical services provided via telephone, the Internet, or other communications networks or devices that do not involve direct, in-person patient contact. 19
PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
CPT® Telephone Codes ? The AMA has established several CPT®s for ?online? and ?telephone? codes, none of which are payable by Medicare.
CMS Link to all approved Telehealth codes for CY 2018 appears in the ?Downloads? section at: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.html
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
The complete text of the Medicare Claims Processing Manual, including Chapter 12 ?Physicians/Non-physician Practitioners? is available to PARA Data Editor users on the Calculator tab by clicking on the link in the lower left corner:
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
The following table includes codes that can be reported by the physician performing the Telehealth services for CY 2018:
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
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PARA Weekly Update: May 16, 2018
TELEHEALTH: CHARGING, CODING & REIMBURSEMENT
*For ESRD-related telehealth services, a physician, NP, PA or CNS must furnish at least one (1) face-to-face visit (not telehealth) each month to examine and access the vascular access site. Reference: https://www.cms.gov/Outreachand-Education/Medicare-Learning -Network-MLN/MLNProducts/ Downloads/Telehealth-Services -Text-Only.pdf
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PARA Weekly Update: May 16, 2018
LOG IN TO THE PDE USING GOOGLE CHROME
The PARA Data Editor is now compatible with multiple web browsers so that everyone can have options when it comes to which browser to use, depending on resources or preferences. Our PARA Data Editor Multiple Web Browser (Beta) Version to available to everyone with a proper PARA Data Editor Login. The Web Browsers available include a version in both Internet Explorer and Google Chrome. To all users who wish to use the Multiple Web Browser (Beta) Version, please be aware that this is a PRELIMINARY version meant to work out any errors and issues that it might exhibit. It is in the process of being updated to mirror the current production version of the PARA Data Editor. With your help, we will be able to narrow in on fixes throughout the PARA Data Editor Multiple Web Browser (Beta) Version to then ensure full functionality and to further expand to more Web Browsers. The PARA Data Editor Multiple Web Browser (Beta) Version can be accessed via the following link and using the appropriate login when prompted by the browser: https://www.para-hcfs.com/projects/ pde_upgrade/pde_MultBrowser Once logged in, we would like for you to please be aware of a few key features to help us improve the PDE Multiple Browser (Beta) Version. First, please be aware of the change in look for the Multiple Browser (Beta) Version. We are attempting to update the look and feel of the PDE to be cleaner and user-friendly. Second, if you may have any questions, need help, would like to report an error or issue with the PDE Multiple Web Browser (Beta) Version, or anything else you may think of, click on the ?Contact Support? Link in the upper-right hand corner of the PDE.
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PARA Weekly Update: May 16, 2018
There was ONE new or revised Med Learn (MLN Matters) article released this week. To go to the full Med Learn document simply click on the screen shot or the link.
FIND ALL THESE MED LEARNS IN THE ADVISOR TAB OF THE PDE
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PARA Weekly Update: May 16, 2018
The link to this Med Learn: MM10622
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PARA Weekly Update: May 16, 2018
There were SEVEN new or revised Transmittals released this week. To go to the full Transmittal document simply click on the screen shot or the link.
FIND ALL THESE TRANSMITTALS IN THE ADVISOR TAB OF THE PDE
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PARA Weekly Update: May 16, 2018
The link to this Transmittal R4048CP
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PARA Weekly Update: May 16, 2018
The link to this Transmittal R4049CP
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PARA Weekly Update: May 16, 2018
The link to this Transmittal R207NCD
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PARA Weekly Update: May 16, 2018
The link to this Transmittal R796PI
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PARA Weekly Update: May 16, 2018
The link to this Transmittal R4047CP
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PARA Weekly Update: May 16, 2018
The link to this Transmittal R4045CP
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PARA Weekly Update: May 16, 2018
The link to this Transmittal R2081OTN
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PARA Weekly Update: May 16, 2018
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