BSD Draft APPEAL TO THE MEDICARE PROVIDER REIMBURSEMENT REVIEW BOARD Suzanne Cochran, Esquire, Chairperson Yvette C.

Hayes Michael D. Richards, C.P.A Keith E. Braganza, C.P.A. John Gary Bowers, C.P.A. In Re The Chassidic Healthcare Accreditation for Sofer-therapy Service International and Domestic Institutions Commission (CHASSIDIC), a religious, non-medical health care institution (RNHCI) accrediting organization. Viz http://www.google.com/search? q=EMDR+calligraphy&tbo=p&tbm=vid&source=vgc&hl=zhTW&aq=f http://www.calli-health.com/ http://www.youtube.com/watch?v=X6JZB3_R-IY Shalom uBrocho, Under Medicare regulations, non-contact nursing practices are eligible for coverage. Thus, Chassidic Soferim who engaged in teaching how to practice writing the Alef Bet in a traditional religious manner, with the intent of therapy, could be eligible for Medicare reimbursement. The health programs permit organizations to be designated as religious nonmedical healthcare services eligible for service reimbursements. We pray the Board declare the Commission is a recognized national professional organization for the particular activity under the provisions of 42 C.F.R. 413.85(e) for purposes of accrediting the

RNHCI Providers nursing education programs, facilities, and religious nonmedical healthcare services consonant 42 C.F.R. 413.85(e). The Medicare program was established to provide health insurance to the aged and disabled. 42 U.S.C. 1395-1395cc. The Centers for Medicare and Medicaid Services (CMS), formerly the Health Care Financing Administration (HCFA), is the operating component of the Department of Health and Human Services (DHHS) charged with administering the Medicare program. CMS payment and audit functions under the Medicare program are contracted to organizations known as fiscal intermediaries. Fiscal intermediaries determine payment amounts due providers under Medicare law and under interpretive guidelines published by CMS. See, 42 U.S.C. 1395h, 42 C.F.R. 413.20 and 413.24. Cost reports are required from providers on an annual basis with reporting periods based on the providers accounting year. Those cost reports show the costs incurred during the fiscal year and the portion of those costs to be allocated to Medicare. 42 C.F.R. 413.20. The fiscal intermediary reviews the cost report, determines the total amount of Medicare reimbursement due the provider and issues the provider a Notice of Program Reimbursement (NPR). 42 C.F.R. 405.1803. A provider dissatisfied with the intermediarys final determination of total reimbursement may file an appeal with the Provider Reimbursement Review Board (Board) within 180 days of the issuance of the NPR. 42 U.S.C. 1395oo(a); 42 C.F.R. 405.1835. In Chassidic practice, especially according to the derech and daas Toirah of Rebbe Nachman of Breslov, or HaRav Ginsburgh of the
Gal Einai School for Jewish Psychology
The Gal Einai School for Jewish Psychology is entering its second year. We teach Jewish psychology based on the

teachings of the Ba'al Shem Tov as developed by Rav Yitzchak Ginsburgh.

Note: We are now accepting applicants for a three year track in Jewish psychology. The required curriculum encompasses courses on the entire structure of the psyche and its treatment based on Kabbalah and Chassidut. Each academic year spans 26 weeks, with one weekly 6 hour meeting. In addition to the regular course of instruction by the school's instructors, mini-seminars will be given by guest therapists and mental health practitioners. Graduates fulfilling all requirements will receive personal certification form Rav Yitzchak Ginsburgh.

Classes are separate for men and women. All instruction is in Hebrew. Lectures offered in both Jerusalem and Tel Aviv.

Fall semester begins October 15, 2007

Courses include:

The Healthy Psyche - Rectifying the Ego Anatomy of the Psyche Kabbalistic Psychology for Mental Illness Faith As the Foundation for Mental Health Balancing the Psyche Shalom Bayit (Family Health and Peace) Kabbalah and Meditation Natural Consciousness Foundations of the Arizal's Kabbalah in Light of Chassidut Relationships in Educational Settings Chassidic Bibliotherapy

For more information (in Hebrew) please contact Rabbi Chaim Nativ, Dean at 02-6310557 or email: .

, it is preferable for Chosidim to receive nonmedical health care from a religious, non-medical health care institution (RNHCI), than from secular organizations and practices unless otherwise halachically and clinically indicated. RNHCIs Interim final and final regulations, 67 FR 67028 and 68 FR 66710, continued the requirement that these facilities meet Medicares Conditions of

Participation, but changed the process by which the facilities were certified to require certification by the Medicare program.

A Sofer scribal arts calligraphy Bibliotherapy nurse education program that is not required to be licensed under State law is considered an approved educational activity for Medicare reimbursement purposes if the program is accredited by the recognized national professional organization for the particular activity. The Commission specifically reviews and accredits nursing education programs operated by RNHCIs. The Commission is the recognized national professional organization that accredits Chassidic Sofer scribal arts calligraphy Bibliotherapy nursing education programs. Accordingly, the Commission meets the regulatory definition of a recognized national professional organization for the particular activity. The plain reading of 42 C.F.R. 413.85(e) indicates only one requirement for the approval of the Providers nursing education programs accreditation by the recognized national professional organization. The Commissions accreditation meets the requirements of the Secretarys regulation. Provider-based nursing education programs must be accredited by an organization with established standards by which to evaluate and measure the performance of the nurse training program. Thus we ask the Board declare that the Commission is a nationally recognized organization within the meaning of 42 C.F.R. 413.85 The Commission is a recognized national professional organization for the particular activity under the provisions of 42 C.F.R. 413.85(e) for purposes of accrediting the Sofer scribal arts calligraphy Bibliotherapy nursing education programs. Respectfully,

Dr. Paul Maas Risenhoover, JD, Doctor of Religious Counseling (and ordained Mumcheh expert in Sefardic Chinuch Guidance and Education, from Rabbi Dr. Stefan DiMauro, MD, President, Maimonides University) Tainan, allied American Formosa trust territory island of Taiwan, Western Pacific, USA