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Can we clarify the annual in depth review requirement, as the year has 365 days and creates tracking problems with the 90 day update requirements?

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Can we clarify the annual in depth review requirement, as the year has 365 days and creates tracking problems with the 90 day update requirements?

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We would urge providers to consider tracking annual reviews every 360 days and set the date 360 days from the last annual review. Thus, providers are able to plan and track the annual due date and will complete 90 day review within that timeframe. Examples:If reviews are completed on an exact 90 day timeframe: Annual ISP completed 01/20/06…next annual review due 01/15/07 90 day due 4/20/06 90 day due 07/19/06 90 day due 10/17/06 Annual due 01/15/07…If one review is done late: Annual ISP completed 01/20/06…next annual review due 01/15/07 90 day review due 4/20/06 90 day review due 7/19/06 90 day review due 10/17/06..completed 10/25/06 (eight days late) Annual review still due 01/15/07..and next review due 90 days from 01/15/07…..

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