Problems Remain For Ensuring That All High Risk Medicaid Providers .
U.S. Department of Health and Human ServicesOffice of Inspector GeneralProblems Remainfor Ensuring ThatAll High-RiskMedicaid ProvidersUndergo CriminalBackground ChecksOEI-05-18-00070July 2019oig.hhs.govSuzanne MurrinDeputy Inspector General forEvaluation and Inspections
Report in BriefJuly 2019OEI-05-18-00070U.S. Department of Health and Human ServicesOffice of Inspector GeneralProblems Remain for Ensuring That AllHigh-Risk Medicaid Providers UndergoCriminal Background ChecksWhat OIG FoundKey TakeawayWe found flaws with States’ implementationMedicaid is still vulnerableof fingerprint-based criminal backgroundto being defrauded bychecks for high-risk Medicaid providers.high-risk providers thatEighteen States missed the implementationwere not properly screened.deadline that the Centers for Medicare &Medicaid Services (CMS) had set, and 13 ofthose 18 States had not implemented these checks as of January 1, 2019.Unscrupulous providers could exploit two loopholes in the provider enrollmentprocess to enroll in Medicaid without undergoing these checks. The firstloophole involves CMS’s allowing States to—in certain circumstances—forgoconducting these checks for high-risk providers that Medicare has alreadyenrolled, even though Medicare has not conducted checks on some providers.The second loophole involves States’ reliance on providers to accurately reporttheir ownership information.Thirteen States had not implemented criminal background checks.Why OIG Did This ReviewAn effective provider enrollmentscreening process is an important toolfor preventing Medicaid fraud. Itplays a vital role in identifyingunscrupulous providers andpreventing them from enrolling inMedicaid. The Federal Governmentrequires States to conduct risk-basedscreening activities as part of theirprocesses for enrolling providers inMedicaid. The Office of InspectorGeneral’s (OIG) evaluation of theMedicaid provider enrollmentscreening process in 2016 found thatStates were struggling to implementthe required screening activities.Many States had yet to implementfingerprint-based criminalbackground checks—a screeningactivity required for providers thatthe Federal Government deems to beat high risk for fraud, waste, andabuse.If not all high-risk providers undergocriminal backgroundchecks, the Federal and StateGovernments are vulnerable tounscrupulous providers intent ondefrauding the Medicaid program.How OIG Did This ReviewSource: OIG analysis of State survey and interview responses, 2019.What OIG Recommends and How the Agency RespondedWe recommend that CMS (1) ensure that all States fully implementfingerprint-based criminal background checks for high-risk Medicaid providers,(2) amend its guidance so that States cannot forgo conducting criminalbackground checks on high-risk providers applying for Medicaid that havealready enrolled in Medicare unless Medicare has conducted the checks, and(3) compare high-risk Medicaid providers’ self-reported ownership informationto Medicare’s provider ownership information to help States identifydiscrepancies. CMS concurred with the first recommendation. CMS did notconcur with the second and third recommendations.Full report can be found at oig.hhs.gov/oei/reports/oei-05-18-00070.aspWe based this study on data fromthree sources: (1) a survey of 50 Statesand the District of Columbia (States)requesting information on theirimplementation of criminalbackground checks andthe challenges they faced;(2) interviews with officials from 14 ofthe 18 States that had notimplemented criminal backgroundchecks by CMS’s July 2018 deadlinefor implementing this requirement;and (3) an interview with officials fromCMS.
TABLE OF CONTENTSBACKGROUNDMethodology15FINDINGSThirteen States had not implemented fingerprint-based criminal background checks forhigh-risk Medicaid providers as of January 20196Loopholes enable high-risk providers to enroll in Medicaid without undergoing criminalbackground checks9CONCLUSION AND RECOMMENDATIONSEnsure that all States fully implement fingerprint-based criminal background checks forhigh-risk Medicaid providers12Amend its guidance so that States cannot forgo conducting criminal background checks onhigh-risk providers applying to Medicaid that have already enrolled in Medicare unlessMedicare has conducted the checks13Compare high-risk Medicaid providers’ self-reported ownership information to Medicare’sprovider ownership information to help States identify discrepancies13AGENCY COMMENTS AND OIG RESPONSE15APPENDICESA: Detailed Methodology17B. Agency Comments20ACKNOWLEDGMENTS23
BACKGROUNDObjectives1.To determine the extent to which States have implementedfingerprint-based criminal background checks for high-riskproviders in Medicaid, and2. To describe the remaining challenges to the implementation ofcriminal background checks in Medicaid.An effective provider enrollment screening process is an important tool forpreventing Medicaid fraud. To protect Medicaid against fraudulent andabusive providers, Federal laws require that States screen Medicaidproviders according to the risk that the providers pose of committing fraud,waste, or abuse.1 , 2 State Medicaid agencies conduct risk-based screeningactivities for all providers at the time of enrollment and periodicallythroughout providers’ enrollment in Medicaid.3 If States do not fullyimplement provider enrollment screening activities, Medicaid is at increasedrisk of enrolling fraudulent or abusive providers.In 2016, the Office of Inspector General (OIG) found that many Statesstruggled to implement the screening activities that the FederalGovernment requires them to perform as part of the Medicaid providerenrollment process. Specifically, OIG found that 37 of the 47 Statessurveyed had not yet implemented fingerprint-based criminal backgroundchecks, a screening activity that Federal rules require for all providersdeemed to be high-risk.4 Because criminal background checks are requiredfor screening only the riskiest providers, full implementation of these checksis vital to safeguarding the Medicaid program. This report providesinformation on the progress that States have made in implementingcriminal background checks since OIG’s 2016 review.Screening requirements for Medicaid provider enrollmentFor the purposes of Medicaid provider enrollment, States must assignproviders to one of three risk categories: high-risk, moderate-risk, orlimited-risk. The screening activities that States must conduct varyaccording to the risk category to which a provider is assigned. For allproviders, States must verify licenses and any provider-specific requirementsas well as conduct checks of numerous databases. States also mustconduct a site visit for any high-risk or moderate-risk provider, anda criminal background check for any high-risk provider.5 Federal rulesrequire that States conduct fingerprint-based criminal background checksbecause fingerprints—as uniquely personal identifying information—areProblems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000701
necessary for complete access to criminal history records held by Statecriminal history repositories and the Federal Bureau of Investigation.6, 7CMS guidance on implementing criminal background checksThe Centers for Medicare & Medicaid Services (CMS) has provided guidanceto States as to which provider types States must consider high-risk,although States may classify additional provider types as high-risk at theirdiscretion. For provider types that exist both in Medicare and Medicaid,CMS requires States to use either the same risk level that Medicare assigns,or a higher level.8, 9 Accordingly, State Medicaid agencies must classify ashigh-risk (1) newly enrolling home health agencies (HHAs) and (2) newlyenrolling suppliers of durable medical equipment, prosthetics, orthotics, andsupplies (DMEPOS), because CMS considers these provider types assusceptible to engaging in fraud, waste, and abuse.10In addition to screening newly enrolling HHAs and newly enrolling DMEPOSsuppliers as high-risk, States must also screen as high-risk some providersthat are already enrolled in Medicaid. States must retroactively screen ashigh-risk any HHAs and DMEPOS suppliers that they enrolled betweenAugust 2015—when CMS required States to begin implementing criminalbackground checks—and when their respective State processes for criminalbackground checks became operational.11 For the purposes of this report,OIG refers to providers that States must retroactively screen as “lookbackproviders.” States must also screen as high-risk any providers with existingoverpayments or payment suspensions.12 All of these providers mustundergo criminal background checks.Finally, CMS has provided guidance to States as to which individualsassociated with high-risk providers must undergo criminal backgroundchecks. Any person with 5 percent or more direct or indirect ownershipinterest in a high-risk provider must undergo a criminal background check.13Providers must disclose all individuals with an “ownership or controlinterest” when submitting their applications for Medicaid enrollment.14 Theymust also report any changes in ownership that occur after Medicaid enrollsthem.15According to CMS guidance, “implementation” of criminal backgroundchecks for high-risk providers means that a State has conducted criminalbackground checks on each high-risk provider and owner. Specifically, CMSstated the following: “Implementation means that the State Medicaidagency has conducted [a fingerprint-based criminal background check] withrespect to each provider that the agency has designated as ‘high’ risk.”16CMS monitoring of States’ implementation of criminal backgroundchecksCMS ultimately required States to implement criminal background checksfor high-risk providers in 2018. CMS’s initial deadline for implementationwas June 2016, but—because of feedback from States to CMS on theirProblems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000702
difficulties in implementing this requirement—CMS delayed the deadlineuntil July 2017 and then again until July 1, 2018.17 When CMS extendedthe deadline the second time in 2017, as many as 40 States had yet toimplement criminal background checks.18One tool that CMS uses to monitor State compliance with the Medicaidprovider enrollment requirements is the Payment Error Rate Measurement(PERM) program. CMS uses the PERM program to measure improperpayments on a sample of Medicaid claims for 17 different States every year,with CMS reviewing each State once every 3 years.19, 20 The PERM programmay identify as improper any sampled claims that States paid in error andany sampled claims that did not meet all requirements, includingthe requirements for Medicaid provider enrollment.21 Importantly, withina single year, the PERM program identifies only improper paymentsthat 17 States made to providers that are within the sample of claims.After July 1, 2018, the PERM program began reviewing whether providerswithin the sample of claims had undergone criminal background checks.22The PERM program may identify as overpayments any payments withinthe sample that States made to providers that had not undergone criminalbackground checks.23 States must return to CMS the Federal portion ofoverpayments.24 The first PERM review that could include findings onStates’ implementation of criminal background checks would be in 2020.25Steps for implementing criminal background checksTo implement criminal background checks at the State level, States shouldcomplete the steps in Exhibit 1, below.26Exhibit 1: States should complete these steps to implement criminalbackground checks.Source: OIG review of CMS, 2016 Sub Regulatory Guidance on Fingerprint-based Criminal BackgroundChecks and the Medicaid Provider Enrollment Compendium, 2018.27Problems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000703
Implementing criminal background checks at the State level entails somepreliminary work by States. States may need to do some or allof the following: pass State legislation,determine the criminal convictions and histories that willdisqualify a provider from enrolling in Medicaid,28, 29 anddevelop a system for submitting fingerprints to State lawenforcement and obtaining the results of criminal backgroundchecks.Criminal background checks on providers enrolled in MedicareTo help States achieve implementation and to reduce the administrativeburden on States and on providers, CMS permits States to simplifythe enrollment process for high-risk providers that Medicare has alreadyenrolled.30, 31 For providers enrolled in Medicare, CMS permits States to relyon Medicare’s enrollment screening results instead of duplicating thecriminal background check at the State level. However, in certaincircumstances, CMS permits States to forgo conducting the criminalbackground check on high-risk providers enrolled in Medicare, regardless ofwhether Medicare’s enrollment records show a result for the backgroundcheck.32, 33 This means that States can forgo conducting a criminalbackground check for a high-risk provider that is already enrolled inMedicare, even when Medicare has not yet conducted a background checkfor that provider.34Related OIG workThis report builds on OIG’s extensive body of work on provider enrollment.Although enhancements to the provider enrollment screening process havestrengthened Medicaid program integrity, OIG has found that outstandingvulnerabilities have persisted. In 2013, OIG found that CMS’s system for Medicare enrollment datawas incomplete and often inaccurate.35In 2016, OIG found that implementation of enhanced screeningactivities for provider enrollment in Medicaid and Medicare—including site visits and criminal background checks—wasincomplete.36, 37In 2016, OIG found that CMS’s data and State Medicaid agencies’data on provider ownership—recorded for provider enrollment—often did not match.38, 39In 2016, OIG found that 43 State Medicaid agencies did not collectall ownership information and 33 States did not verify the accuracyof ownership information.40Since OIG’s 2016 work on provider enrollment, CMS has taken several stepsto assist States in implementing criminal background checks in Medicaid.Specifically, CMS has provided updated guidance, technical assistance, andProblems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000704
training, and has offered onsite visits to review procedures. However, CMShas not fully implemented any of OIG’s recommendations fromthe 2016 report on Medicaid provider enrollment.41 Further, CMS has notimplemented one recommendation from OIG’s 2016 report on providerownership information: the recommendation for it to require State Medicaidprograms to verify the completeness and accuracy of the ownershipinformation that providers self-report.42MethodologyFor this status update, we collected and analyzed information from CMS,all 50 States, and the District of Columbia. We included all States andthe District of Columbia in our study to ensure that we had the most currentstatus on States’ implementation of criminal background checks andthe most up-to-date information about States’ challenges withimplementation. The data for this study came from three sources: a surveyto which 48 States responded; followup emails to the subset of States thathad not implemented the checks at the time of our survey (May 2018), andstructured interviews with 14 of the 18 States that had not implementedthe checks by the deadline for them to do so (July 2018). We conductedone final round of followup in December 2018 to update States’implementation status as of January 1, 2019. We also conducteda structured interview with CMS in July 2018.Appendix A provides a detailed methodology.StandardsWe conducted this study in accordance with the Quality Standards forInspection and Evaluation issued by the Council of the Inspectors General onIntegrity and Efficiency.Problems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000705
FINDINGSThirteen States hadnot implementedfingerprint-basedcriminal backgroundchecks for high-riskMedicaid providersas of January 2019Not all States have implemented fingerprint-based criminal backgroundchecks for high-risk providers in Medicaid. As of July 1, 2018—CMS’sultimate deadline for implementation—18 States reported that they had notimplemented these checks. By January 1, 2019, 5 of those 18 States hadimplemented criminal background checks, but the other 13 States had not.43Further, three States did not report their implementation status to OIGdespite several OIG attempts to obtain this information, and theirimplementation status is unknown.44After the July 2018 deadline for States to implement the requiredbackground checks, CMS could consider as overpayments any paymentsthat States have made to high-risk providers that had not undergonea criminal background check.45, 46 States must return to CMS the Federalshare of overpayments related to noncompliance with provider enrollmentrequirements, including the requirements related to criminal backgroundchecks.47 For each State’s specific status, see Exhibit 2, below.Exhibit 2: Thirteen States had yet to fully implement criminalbackground checks as of January 1, 2019Source: OIG analysis of State survey and interview responses, 2019.The 13 States that had not implemented criminal background checks byJanuary 1, 2019, varied as to when they anticipated implementing them.Nine States reported that they anticipated doing so by the end of 2019,one State reported that it anticipated doing so in 2020, and three Statesreported that they did not know when they would implement the checks.Problems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000706
The 13 States that had not implemented the checks by January 1, 2019, alsovaried as to the progress they had made toward full implementation.Five of the 13 States had not collected fingerprints from any of theirproviders. The remaining eight States had conducted criminal backgroundchecks for at least some of their high-risk providers. For more detailsregarding States’ progress toward implementation, see Exhibit 3, below.Exhibit 3: Five States had not collected fingerprints, and eight Stateshad not completed all required steps for implementation.Source: OIG analysis of State survey and interview responses, 2018.Startup challenges had prevented five States from collectingfingerprintsThe five States that had not collected fingerprints reported that they hadnot done so because they faced startup challenges. The most commonchallenges that these five States reported included lack of authority; lack ofresources; and delays in determining which criminal convictions andhistories should disqualify providers from enrolling in Medicaid. Thesestartup challenges prevented States from collecting fingerprints from theirhigh-risk providers.Challenge 1: Lack of authority at the State level. Three of the five Statesreported that they needed executive or legislative authority before theycould collect fingerprints. In one case, the State’s Governor would not grantthe necessary authority, preventing the State Medicaid agency fromcollecting fingerprints from providers. In another case, the State was unableto proceed because State law enforcement could not collect and processfingerprints for Medicaid providers without State legislation.Problems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000707
Lack of authority also hindered these States in obtaining money forfingerprint collection and processing. These States reported that to achieveimplementation, they needed to hire new staff or contractors, and to makethose hires, they needed legislation. For example, one State’s staff reportedthat CMS had authorized funding for the State to implement criminalbackground checks, but the funding had been intended as matchingfunding and the State contribution did not yet exist because it requiredlegislation.Challenge 2: Lack of resources. One of the five States indicated that a lackof resources delayed or stopped it from developing a State process tocollect fingerprints. This State reported that it did not have enough staff toimplement criminal background checks.Challenge 3: Delays in determining disqualifying criminal histories. Oneof the five States had not collected fingerprints because of delays indetermining which criminal convictions and histories should disqualifyproviders from enrolling in the State’s Medicaid program. Before States canevaluate the results of providers’ criminal background checks and makeenrollment determinations, they must first establish criteria for disqualifyingcriminal convictions and histories.48 According to staff in this State, providerconcerns about beneficiary access to care forced the State to revise itscriteria, causing this delay.The eight remaining States had moved beyond the startup phase,but they had not completed all required steps for implementingcriminal background checksEight States had completed the required steps for implementing criminalbackground checks for some providers, but not all providers. In general,these States varied in the extent of their implementation. Some States hadproviders that still needed to submit fingerprints, while others had nearlyfinished implementing criminal background checks but did not have resultsfor some providers.Two of the eight States faced residual delays resulting from lack ofresources and lack of authority. One State—initially delayed because itlacked the necessary authority—had collected fingerprints from its providersbut had not received criminal background check results from the FederalBureau of Investigation for some providers. Another State reported that ithad notified providers and had begun collecting fingerprints, but it faceddelays because it is one of the largest Medicaid programs in the countryand had approximately 600 providers that required criminal backgroundchecks.Three of the eight States had collected fingerprints for all high-risk providersthat were newly enrolled in their respective Medicaid programs, but not forexisting enrolled providers that needed a criminal background check. Twoof these three States had not conducted criminal background checks forProblems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000708
“lookback providers,” while one State had not conducted criminalbackground checks for providers with overpayments. These three Statesreported that they were in the process of obtaining the resources needed toconduct criminal background checks for these providers.Three of the eight States reported relying on Medicare enrollment resultsfor all or most of their providers but also reported that they had notimplemented background checks. One State reported that it had high-riskproviders that were not enrolled in Medicare and that it needed to conductcriminal background checks on these providers. Another State reportedthat it was waiting for the Medicare enrollment results for seven providersand that it had not implemented background checks. The third Statereported that it had nearly completed all steps but had not documentedthe results of criminal background checks in its provider enrollmentrecords—a step that is necessary for demonstrating to Federal authorities,such as CMS, that a provider has undergone a criminal background check.49Loopholes enablehigh-risk providersto enroll inMedicaid withoutundergoing criminalbackground checksStates reported that even when they have fully implementedfingerprint-based criminal background checks, high-risk providers can enrollin Medicaid without undergoing the required criminal background checks.This results from two loopholes in the provider enrollment process:(1) CMS’s permitting States to forgo conducting criminal backgroundchecks, in certain circumstances, for high-risk providers applying toMedicaid that Medicare has already enrolled, regardless of whetherMedicare has conducted a fingerprint-based criminal background check;and (2) the ease with which high-risk providers can conceal owners whomust undergo fingerprint-based criminal background checks. For theprovider enrollment screening process to function as a fully effectiveprogram integrity safeguard, all high-risk providers should submitfingerprints and undergo criminal background checks. Unscrupulousproviders could exploit these enrollment loopholes to enroll in Medicaidwithout undergoing criminal background checks and defraud the program.CMS permits States to forgo conducting criminal backgroundchecks on high-risk providers applying to Medicaid that Medicarehas already enrolled, regardless of whether Medicare hasconducted a background checkIn its guidance to States, CMS permits States to forgo conducting criminalbackground checks on providers that Medicare has already enrolled. As thisreport has previously mentioned, this is meant to reduce the administrativeburden on States and on providers. However, CMS permits States to do thisfor providers that Medicare has enrolled as high-risk, even when Medicarehas not conducted a criminal background check on the provider as part ofits enrollment screening.50, 51 CMS staff reported that Medicare has yet toconduct criminal background checks on approximately 1,000 high-riskproviders, and that Medicare will not conduct criminal background checksfor these high-risk providers until 2020 or later.Problems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-000709
CMS staff reported that although Medicare has not conductedfingerprint-based criminal background checks for these providers, CMS usesits Advanced Provider Screening (APS) system to monitor a variety ofdatabases that might indicate whether a provider has a criminal history.APS is a useful tool; however, it is not equivalent to a criminal backgroundcheck that uses a fingerprint—uniquely personal identifying information—and APS may not catch instances in which a provider with a criminal historyalters his or her name or other personal information. Fingerprints arenecessary for the positive identification of providers with criminal historyrecords in repositories maintained by States and the Federal Bureau ofInvestigation.52 Name-based background checks are subject to errors—false negatives—that could permit a provider with a disqualifying criminalhistory to enroll.53 The use of fingerprints eliminates these errors.54Forty-four States reported that they rely on Medicare enrollment results forproviders that Medicare has already enrolled. These States may haveenrolled any of the approximately 1,000 high-risk Medicare providers—without either Medicaid’s or Medicare’s having conducted fingerprint-basedcriminal background checks—because CMS gave States permission to relyon Medicare enrollment results, regardless of whether Medicare hasconducted the criminal background check. This loophole could result inunscrupulous high-risk providers’ being able to enroll in Medicaid withoutundergoing fingerprint-based criminal background checks, posing a threatto the program.High-risk providers can conceal owners who require criminalbackground checksStates rely on providers to truthfully disclose all owners so that States knowwhich individuals should undergo a criminal background check. The Federalrules require providers to disclose—and require States to collect fingerprintsfrom—individuals whose ownership interest, either direct or indirect, inhigh-risk providers is 5 percent or greater.55, 56 The Federal rules alsorequire States to deny or terminate the enrollment of any provider that hasan owner with a disqualifying criminal conviction.57 Providers disclose theirowners to States when submitting their enrollment applications and mustreport any changes in ownership that occur throughout their enrollment.58In past work, OIG found that 43 States did not collect on their enrollmentapplications information on all individuals with an ownership interest in theirproviders and that 32 States did not verify the accuracy of providers’self-reported ownership information, making it possible for unscrupulousproviders to conceal owners with criminal histories and avoid detection byStates.59 If high-risk providers conceal owners and States have no way todetect these owners, a provider with an owner who has a disqualifyingcriminal history could enroll in Medicaid.States and CMS have worked together to correct gaps on States’applications for Medicaid provider enrollment, but they face limits inProblems Remain for Ensuring That All High-Risk Medicaid Providers Undergo Criminal Background ChecksOEI-05-18-0007010
verifying the accuracy of providers’ self-reported ownership information.Specifically, States and CMS lack an independent system for detectingwhether providers’ self-reported ownership information is accurate, andthus they cannot be certain that they have conducted criminal backgroundchecks on all individuals with an ownership interest in high-risk providers. Inpast work, OIG found that the States that did verify accuracy of ownershipinformation used a variety of data to do so, including Federal and Statedatabases, business documents, online searches, and site visits.60 However,these separate activities do not represent a shared solution to this problem,and nine States reported in 2018 that they still lack the capability to identifyowners whom providers failed to report on their enrollment applications orpurposefully concealed. In July 2018, CMS staff stated that CMS also lacksthe capability to verify the accuracy of ownership information
fingerprint-based criminal background checks for high-risk providers in Medicaid, and 2. To describe the remaining challenges to the implementation of criminal background checks in Medicaid. An effective provider enrollment screening process is an important tool for preventing Medicaid fraud. To protect Medicaid against fraudulent and
Bruksanvisning för bilstereo . Bruksanvisning for bilstereo . Instrukcja obsługi samochodowego odtwarzacza stereo . Operating Instructions for Car Stereo . 610-104 . SV . Bruksanvisning i original
IAS 36 – LỖ TỔN THẤT TÀI SẢN. xxx KHÔNG áp dụngcho Ápdụngcho x Hàng tồnkho (IAS 2) x . Tài sản tài chính (IFRS 9) x . Quyền lợi người lao động (IAS 19) x . Tài sản thuế hoãn lại (IAS 12) x . Hợp đồng xây dựng (IAS 11) x . Bất động s
10 tips och tricks för att lyckas med ert sap-projekt 20 SAPSANYTT 2/2015 De flesta projektledare känner säkert till Cobb’s paradox. Martin Cobb verkade som CIO för sekretariatet för Treasury Board of Canada 1995 då han ställde frågan
service i Norge och Finland drivs inom ramen för ett enskilt företag (NRK. 1 och Yleisradio), fin ns det i Sverige tre: Ett för tv (Sveriges Television , SVT ), ett för radio (Sveriges Radio , SR ) och ett för utbildnings program (Sveriges Utbildningsradio, UR, vilket till följd av sin begränsade storlek inte återfinns bland de 25 största
Hotell För hotell anges de tre klasserna A/B, C och D. Det betyder att den "normala" standarden C är acceptabel men att motiven för en högre standard är starka. Ljudklass C motsvarar de tidigare normkraven för hotell, ljudklass A/B motsvarar kraven för moderna hotell med hög standard och ljudklass D kan användas vid
LÄS NOGGRANT FÖLJANDE VILLKOR FÖR APPLE DEVELOPER PROGRAM LICENCE . Apple Developer Program License Agreement Syfte Du vill använda Apple-mjukvara (enligt definitionen nedan) för att utveckla en eller flera Applikationer (enligt definitionen nedan) för Apple-märkta produkter. . Applikationer som utvecklas för iOS-produkter, Apple .
och krav. Maskinerna skriver ut upp till fyra tum breda etiketter med direkt termoteknik och termotransferteknik och är lämpliga för en lång rad användningsområden på vertikala marknader. TD-seriens professionella etikettskrivare för . skrivbordet. Brothers nya avancerade 4-tums etikettskrivare för skrivbordet är effektiva och enkla att
Den kanadensiska språkvetaren Jim Cummins har visat i sin forskning från år 1979 att det kan ta 1 till 3 år för att lära sig ett vardagsspråk och mellan 5 till 7 år för att behärska ett akademiskt språk.4 Han införde två begrepp för att beskriva elevernas språkliga kompetens: BI
