Transcript COMPLIANCE AND THE REVENUE CYCLE

COMPLIANCE AND THE
REVENUE CYCLE –
What Does the Compliance Officer Need
to Understand About the Risks?
PRESENTED BY: TAUNA SHELTON MHSM,MS,CHC
REGIONAL DIRECTOR COMPLIANCE AND PRIVACY
THR
1
REVENUE CYCLE PROCESS
Who is involved in the Revenue Cycle?
Scheduling & Pre-Registration
Registration Verification
Financial Counseling
Charge Capture
Documentation Coding
Bed Control
Billing
Payment Posting
Account Follow-Up
A/R Management
Contracting
Medical Records/ HIM
Case Management
Utilization Review
IT
Clinical Areas
2
EACH DEPARTMENT PROVIDES
OPPORTUNITY FOR ERROR AND
RISK
Scheduling & Pre-Registration:
patient screening for demographic information,
verification of orders, insurance, insurance
approval for OP procedures – will ABN be
needed for Medicare patient because
diagnostic test does not meet medical
necessity?
Registration Verification: verifying
patient identity, insurance card (Is patient the
person presented, or is this a fraudulent use of
identification to obtain services by using
someone else’s insurance card?) (Medicaid /
Medicare), fraud perpetuated via follow up
services? or case of identity theft by patient or
even entity staff ?
3
ERROR OR RISK (cont)
Financial Counseling: financial
screening for self pays or charity care
supported by organizational Charity
Care Policy and state laws
Charge Capture: are the correct
charges for services provided, including
number of charges actually being placed
onto the patient’s account (medications,
procedures) including overcharging,
undercharging, lost charges or charging
for services not provided?
4
ERROR AND RISK (cont)
Documentation Coding: Physician
notes, Nurses notes, ancillary staff notes
supporting the ordered services detailed
enough to provide substantiation to an
auditor ?
Bed Control: placement of patient in
correct bed based upon order timed by
physician, patient transfers?
Billing: billing the correct patient on the
correct account, correct number of
services?
CHARGEMASTER updates for each
service, billing edits loaded, charge capture
issues?
5
ERROR AND RISK (cont)
Payment Posting: payments posted
on correct account, payments applied to
correct account , credit balances on
account worked?
Account Follow-Up: accounts worked
with patient friendly guidelines and
following state collection laws?
A/R Management: as accounts age
are they being worked to resolve credit
balances, bad debt and appropriate
communications with payers?
6
ERROR OR RISK (cont)
Contracting: are payments being
monitored by the CBO and the
Contracting Department for proper
payments based upon the written
contract payment guidelines? are edits
in place for both the entity and the
payer?
Medical Records / HIM: coding by
CCI guidelines, backlog in coding,
increased query of physicians for
confirmation of documentation, quality
self department checks?
7
ERROR AND RISK (cont)
Case Management: are appropriate
InterQual or M&R guidelines used for
placement of patient into appropriate
level of service based upon medical
necessity and severity, observation or
inpatient services required?
Risk Management: high profile cases
being checked for billing and compliance
issues, as well as, the current risk
occurrence issue?
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ERROR OR RISK (cont)
IT: system supporting all needs
of clinical staff, billing staff, HIM
staff – EHR being used, ability
for tracking audit trails?
Clinical Areas: continuous
communication on billing and
charging changes, charge
audits?
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REVENUE CYCLE DRILL DOWN
FOCUS TODAY ON:
NEED FOR POLICIES
CHARGEMASTER
CENTRAL BUSINESS OFFICE and
CREDIT BALANCES
CHANGES TO COME IMPACTING
REVENUE AND OPERATIONS
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SYSTEM / ENTITY POLICIES
SUPPORTING THE REVENUE CYCLE
CHARGE CAPTURE POLICIES provide
guidance for all staff involved in the
revenue cycle who document charges,
input charges, monitor charges or audit
charges
CHARGEMASTER POLICIES provide
guidance for all staff responsible for
requesting new services, new charges or
changes in existing charges with the
addition of the appropriate CPT codes
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POLICIES (cont)
BILLING POLICIES: provide guidance to
all staff associated with billing on how to
handle discrepancies, credit balances, bad
debt, A/R and billing cycle requirements
COMPLIANCE POLICIES: provide
government based guidance to assist all
system / entity staff with concerns of illegal
activities, billing concerns, fraud issues or
simple questions
12
COMPLIANCE BILLING AND
OPERATIONAL LAWS
MEDICARE REQUIREMENTS
MEDICAID REQUIREMENTS
FALSE CLAIMS ACT
STARK LAW
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SIGNIFICANT LAWS GOVERNING
FEDERAL HEALTHCARE PROGRAMS
ANTIKICKBACK STATUTE:
Authorizes criminal and civil penalties
against anyone who knowingly and
willfully solicits, receives, offers, or
pays remuneration, in cash or in kind,
to induce or in return for referrals for
services payable under federal
healthcare programs
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SIGNIFICANT LAWS (cont)
Civil Monetary Penalties Law: Holds a
person or entity subject to penalties for
submitting a false claim or a claim that
should have been known to be false,
allows a penalty of up to $10,000 for each
service or item falsely or fraudulently
claimed and an assessment of up to three
times the amount claimed and potential
exclusion from the federal healthcare
program or programs
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SIGNIFICANT LAWS (cont)
False Claims Act: Holds a person or entity
liable for up to treble damages and up to
$11,000 for each false claim it submits or
causes to be submitted to a federal
healthcare program, does not require a
specific intent to defraud and includes a
provision for Qui Tam or whistleblower
suits, which allow individuals to file suit on
behalf of the U.S. government
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SIGNIFICANT LAWS (cont)
Health Insurance Portability and
Accountability Act of 1996:
Addresses use and disclosure of
individuals’ health information
(protected health information) by
hospitals and other covered entities;
includes standards for individuals’
privacy rights and how their health
information is used.
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SIGNIFICANT LAWS (cont)
Physician self-referral law (Stark Law):
Prohibits hospitals from submitting to
Medicare any claim for designated health
service if the referral of the DHS is
generated by a physician who has a
prohibited financial relationship with the
hospital. Hospitals and physicians who
violate the Stark law are subject to civil
monetary penalties and exclusion from
federal healthcare programs
18
STARK III UPDATE
On September 5, 2007 CMS issued final
regulation outlining the third phase of regulations
prohibiting physician self-referral. This prohibits
physicians from referring Medicare patients for
certain items, services and tests provided by
businesses in which they or their immediate family
members have a financial interest. This regulation
is the third part of the final regulations
implementing the physician self-referral prohibition
commonly referred to as the Stark law taking effect
on December 4, 2007
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STARK III (cont)
Redefines arrangements between hospitals
and individual members of group medical
practices as “direct” rather than “indirect”
compensation; eliminates the “safe harbor”
methodology for calculating fair market
value for hourly physician service; and
create additional flexibility for rural
hospitals in recruiting and retaining
physicians. This rule makes no changes to
the in-office ancillary services exemption,
but cites this area as a possible target for
future rulemaking.
20
PATIENT FINANCIAL SERVICES
BILLING LAWS
BILLING CYCLE
EDITS
BAD DEBT
CREDIT BALANCES
CHARITY CARE
WRITE OFFS
21
Financial Risks Associated with
Credit Balances
FRAUD
WASTED MAN-HOURS AND
PROCESSING COSTS
MIS-STATED PROFIT
LOST BILLING OPPORTUNITIES
MEDICARE PENALTIES
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CAUSES OF CREDIT BALANCES
Mis-posted allowances – incorrect
estimates of cash amounts due
Duplicate payments
Charge credits subsequent to billing
Full payments by both primary and
secondary insurers
Up-front collections – incorrect
estimates of patient liability
23
STATS ON HOSPITAL
RESOLUTION
Most credit balances are not the result of
overpayments
One third resolved result in a refund to
patient or payer
One half are mis-posted allowances that
need to be reversed on the PA system and
don’t require refunds
Payer contracts can result in incorrect rates
and terms loaded into the hospital system
– these create understatements of a
hospital’s profitability and AR
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ADDITIONAL SOURCES OF
ERRORS
Errors occur when a claim is paid twice by
a payer
Problems created by manual errors,
system errors or a combination of both
Results of better point-of-service
collections – better up-front collections
create higher volume for credit balances
Over-estimates of what is owed in a
Managed Care environment
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RISKS OF CREDIT BALANCES
Real risks posed by :
Medicare penalties
Wasted time
Lost payment opportunities
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MEDICARE PENALTIES
Suspension of Medicare payments caused
by non-compliance with federal regulations
concerning credit balances
Fines
Imprisonment
CMS requires hospitals report all Medicare
credit balance overpayment accounts
quarterly using form CMS-838, which must
be signed and attested to by an officer of
the hospital, specifically by the CFO or
CEO.
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MEDICARE PENALTIES (cont.)
Documentation must be maintained that shows
that each patient record with a credit balance was
reviewed to determine if any credit balances are
attributable to Medicare
Most hospitals do not have an effective means to
ensure compliance which means several credit
balance accounts can be present
Risky for the CFO because after signing the
Medicare Credit Balance Report, he/she is
attesting to the fact that all of the hospital’s credits
have been reviewed
Credit balances are NOT a profit center!
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LOST BILLING OPPORTUNITIES
Once accounts are analyzed and adjusted,
billing opportunities to generate additional
cash receipts are often revealed
Amounts due from payers and patients
have been hidden by the credit balances
Failure to analyze credit balances in a
timely fashion can result in permanent lost
cash
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FRAUD
High volume of refund checks issued by large
hospitals to patients, insurance companies and
vendors make it impossible for controllers to
scrutinize & verify each refund
Because refund checks pass through many hands,
they can end up in the hands of the originator of
the request
Credit balances and the refund processes are ripe
for fraudulent activity – making hospitals exposed
to financial losses and corporate embarrassment
Refund checks can be misappropriated because
of weak internal controls and because the
intended receiving parties are not aware that they
are due a refund check
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NEGATIVE PRESS
Unresolved credit balances can
trigger management letter comments
to a hospital’s board of directors
noting items of concern
Credit balances understate an
organization’s profit and the AR
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COMMON MISCONCEPTIONS
Setting high dollar thresholds for account
management creates a time-bomb effect…leaving
a growing number of smaller balance credits
Hospital is forced to allocate staff to resolve the
smaller credit balance accounts creating work
pressure in PA
Vendor credit balance auditors are paid by
commercial insurers to recover overpayments but
only 1/3 of the accounts are commercial, largest
percentage of credit balance accounts are
government and patients
32
Required Reporting of Medicare
Overpayments CMS 838 Form
Providers must submit Quarterly Reports
detailing all Medicare overpayments
CFO must sign the report attesting to the
completeness and accuracy of the data
Failure to comply may result in:
Financial penalties that include interest and
fines/treble damages
Criminal penalties
Compliance is monitored as part of the cost
report auditing process
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COMPLIANCE SOLUTIONS
To reduce risk and improve cash flow:
Processes established to ensure
compliance with Medicare requirements
for refunding credit balances and filing
the CMS-838
Determine total dollar amount and
volume of credit balances
Determine volume of new credit
balances created on a weekly basis to
determine risk
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COMPLIANCE SOLUTIONS
Determine thresholds allowed for credit balance
levels based on total dollar and total volume of
accounts (2 days of a hospital’s revenue)
Review current processes
Automate manual processes
Monitor unresolved Medicare credits
Minimize fraud potential and issuance of refund
checks by using payers’ processes and systems
that allow reporting overpaid accounts – insist on
voucher recoveries by the payer
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COMPLIANCE AREAS OF
CONCERN
Registration: fraudulent use of identifications to
obtain services / ID Theft by patients or even entity
staff
Insurance verification: patient using another
patient’s Medicare number
Charge Capture: overcharging / charging for
services not provided, lost charges
Billing Errors: Duplicate billing
Observation or IP : Medicare and Medicaid
correct status
Charity Care: evaluations for medical assistance
eligibility
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MEDICAID AUDITS:
STATE
MEDICAID FRAUD CONTROL UNITS
(MFCU)
For fiscal year 2006, from October 1, 2005 and
ending September 30 2006, the MFCU received
more than $1.1 billion in court ordered restitution,
fines, civil settlements, and penalties. They also
obtained 1,226 convictions in FY 2006.
MFCUs reported 676 instances in which civil
actions were taken with successful outcomes.
Of 3,425 OIG exclusions from participation in
Medicare and Medicaid programs, 731 exclusions
were based on referrals made to OIG by the
MFCUs.
SOURCE: State Medicaid Fraud Control Units
Annual Report, Fiscal Year 2006
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EXAMPLE IN TEXAS
In Texas, a physical therapy clinic operator was
sentenced to 51 months in prison and ordered to
pay $1.32 million in restitution for conspiracy to
commit wire fraud and health care fraud. She and
her partner billed the Medicare and Medicaid
programs for services not rendered and billed for
physical therapy services as if they were
performed or supervised by a licensed physician.
The investigation revealed that the defendants
hired unlicensed foreign medical graduates to
perform the services of a licensed physician. The
investigation involved OIG, the Texas MFCU, and
the FBI.
SOURCE: OIG Semi-Annual Report for First Half of 2007
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KEY COMPLIANCE AND
REVENUE CYCLE METRICS
PATIENT ACCESS QUALITY:
Physician authorization compliance:
96-98%
Inpatient admissions error ratio:
<1-2%
Outpatient registration error ratio:
<1-2%
% Pre-registered IP accounts: 40-50%
% Pre-registered OP accounts: 25-30%
HFMA Benchmarks
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KEY COMPLIANCE AND
REVENUE CYCLE METRICS
CASE MANAGEMENT QUALITY
Payer acceptance of clinical treatment
plan based on authorization: 95-97%
acceptance
Clinical denials overturn rate: 95%
HFMA Benchmarks
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KEY COMPLIANCE AND
REVENUE CYCLE METRICS
HEALTH INFORMATION
MANAGEMENT QUALITY
DNFB (discharged not final billed) and
HIM bill holds
Awaiting coding: <0.5 day in A/R
Awaiting dictation: <0.5 day in A/R
Charge capture quality: 98% compliance
HFMA Benchmarks
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KEY COMPLIANCE AND
REVENUE CYCLE METRICS
PFS/PATIENT ACCOUNTING QUALITY
Gross Days Receivable Outstanding:
< 52 days outstanding
% A/R over 90 days: 17-20%
% A/R over 120 days: 10-12%
% A/R over 1 year: < 2%
Credit Balance A/R: < 1 A/R day
Billing turnaround: 5 days from DOS or
discharge
HFMA Benchmarks
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KEY COMPLIANCE AND
REVENUE CYCLE METRICS
ALL REVENUE CYCLE
DEPARTMENTS NET REVENUE
EXPOSURE
Denial overturn ratio: 95-98%
Underpayments overturn ratio: 95-98%
Bad debt expense as % of gross
revenue: < 2.5%
Bad debt expense as % of net revenue:
< 2-3%
HFMA Benchmarks
43
CHARGEMASTER UPDATES
The CHARGEMASTER is a computer file
that contains all the charges that a hospital
makes. It is the link between services
provided and the generation of claims and
billings.
Key elements to review in a hospital
CHARGEMASTER are: invalid or
inaccurate CPT/HCPCS codes, invalid or
inaccurate revenue center codes,
inadequately defined procedures and tests,
appropriateness of bundled CPT/HCPCS
codes, and validity of service.
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CHARGEMASTER UPDATES
Must have an on-going CHARGEMASTER
review since the factors that go into the
CHARGEMASTER are constantly
changing, including the annual updates of
CPT/HCPCS codes, changes in
reimbursement guidelines and advances in
technology.
SOURCE: HFMA Compliance Checklist for
Hospitals, Revised June 2002
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NEW CMS CHANGES IMPACTING
COMPLIANCE AND REVENUE
start date 10/1/2007 is defined
as present at the time the order for inpatient admission
occurs – conditions that develop during an outpatient
encounter, including emergency department, observation, or
outpatient surgery, are considered as present on admission.
Purpose is to distinguish between pre-existing conditions
and complications.
All claims involving inpatient admissions to general acute
care hospitals or other facilities that are subject to a law or
regulation mandating collections of present on admission
information
POA indicator is assigned to principal and secondary
diagnoses and the external cause of industry codes
Issues related to inconsistent, missing, conflicting or unclear
documentation must still be resolved by the provider.
PRESENT ON ADMISSION (POA)
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POA AFFECTS PAYMENTS
Starting 10/1/2007, CMS reduces
payments in some cases when the
patient acquires an infection (or other
condition) during a hospital stay.
Will not assign higher paying DRG to
patients who have /suffer from the 8
conditions, unless they are
documented as present on admission:
47
EIGHT POA’s NOT ASSIGNED TO
HIGHER DRGs
Serious preventable event – object
left in during surgery
Serious preventable event – air
embolism
Serious preventable event – blood
incompatibility
Catheter associated urinary tract
infections
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EIGHT POA’s (cont)
Pressure ulcers (decubitus ulcers)
Vascular catheter – associated
infection
Surgical site infection – mediastinitis
after coronary artery bypass graft
(CABG)
Falls
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POA (cont)
MULTIDISCIPLINARY EFFORT
HIM department / Coding professionals
Finance
Physicians
Quality department
Risk Management
Compliance
Support from Administration
Vendor readiness
50
SEVERITY ADJUSTED DRGs
CMS finalized the inpatient
prospective payment system (IPPS)
rule which forces hospitals to
understand Medicare’s new approach
to reporting complications and
comorbidities (CCs) and determining
what combination of primary and
secondary diagnoses gets the most
favorable reimbursement while
remaining compliant
51
MS-DRGs
The final rule has 745 “Medicare
Severity DRGs” (MS-DRGs) that
replace 538 existing DRGs.
Severity adjusted DRGs are better
designed to capture the extent of the
patient’s illness and complications.
There is a third category to describe
the relative intensity of a patient’s
illness.
52
MS-DRGs
Before the final rule, there was simply the
absence or presence of CCs. CMS has
added a new category to describe the most
severe secondary diagnoses: major CCs
(MCCs)
The best reimbursement scenario will be
unclear to a hospital in any given case
when a patient presents with two or more
diagnoses that meet the definition of
“principal diagnosis”
53
MS-DRGs
Hospital coders will be required to analyze
sequencing to protect the hospital’s bottom
line because the principal diagnosis
dictates the DRG and when there are two
or more diagnoses that meet criteria for
principal, Medicare allows hospitals to bill
whichever it chooses.
Hospitals must ensure both diagnoses
were present on admission, drove the
admission and were treated or evaluated.
54
MS-DRGs
Compliance Officers should use case mix
index (CMI) to monitor how well their
hospitals are doing with documentation of
changes.
If the CMI flies above or below what it is
now, consider why.
Urban hospitals should expect CMI
increases because they generally take
care of sicker, more complex cases / that is
what the severity adjusted DRG system is
designed to recognize
55
MS-DRGs
CMS states payments under the new DRG system
are expected to rise in fiscal year 2008 by about
3.5% “when all provisions of the rule are taken into
account, primarily as a result of the 3.3% market
basket increase”…CMS
Independent of Medicare reimbursement changes,
the final IPPS rule has built-in payment reductions
to account for what CMS considers to be the way
hospitals adapt coding and documentation to
capture severity of illness and thus get paid more
under MS-DRGs and because CMS views the
hospitals to be seeing sicker patients
56
MS-DRGs
CMS has stated “We do not believe
there is anything inappropriate,
unethical or otherwise wrong doing
with hospitals taking full advantage of
coding opportunities to maximize
Medicare payment that is supported
by documentation in the medical
record”
57
FUTURE: FY08 IPPS FINAL RULE
The FY08 Inpatient PPS final rule
includes a full market basket (MB)
update:
Increase of 3.3% effective October 1,
2007, for Inpatient PPS hospitals
providing quality data
MB 2.0% or 1.3% for those not
submitting data
58
Impact of the Final Rule’s Changes
The change in payment per case
for hospitals in FY 2008 is
estimated to average a 3.5%
increase, estimated by modeling
those changes shown in Table I –
Impact Analysis of Changes for
FY 2008.
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IMPACT ANALYSIS OF CHANGES
Table I:
Geographic
Location
Average FY07
Pmt Per Case in
Dollars
Average FY08
Pmt Per Case in
Dollars
Percent Change
Urban
hospitals
9,304
9,663
3.9%
Large urban
areas
9,702
10,122
4.3%
Other urban
areas
8,826
9,110
3.2%
Rural hospitals
6,993
7,081
1.2%
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Updates to Inpatient Rates
The CMS impact analysis of the final rule’s
changes attempts to account for:
The effects of the reclassification of diagnoses
and procedures and the proposed recalibration
of the DRG relative weights required by Section
1886(d)(4)(C) of the Social Security Act
Effects of changes in wage index values
Effects of wage and recalibration budget
neutrality factors
61
Changes to Inpatient PPS DRG
Weights
The final rule continues the 2-year
transition to weighting DRGs on the
basis of cost.
For FY 2008: two thirds on cost; one
third on charges
62
Changes to DRGs
The adopted “Medicare severity”
adjusted DRGs (MS-DRGs)
Are based on the current CMS DRGs
Increase the number of DRGs from 538
to 745
63
Changes to DRGs
MS-DRGs split some current DRGs
based on
MCCs – major complications or
comorbidities
CCs – complications or comorbidities
No CCs
64
Changes to DRGs
Factors in dividing DRGs:
Variance of charges of at least 3%
At least 5% of patients in the MS-DRG are
falling within the CC or MCC subgroup
At least 500 cases are in the CC or MCC
subgroup
There is at least a 20% difference in
average charges between subgroups
There is at least $4,000 difference in
average charges between subgroups
65
Changes to DRGs
Redistribute case mix
Have a negative impact on rural hospitals,
but CMS expects an offset to some degree
from weighting on cost
Necessitate (CMS says) an offset of 1.2%
in FY08 and 1.8% in FYs 2009 and 2010,
for case mix improvement attributable to
coding and documentation
66
Changes to DRGs
MS-DRGs affect the Postacute Care
Transfer Policy
273 of 745 MS-DRGs will be subject to the post
acute care policy
For qualifying stays, hospitals will be paid 50%
of the total inpatient PPS payment plus the
average per diem for the first day of the stay
Fifty percent of the per diem amount will be
paid for each subsequent day of the stay, up to
the full MS-DRG payment amount
Includes MS-DRGs that share a base MS-DRG
67
Changes in the LTC-DRG
Classifications
The LTCH PPS updates to the LTCDRGs
(MS-LTC-DRGs) will be included with
the IPPS and effective for discharges
occurring on or after October 1, 2008
and through September 30, 2009
68
Outliers
The fixed loss cost outlier
threshold for FY08 is $22,650
(down from the current $24,485)
69
New Services and Technologies
Add-On Payments (cont.)
Add-on payments will not continue
in FY08 for the new services and
technology recognized in FY07
70
Recalled/No Cost/
Partial Credit Devices
The FY08 final rule expands the 2007
outpatient PPS final rule to pay a hospital
less when a device is provided at no cost
CMS will apply the policy when the hospital
receives a credit equal to 50% or more of
the cost of the device
Hospitals will identify replacement devices;
CMS will reduce the DRG payment to
reflect the hospital’s lower cost
71
Hospital Acquired Conditions
Section 501(c) of the DRA requires
hospitals to begin reporting on October
1, 2007, at least two secondary
diagnoses that are present on the
admission (POA) of patients
Beginning October 1, 2008, the two
selected conditions will not be
assigned to a higher paying DRG
unless they were present on admission
72
Physician-Owned Facilities
The rule includes provisions for more
transparency by physician-owned
facilities and their physician owners
73
FUTURE OPPS PROPOSAL FOR
2008
Medicare’s 2008 OPPS rule updates
the conversion factor by 3.3% but
also forces entities to be more
efficient by reducing the ability to bill
for additional, individual services
74
2008 OPPS Proposed (cont)
Other proposed provisions:
No separate payment for observation
Ten outpatient quality of care measures
ASC payment system revised
Discounted device payments when
manufacturer gives entity partial credit
End to billing for consults
75
CONCLUSIONS:
REDUCING COMPLIANCE RISK and REVENUE
CYCLE RISK will be more challenging and require
increased system / entity policy audits
INCREASING REVENUE will require more
detailed documentation from all who are members
of the REVENUE CYCLE and require more
Access Services, Medical Management, CBO,
Charge, Billing, Denial and process audits on a
continuous basis
MANAGING COMPLIANCE RISK surrounding the
REVENUE CYCLE will require a willing MULTIDISCIPLINARY TEAM with system and process
improvement thinking who are not fearful of
making changes
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RESEARCH SOURCES:
HFMA: www.hfma.org, Revenue Cycle file
TWCC: This Week in Corporate Compliance
STATE MEDICAID FRAUD CONTROL UNITS
ANNUAL REPORT FY 2006
MEDICARE COMPLIANCE, VOL 16, NUMBER
32, SEPT. 10, 2007
APC PAYMENT INSIDER, VOL. 9, NO. 8, 8/07
THIS WEEK FROM SG2 9/3/2007
Also: School of Hard Knocks
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