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| PM News | |
The Voice of Podiatrists
Serving Over 22,046 Subscribers Daily
March 13, 2024 #7,708  Publisher-Barry Block, DPM, JD
A partner of Podiatry Management https://podiatrym.com
E-mail us by hitting the reply key.
COPYRIGHT 2024- No part of PM News can be reproduced without the
written permission of Barry Block
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| PM NEWS QUICK POLL |
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Was your practice affected by the recent Change Healthcare cyberattack? |
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| IN YOUR MAILBOX SOON | |
We've just mailed the March 2024 issue of Podiatry Management. The cover story is titled "The One-Page Marketing Plan". In addition, our usual assortment of columns and features, including a CPME-Approved CME.
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March 2024 Podiatry Management |
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| AT THE COLLEGES | |
NJ Podiatrist Honored on the TUSPM Gallery of Success
Harris Klear, DPM has been honored by the Temple University School of Podiatric Medicine (TUSPM) Alumni Association for his many years of service to TUSPM. Dr. Klear graduated from the Pennsylvania College of Podiatric Medicine in 1971 and completed his podiatric residency at Parkview Hospital in Philadelphia.
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Dr. Harris Klear |
The Temple University Gallery of Success celebrates outstanding professional achievement, inspiring students toward their future. Representing Temple’s 17 Schools and Colleges, Gallery of Success honors the impressive accomplishments of some of its most esteemed alumni.
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| MEETING NEWS | |
400+ Attend lerEXPO No-Nonsense Virtual Podiatry Seminar
Over 400 clinicians gathered together online this past weekend on the lerEXPO platform for the No-Nonsense Virtual Podiatry Seminar. The event was worth up to 25 CECH and brought together podiatrists, dermatologists, vascular surgeons, rheumatologists, endocrinolgists, and cardiovascular surgeons for a weekend of learning like no other.
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Presentation at lerEXPO No-Nonsense Virtual Podiatry Seminar |
The faculty included, Patrick DeHeer, DPM Jeffrey Lehrmann, DPM, Lowell Weil, DPM, Brad Abicht, DPM, John Cozzarelli, DPM, Joseph Park, DPM, Windy, Cole, DPM, Warren Joseph, DPM, Ryan Fitzgerald, DPM, Tracey Vlahovic, DPM, William Scherer, DPM, Adrienne Estes, DPM, James McGuire, DPM, Kevin Kirby, DPM, Mark Hardy, DPM, Krupa Patel, DPM, Lauren Schnack, DPM, Kelly Parks, DPM, Mark Mendeszoon, DPM, and Aamir Ahmed, DPM. The agenda was comprehensive and included talks on MIS, heel pain, plantar plate, pediatrics, Lapidus, coding, wound care, bone grafting, gout, biomechanics, dermatology, diabetes, surgery, fracture management, nerve surgery, and much more.
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| PRACTICE MANAGEMENT TIP OF THE DAY | |
8 Strategies for Improving Employee Loyalty and Commitment
Building a culture of loyalty and commitment takes time, consistency, and effort. By effectively implementing these strategies, you can create an environment where employees feel valued, supported, and inspired to contribute their best, leading to improved retention, productivity, and overall success.
4. Recognize and reward excellence
Acknowledge and reward employees who demonstrate exceptional performance, dedication, and commitment. This can be through verbal praise, written recognition, or even incentives such as bonuses or additional benefits. Recognizing and rewarding outstanding work helps motivate employees and strengthens their loyalty to the practice.
Source: Mike Szczesny, Keith A. Reynolds, Physicians Practice [3/1/24]
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| RESPONSES/COMMENTS (APMA HOD) | |
RE: APMA Policy Proposition 2-24: One Board in Podiatric Medicine & Surgery
From: Lee C. Rogers, DPM
Officers of the ABPM have submitted a proposition (Resolution) to the House of Delegates calling for a single certifying board in podiatric medicine and surgery. The APMA Policy Review Committee met on Saturday and gave Proposition 2-24 a "Do Pass" recommendation. If you're an APMA member, you can add your name to the list of co-sponsors by contacting ABPM. We will take your signature to the House of Delegates in Washington, DC this weekend.
We have ONE profession. We have ONE residency program. It's time to have ONE recognized certifying board. This is parity. The MDs have only one recognized board for each residency specialty. One board will reduce confusion, eliminate infighting, lower examination costs/dues, and prevent board certification from being used as an anticompetitive tool which keeps many podiatrists from getting hospital or surgical privileges.
APMA Policy Proposition 2-24: Single Certifying Board in Podiatric Medicine & Surgery
It is the policy of the American Podiatric Medical Association (APMA) to support the unification of the two currently recognized certifying boards under a single administrative entity resulting in a single unified board in podiatric medicine and surgery.
Lee C. Rogers, DPM, (TX), Immediate Past President, ABPM
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| RESPONSES/COMMENTS (CLINICAL) - PART 1 | |
From: David T Weiss, DPM
The most powerful way to manage DPN, (besides glycemic control,) is refraining from sugar (and carbohydrates) completely - especially after dinner. Sugar is extremely inflammatory. I have recommended liposomal glutathione (powerful antioxidant) as a supplement, along with L-methyl folate vitamins.
David T Weiss, DPM, Richmond, VA
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| RESPONSES/COMMENTS (CLINICAL) - PART 2A | |
From: Jeff Root
Regarding the query about the treatment of recalcitrant "posterior tibial tendonitis", or what many would call posterior tibial tendon dysfunction (PTTD), I would like to share a few of my thoughts. The PM News subscriber stated that the patient wears "HOKA shoes and custom orthotics". The term "custom orthotics" simply implies that the devices were not prefabricated. In some cases, the lines between custom and prefabricated shoe inserts have been intentionally and unintentionally blurred. In addition, the term "custom orthotics" tells us little to nothing about the nature (i.e. design and properties) of the orthoses because there are hundreds if not thousands of types of custom orthotics and orthotic designs.
For example, what was the position of the joints of the foot, including the STJ, MTJ and 1st ray when the foot was casted or scanned? What were the specifications of the orthotic prescription? What lab techniques were used in creating...
Editor's note: Jeff Root's extended-length letter can be read here.
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| RESPONSES/COMMENTS (CLINICAL) - PART 2B | |
From: Robert Kornfeld, DPM
I have spent more than 30 years treating chronic foot and ankle pain and have had many cases of “recalcitrant” PT tendinitis. Once you come out of the “next best treatment” mentality and focus on the patient, you will find answers. Functional medicine teaches you to examine the patient's total health landscape to uncover immune burdens and any epigenetic and genetic issues (SNPs) which will create inefficiency in repair pathways. These underlying mechanisms are managed prior to any treatment. Once you have up-leveled immune function, you can heal these chronic cases via regenerative medicine injection therapies. This is how every doctor should be practicing. I have loved my practice all these years.
Robert Kornfeld, DPM, NY, NY
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| RESPONSES/COMMENTS (BILLING & CODING) - PART 1A | |
From: Michael G. Warshaw, DPM, CPC
More often than not, it appears that it is the Medicare Advantage Plans that always find a way to not reimburse for a claim that was submitted. In the posted scenario, two flexor tenotomies were performed and billed for using CPT code 28230 appended by the toe modifiers. The payer denied charges stating" denied for exceeds number/frequency approved/allowed. Unfortunately, in this instance, the issue is not the Medicare Advantage Plan, but rather the incorrect way that this procedure code set was billed.
CPT code 28230 is defined as the following: Tenotomy, open, tendon flexor; foot single or multiple tendon(s) (separate procedure). Clearly, this CPT code is not intended to be used to indicate that a flexor tenotomy was performed on a toe. The definition of the CPT code demonstrates that the flexor tenotomy is performed within the foot, not the toe, and the CPT code is billed if one or more flexor tendons are addressed. It is apparent that this CPT code can only be billed one time per date of service. Billing the CPT code on two lines and appending a toe modifier on both lines was incorrect. Therefore,...
Editor's note: Dr. Warshaw's extended-length letter can be read here.
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| RESPONSES/COMMENTS (BILLING & CODING) - PART 1B | |
From: Jacob Panici, DPM, Keith L. Gurnick, DPM
You may be using an inappropriate code. When I have performed said procedures, I will utilize CPT 28220 for a single flexor tenolysis or CPT 28222 when performing multiple toes.
Jacob Panici, DPM, Raleigh, NC
CPT 28230 is for single or multiple tenotomies done at the same setting (same day). You can only bill 28230 code once. You should rebill 28230 T8 and then 28232 59T5.
CPT 28230 - Tenotomy, open, tendon flexor; foot, single or multiple tendon(s) (separate procedure)
CPT 28232 - Tenotomy, open, tendon flexor; toe, single tendon (separate procedure)
Keith L. Gurnick, DPM, Los Angeles, CA
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| RESPONSES/COMMENTS (PODIATRISTS AND PODCASTS) | |
From: Jeffrey Trantalis, DPM
One therapy for treating plantar fasciitis is orthotic therapy; not mentioned by Dr. Bhela. During my many years in practice in the Pacific NW, I successfully treated hundreds of people (working at Boeing) with custom orthotics. I feel other alternatives such as laser therapy are appropriate but may not be viable under certain circumstances.
It is fine if this doctor does not offer this option in his practice, but orthotic therapy should be mentioned as a viable alternative. He mentions lasers or medications as the only alternative. Maybe younger doctors are not exposed to this possibility. I admit I graduated over 40 years ago and laser options were not readily available.
Jeffrey Trantalis, DPM, Delray Beach, FL
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| RESPONSES/COMMENTS (NON-CLINICAL) | |
From: Michael A Uro, DPM
Thank you Dr. Tomczak for the gracious compliment. The feeling is mutual. Once again, I agree with your assessment of our profession. While I do not possess your eloquence in the written word, I will in my own humble way attempt to further express my feelings. Your assumption as to why I would not recommend podiatry to a college student is correct. I do not like the direction in which the profession is going.
Not everyone who enters medical school wants to be a surgeon. Not all have the abilities to become a surgeon. Does this make them any less of a physician? Of course not. Our patients need and deserve the experience of all the specialties and subspecialties. It takes many spokes to...
Editor's note: Dr. Uro's extended-length can be read here.
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| RESPONSES/COMMENTS (OBITUARIES) | |
Just caught up with PM News and read about the passing of Larry Lundy. He was a mentor years ago. Without a doubt, he was one of the nicest, kindest, warmest men that I have ever known.
Michael Z Metzger, DPM
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| YOU CAN'T MAKE THESE THINGS UP | |
RE: Outrageous Shoe of the Day
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Worn at the Oscars? |
Source: Alejandro Ingelmo via Footwear News
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MEETINGS & WEBINARS
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NEED CME CREDITS FAST?
PODIATRY MANAGEMENT'S AFFORDABLE ONLINE CME
You can Earn up to 50 Continuing Education Contact Hours (CECH) Online
Earn 15 CECH only $299
podiatrym.com/cme.cfm
All required credits can be taken online for AL, AK, AR, CA, CO, DE, HI, IN, KS, LA, MA, ME, MI, MI, MS, NV, NJ, NM, ND, OH, OR, PA, RI, SC, SD, UT, VA, VT, WV, and WI
Partial required credits can be taken online for AZ, FL, GA, ID, KY, IL, ID, IA, MD, MN, MO, MT, NE, NH, NY*, NC, OK, PR, TN, TX, WA, and DC
Choose any or ALL from 25+ CECH Category-1 articles posted
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| CLASSIFIED ADS - ASSOCIATE AND FACULTY POSITIONS, AND FELLOWSHIPS |
PM NEWS CLASSIFIED ADS REACH OVER 20,000 DPMs AND STUDENTS
Whether you have used equipment to sell or are offering an associate position, PM News classified ads are the fastest, most-effective way of reaching over 22,000 subscribers. For details, click here or write to: bblock@podiatrym.com or call (718) 897-9700 for details.
ASSOCIATE POSITION – NEW YORK CITY BOROUGHS
Busy and rapidly expanding practice looking for a full time associate. Multiple locations in Queens, Brooklyn, and Staten Island, Bilingual preferred. Required to take call in hospitals. Great balance between surgery and medicine. Ideal for recent graduates. Competitive compensation. Please submit CV to careersmobilepodiatry@gmail.com
FULL AND PART TIME POSITIONS AVAILABLE - KY, MA, and MD
Rapidly expanding podiatrist owned and operated company offering full and part time positions servicing Nursing Homes and SNFs in Kentucky, Maryland, and Massachusetts. Inquire about availability in other states as well. Send CV and inquiries to info@thepodiatrycompanyllc.com
FULL-TIME PODIATRIST - DALLAS/FORT WORTH AREA
Join a Dynamic multi-specialty 6 location group with cutting-edge equipment, storefront presence, physical therapy. Competitive starting salary of $150k, with the potential to easily earn up $200k with bonus. Send CV to Cnunez1940@gmail.com (Texasfootdoctor.org)
ASSOCIATE POSITION - MASSACHUSETTS
Well-established, well-rounded hospital-based group practice located just North of Boston seeking full-time DPM. Applicant must be ABFAS Board Qualified/Certified, well-trained with interest in wound care and limb salvage. We are well integrated within the medical community and are active in both hospital in-patient care and out-patient clinic. Excellent referral base and high volume of new patients. Competitive compensation and benefits package. Excellent opportunity for qualified candidate. Please email CV to footdocsma@gmail.com
ASSOCIATE POSITION – MASSACHUSETTS GENERAL HOSPITAL, BOSTON, MA
Immediate opening for a podiatric surgeon with interest in wound care, podiatric medicine, foot surgery and clinical research. Ankle surgery and reconstructive rearfoot surgery is not available. Ideal candidate is board-certified/qualified with prior clinical experience. MGH is affiliated with Harvard Medical School and our podiatric physicians are eligible for faculty appointments through department of orthopedic surgery. Excellent salary and benefits. Please contact Dr. Landsman. alandsman@mgh.harvard.edu
ASSOCIATE POSITION - GREENVILLE, SC
Busy two-office practice with three doctors in Greenville SC seeking a full-time podiatry associate. Start date immediately. All aspects of podiatric surgery, medicine and biomechanics. Benefits include 401 K, malpractice, health and dental insurance, CME, short and long-term disability. PTO. (All other standard benefits) Please send cover letter with CV to podiatryresumes@upstatefootdocs.com
ASSOCIATE POSITION – ST. GEORGE, VERNAL, PRICE, MILLCREEK OR WVC, UTAH
Immediate Doctor of Podiatric medicine position for a well-trained, highly motivated individual. Location: St. George, Vernal, Millcreek, Price or WVC , Utah. Competitive salary with commission structure. Benefits include: PTO, CME allowance, health and malpractice insurance. Must be confident in working solo in your own office environment. Please email Cover Letter and CV to laney@summitmedicalpartners.com
OPPORTUNITY OF A LIFETIME! - GAINESVILLE, FL
Surgically trained podiatrist needed. 40% of collections first year and equity partnership after that. Looking for someone to start now in Gainesville, FL. Located close to the surgical center and hospital. Seriously interested podiatrists please send CV to podiatry42984@gmail.com
FULL TIME PODIATRIST - NEW JERSEY
Established Podiatry practice in New Jersey with multiple locations and Doctors. We are currently looking for a full-time motivated and caring Doctor to join our busy practice. Benefits include: competitive six-figure compensation ranging from $155,000-$250,000, health insurance (including vision & dental), paid vacation time off, paid malpractice insurance and 401(k) plan. Great prospects for experienced Doctors as well as new Associates. This is an excellent opportunity to expand your podiatric medical experience in an office-based practice! If interested, please submit your CV to DrSamofal@PodiatryCenterNJ.com
ASSOCIATE POSITIONS – SOUTH CAROLINA
KG Health Partners is seeking full-time and part-time podiatrists to provide mobile lower extremity care to long-term care residents in these territories: Greenville/Spartanburg, South Carolina; and Charleston, South Carolina. Monday through Friday schedule, competitive wages, malpractice insurance, and benefits for full-time employees. Email CV to Kgadmin@kghealthpartners.com
FULL TIME PODIATRIST - NORTHERN NEW JERSEY
Busy Sports Medicine-Surgical Practice looking to hire motivated individual with interest in sports medicine getting patients back to activities ASAP thru conservative and surgical treatments. Must be willing to learn and/or perform reconstructive Foot, Ankle and related leg surgery including Nerves and other soft tissue microsurgeries. Board qualified ABFAS necessary. Potential partnership. Competitive salary, malpractice, health insurance, vacation, 401K and CME allowance. email CV to DrRunUSA@gmail.com
ASSOCIATE POSITION - PHILADELPHIA, PA
Full time associate with partnership opportunity for a well-trained, highly motivated individual. Competitive salary with commission structure. Benefits include PTO, CME allowance, health and malpractice insurance. Must be confident in surgical and wound care practices. Please email Cover Letter and CV to dgvc88a@gmail.com
ASSOCIATE POSITION - LATHAM, NY
Expanding, busy practice seeking BQ/BC well-trained, hardworking and motivated associate. Great opportunity with competitive salary, performance base incentive, comprehensive benefits package including potential equity offering at 18 months. Email: CV to rbauer.dpm@gmail.com www.summitfootandankle.com
ASSOCIATE POSITION – FLORIDA
PT to possible FT mobile positions throughout sunny Florida for responsible DPM team players. Primarily home visits and ALF/ILF's. No call. No ER. Flexible 9-5. Weekends optional. Generous commission salary. Great for new grads, semi-retired, or those looking to help fill their schedule. Serious applicants email contact@PodiatristAtHome.com
ASSOCIATE POSITION - NYC
Busy multi-doctor podiatry practice with 5 locations across 3 boroughs looking for a DPM ready to work. Part-time and full time available. Candidates should be personable, driven and hard working. All phases of podiatry including forefoot and rearfoot surgery. Generous salary, malpractice, 401k, vacation days and holidays. For inquired, please contact drlevy@starrettpodiatry.com
ASSOCIATE POSITION - VANCOUVER, CANADA
Busy, well-established practice looking for motivated podiatrist with excellent clinical and people skills. 2 office locations. CASH PAY. Lots new patients monthly. Huge growth potential. Practice allows great work-life balance. NO CALLS. Competitive pay structure and sign-on bonus. Non-Canadian, new graduate, experienced DPM applicants welcome. Email CV to podiatryvancouver@gmail.com
ASSOCIATE POSITION - MICHIGAN (OAKLAND COUNTY/DETROIT SUBURBS)
Outstanding opportunity, well established group practice, general podiatry, surgical forefoot, rearfoot & ankle (full time). Responsible, motivated team player with good communication skills, base salary + bonus,+ benefits, malpractice, continuing education. Confidential reply CV & letter of interest to: DPMposition@AOL.com
ASSOCIATE POSITION – NEW JERSEY
Looking for a podiatrist, part-time or full time, to service nursing homes in NJ with possibility to work in office for the right person. Looking to start ASAP. Please email resume to ghcp@globalhealthcarepartner.com. Days and Hours are flexible. Good compensation.
SEEKING PODIATRISTS THROUGHOUT OHIO
Onyx health group is looking to hire p/t or f/t podiatrists for nursing homes and assisted living facilities throughout Ohio. Set your own hours, clinical support, excellent commission pay. New grads as well as those with experience welcome to apply. Send CV and inquiries to Info@onyxhealthgrp.com.
ASSOCIATE POSITION - ALBUQUERQUE, NM
Foot & Ankle Specialists of New Mexico has an exciting, immediate full-time position open for a board qualified or board-certified foot and ankle surgeon. You can view our website at footanklenm.com. Spanish speaking and Fellowship are a plus but not a requirement. Billing/coding experience is preferred. Compensation is a competitive salary plus a percentage bonus structure to start. 20k sign-on bonus for provider that starts before April 1st, 2021. Please email CV and cover letter to ACharlie@footanklenm.com
ASSOCIATE POSITION – SANTA BARBARA, CALIFORNIA
Looking for a motivated podiatrist to be part of the Foot & Ankle Concepts Inc. team in Santa Barbara California and Ventura county California. Our practice includes surgical and non surgical care of the foot and ankle. Starting salary of 250K, please send resume to alangroudi@gmail.com www.footsurgeon.com
ASSOCIATE POSITION - THE WOODLAND, TEXAS
Successful, well respected multi-location, podiatric group seeking one physician with experience in wounds/diabetic care, and one physician with experience in biometrics/orthotics. Please send current resume with availability and Texas license status to alexandra@nevillefeet.com
ASSOCIATE POSITION – COASTAL SOUTH CAROLINA
Expanding, busy practice seeking BQ/BC associate with training in F&A surgery, wound care, hospital in-pt management and well-rounded clinical skills. Great opportunity for continued growth with great diversity in patient mix. Opportunity for great incentive salary. Email cover letter, CV and LORs to podiatrypracticesc@gmail.com
ASSOCIATE POSITION - MARYLAND
Immediate associate position to join our team. An expanding, dynamic podiatry practice with lots of room to grow. Limb salvage, deformity, trauma & clinic. Multiple hospitals to take call, hospital call required. Maryland license preferred, BQ required. Full benefit package available. Please email CV to footanklerecon@gmail.com
ASSOCIATE POSITION – CALGARY, CANADA
We are looking for a podiatrist comfortable with all aspects of podiatry, ranging from surgery to foot care. We have four exam rooms and an accredited in-office surgical suite, digital x-ray, shockwave and EMR. Must be able to work in Canada. Partnership opportunities available. Please contact lalani@alpinefootankle.com
WOUND CARE FELLOWSHIP - NEW YORK
CPME APPROVED 12 month fellowship beginning July 1st, 2024. Hospital and clinic environment, with onsite hyperbaric medicine. Working with infectious disease, as well as, general, vascular, and podiatric surgeons. Must have completed a PMSR residency. Please contact or jtfootcare@gmail.com. EOE employer.
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| CLASSIFIED ADS - PRACTICES FOR SALE OR WANTED, EQUIPMENT FOR SALE | |
PM NEWS CLASSIFIED ADS REACH OVER 22,000 DPMs AND STUDENTS
Whether you have used equipment to sell or are offering an associate position, PM News classified ads are the fastest, most-effective way of reaching over 22,000 subscribers. For details, click here or write to: bblock@podiatrym.com or call (718) 897-9700 for details.
PODIATRY OFFICE FOR RENT AND SHARE – MANHATTAN AND / OR PLAINVIEW, NY
Plainview Long Island and or Manhattan (22nd street between 2nd and 3rd Aves), Fully equipped, turn-key. Call (516) 476-1815 or e-mail podo2345@aol.com for details.
PRACTICE FOR SALE – MASSACHUSETTS
Modern, well established since 1986. Busy, 75 new patients a month. All aspect of podiatric services. Fully equipped, certified EHR, laser, digital x-ray, vascular machine, Pad net. In-house billing, well run. Located within a mile from hospital. Owner is willing to stay as necessary during transition. Contact drwaw54@aol.com
PRACTICE FOR SALE - MINNEAPOLIS, MINNESOTA
Amazing opportunity to take over a thriving established practice. Ideal for someone who wants to provide high quality foot care and practice the way you want with unlimited potential. Affordable with immediate income. Financing available. Wonderful place to live and practice. Serious inquiries only. Contact: wwfootclinic@gmail.com
PRACTICE FOR SALE - SOUTHERN VIRGINIA
Thriving 30 year 4-day practice with unlimited growth potential. All clinical aspects of podiatry including nursing homes, housecalls with multigenerational patient base. Significant physician referral source. Close to hospital. Retiring physician willing to stay during transition. Willing to sell building with practice (optional). PMNEWS@PODIATRYM.COM
PRACTICE FOR SALE - TREASURE COAST, FL
Treasure Coast (Martin/St. Lucie County). 40 YO part-time general practice 2 locations grossing average 200K. Please no brokers email practiceforsaleflo@comcast.net with phone number for information.
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| Disclaimers |
Acceptance and publication by this newsletter of an advertisement, news story, or letter does not imply endorsement or approval by Barry Block or Kane Communications of the company, product, content or ideas expressed in this newsletter. Podiatric Medical News does not represent the views, and is a separate entity from Podiatry Management® Magazine and Podiatry Management® Online. Any information pertaining to legal matters should not be considered to be legal advice, which can only be obtained via individual consultation with an attorney. Information about Medicare billing should be confirmed with your State CAC.
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR
ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS
PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE.
If the reader of this message is not the intended recipient or an
employee or agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination,
distribution, or copying of this communication is strictly
prohibited. If you have received this communication in error, please
immediately notify me and you are hereby instructed to delete all
electronic copies and destroy all printed copies.
DISCLAIMER: Internet communications cannot be guaranteed to be
either timely or free of viruses.
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- Subscribers are reminded that they have an ethical obligation to disclose any potential conflicts of interest when commenting on any product, procedure, or service.
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