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TRANSCRIPT

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[Michael H. Cohen]

Hello, everyone, and thank you for joining us today for our community chat. So, we’ve had a couple of these online events in a few different formats and I’d like to do something a little different today. So, let me share the vision for our 30 or so minutes together.

So, I want to say that unlike the other ones, this is not a webinar with a scheduled PowerPoint and it’s not necessarily office hours. I think I will take some Q&A because I see some things that I can address but my purpose is really a little bit different and that is to have a conversation with you about your health and wellness business or practice in these extraordinarily challenging times, and really a chance to share our thoughts and the things we’re doing with one another.

If I can weigh in, I will but mostly I’d like to hear from you and develop more of a sense of a community here. Of course, if you’d like to share legal insights or experiences, you’re welcome to do so. Understand that my role today is to facilitate the conversation and not dispense legal advice.

Of course, I’m not going to dispense health advice, I’m not a doctor. Although I have to tell you my mom is a doctor and I was a medical school professor. But so is my mom, but I want to qualify that and let you know that when I was on rounds with my mom when I was a kid, I pretty much faint at the sight of blood. So that’s why I didn’t become a doctor and college biology was not my strong suit.

But I do work with health and wellness providers businesses in the course of our law firm practice every day. And since I was a law professor, I am used to posing questions. So, I’m pretty good footing moderating our chat today.

Again, if there’s something you’d like to ask, you’re welcome to use the Q&A function and we’ll try to get to it. But really I want to open up the floor and hear from you so that you can share. So, to start let me ask three questions and you can take notes. And also, Aram, if you’re around in my office, if you have the questions accessible and can type them in the format, then go ahead and do so.

If you can’t, I’ll just start to say them verbally and people can start thinking.

Take note and if anything comes to mind, even spring of consciousness, we would love to hear from you. So, the first question is this. What is your healthcare … Say your name. You don’t need to give your last name unless you want to. What is your healthcare business or practice and how have you pivoted in the last 30 days?

Again, what is your healthcare business or practice briefly and how have you pivoted in the last 30 days? That’s one question, the first question you could answer. And I’d like to ask you to keep your questions succinct so that as many people as possible have time to share.

The second question is this, what inner shifts or realizations have you come to as a result of the pandemic? What new insights do you have about yourself or the world that you would like to share with our community of people who are passionate about health and wellness in the industry? How do you understand life and your business in ways you didn’t a month ago?

Now, I want to say … I have one more question, I want to say people have very, very micro legal questions and during a legal strategy session, we’re comfortable addressing those. I think underlying everything what I’ve learned is I’ve had these enormous pivots during this time of quarantine, isolation, solitude with my friends and professionals. I refer to it as a monkhood. I hope that’s gender neutral. There’s I’m sure an equivalent you can pitch in here.

But it’s a time of really being in the monastery, I guess, the convent and going deep within. And a lot of these mindset things really make all the difference in terms of pivoting what we’re doing in our businesses and practices particularly since we’re in health and wellness, as we know the WHO definition of health and wellness encompasses mental health, emotional health and possibly even spiritual health as well as physical health. So that definition is at the root of my two questions so far.

The third question is this, I recently received a newsletter with this quote from a yoga center. The quote is this, “We are the ancestors of our future.” How is this idea that we’re the ancestors of our future resonate with you personally and in what you’re trying to accomplish in your business?

So, again, how does the idea, we are the ancestors of the future, resonate with you in your life. So, how does this idea resonate with you personally in what you’re trying to accomplish in your business?

So, the floor is open and I would love to hear people share.

[Participant]

All right. Thank you very much, Michael. Thank you very much for the work that you do. I was reading one of your articles that you posted on the American Medical Association say about 10 years ago, and I appreciate that you have a master’s of fine arts and I really feel that coming through the practice that you have, congratulations and thank you for your contributions.

[Michael H. Cohen]

Thank you. I appreciate that comment, Daniel.

[Participant]

Certainly. And so to answer your first question, how I have pivoted. I’m a massage therapist practitioner and so I do a lot of in-person therapies within a six-foot social space. And so, I have pivoted to preparing online education and training programs.

Secondly, my insights is that I’m impressed with the lag time of knowledge in the community both consumer and academic and scientific about the lag time of immunology and the anatomy and physiology of infectious disease compared to more established knowledge regarding neurology, for example. Viral infections, immunology, there still appears to be a mystery and consequently how we approach that specifically the magnitude of the stress, trauma, resilience response relating to immunology skill sets and how the resilience tactics around immunology.

And that speaks to the larger cascade of the effect of stress upon illness in general and what to develop in terms of prevention protocol for individuals especially families and children to establish that early childhood resilience of framework.

And thirdly, regarding the ancestry this very potent question. Again, for me, what comes up is how we understand our thoughts, our beliefs and our behaviors and how that affects the internal structures of our body down to epigenetics and mitochondrial functions. So that in the present moment of time, as we make cognitive decisions, emotional decisions and heart-felt decisions, how that has the potential to shift into our internal bodies down into our mitochondria and down into literally our gonads that affect the sperm and egg structures of our body so that when we reproduce, we’re creating those future generations.

So those are my thoughts on that.

[Michael H. Cohen]        

Great. Thank you for being the first to start and that’s a wonderful, wonderful starting point. It really adds a lot of value. I mean, definitely people are shifting online and I’d like to go around the room a little bit, but maybe at the end we could … Let me get through my comments over them. I have a question for you which is how is a massage therapist you go online? Maybe I could just pose that one to you and then come back to the other points? What are you doing differently or in a new way?

[Participant] 

And so, there’s two parts. I’m based in Marin County here and Marin Public Health has approved that massage therapy can support essential clients. So, I have a new extensive virus transmission mitigation protocol in my office here. I’m seeing a select number of clients who have essential needs and I’m looking at how do I take my skill sets around my understanding of stress resilience deep into the immune system. Potentially, the hypothetical structures around immunology, endocrine gland systems.

How do I package that into a class curriculum around stress resilience specifically on those deeper layers, that’s one. And then secondly, what’s the nature of a six-foot personal space? Because Marin County said that I as a massage therapist could practice but as long as I practice social distancing.

So, they’re confused. A massage therapist requires me to be close, but since it’s not codified yet and that’s still not showing up in the national industry associations of how do you practice massage and get in that six-foot personal space? What are your hygiene protocols? Your transmission mitigation protocols? So how am I learning about this and how can I take this to other people based upon maybe being a leader in this application and implementation of massage in the six-foot space.

[Michael H. Cohen]        

I think if you can do that, that would be a wonderful contribution because I’m sure a lot of people want that kind of relief, want a massage. I’m sure there are many people who need a massage either physically or emotionally for rehabilitation or therapeutic purposes. So, that’s wonderful that you’re tackling that and I hope that you’ll be able to get that worked out and also provide a way for other people with similar professional training to continue having a professional practice.

Just moving over to the legal side a little bit, we talked on the previous webinars about coaching versus professional practice and I think it’s more and more of a step into online work. There was some boundary issues there that we’re all going to need to think about with very little guidance actually in the law.

I see a couple of questions about that and we talked in the last … We encourage the people that asked the questions to reference materials on our blog, cohenhealthcarelaw.com/blog. We have a page on COVID-19 resources and we include there our past materials in which include a discussion of Telehealth and the fact that many states as well as the federal government had begun relaxing standards and relaxing enforcement.

Nonetheless, we don’t know when and how things will snap back into place and a lot of it is more about looking at yellow lights. I don’t call them gray areas because I don’t like the metaphor, and I think gray area doesn’t really tell you anything. I think it’s more about how do we push through, what are the places that I’m more relaxed where we can push through and innovate. And what are the spaces where we’re still good at smacking to a red light and we don’t want to transgress and cross that boundary.

The other thing that I want to say to Daniel by the comments … I see that Ken Pelletier is on the line with us again. And Ken perhaps at some point, you’d think about sharing with us some of your perspective about mind-body interactions and the way that the soul translates into the immune system and where do we go for guidance on best practices. Do we look to supplements? Do we look to education on our immune systems? I mean, what are the best resources for that?

[Participant]

Okay. Hi, Michael. So, I am a physician and I have an integrative functional medicine practice and to answer your question, since the last 30 days, the way I’ve pivoted my practice is all my patient visits have been converted to telemedicine. And as a result of the pandemic though I have seen a significant change as have all the practices. And essentially the number of new patient appointments which have dropped to virtually zero, from a sizable number.

But I have since then still decided that since I’m not working at the frontline of the pandemic, I made a decision to actually donate my services to all the frontline health workers. So I have offered any healthcare worker who was working at the frontline or their immediate family members, I am offering my services free of charge.

And actually, one, in fact, I realized that one of my previous patients is in that situation now. So I’ve actually refunded my money to them despite the fact that my income has significantly dropped this month.

So, to answer your second question then, what inner shifts have I come as a result of the pandemic? That certainly is a reflection of the significant inner shifts I have made recently in this. I may have a profound journey, and to put it succinctly, I think my deepest insight so far has been, which has been validated by some of the ancient wisdom that I’ve been reading is not to seek profit as profit, but to seek righteousness and justice as a profit.

And that has been, even though I read that in past, this has been a genuine … I feel that it’s something I can feel strongly at this point. So, in other words, what I feel at this point, what’s more important and what’s more valuable and meaningful to me at the end of the day and obviously, at the end of my lifetime is for me to transform my inner self in my practice so that the priority is truly helping people, to give myself to humanity as much as I can.

And maybe make a shift so that I’m not so much worried or spending my time and efforts working on the micro details of how to improve my revenue or improve my profits. Of course, that’s important but I want to shift in such a way that it feels much better for me.

Obviously then, your quote about how we’re the ancestors of our future and how does that idea resonate with me. And I think that obviously, it has resonated with me especially in this time and having this broad timeless view really validates the inner shifts that I’ve made and I hope that that will help others, humankind, move towards that type of shift.

[Michael H. Cohen]        

Thank you so much for sharing that, Dr. Wang. And yeah, I mean it certainly is a time of reflection and all the things that I thought were so cool when I read them in college when I was into existentialism and Carlos Castaneda. And then while I was working on Wall Street as a lawyer, I took some courses at an interfaith seminary and did their program and studied energy healing and I mean, all these things, whatever your … They become enormously valuable treasures to me during this time.

And so, whatever your source of spiritual enrichment is, go seek and then thank you for sharing because this is the time to draw on that for sure. So thank you for sharing that, and yeah, we’re all … I’ll speak for myself. I mean, I’m looking at myself with a lot of accountability and it’s always been the case but there’s even … I would say heightened scrutiny right now, which is sort of a term that comes from constitutional law.

But yeah, we all need that kind of self-reflection. And it’s great that you can choose to give even though you’re taking a hit. I think that’s wonderful. So thank you for sharing that with us today.

While more people are gathering their thoughts, I’m going to go to some of these questions. And I’m hoping that more people will participate again. If you want, you can just simply give us your first name. So, yeah, there was a question about the laws governing online client sessions across state lines that used complementary and alternative medicine.

So, there are actually three questions there. So, one is what are the laws governing Telehealth or online sessions? Another one is what are the laws across state lines? And the reality is we have 50 plus different sets of laws. And then using alternative medicine, a lot of times there isn’t necessarily one law that governs that. It’s more about putting different things together like thinking about what is the standard of care, what’s my liability exposure? Do I have exposure for HIPAA or some state law counterpart dealing with privacy and security?

Do I have issues around my consent forms? Am I doing clinical or professional work or am I doing health coaching? So those are these five different legal issues that could be packed into trying to figure out whether what you’re doing is going to raise your risk in ways that are acceptable or not acceptable to you.

There’s a question here about starting a new physician-patient relationship by using Telemedicine as opposed to not being seen in office. Again, this is just a constantly changing map. You could look to our blog or call us for consult because it really needs to be researched in every state.

Some states we mentioned last time and the time before our creating waivers so that physicians could get a virtual license or a second license in the remote state. But it’s really something that states are evolving on a day-to-day basis. So, that would cover those. Yeah, I mean I think that … Sorry, I’m just sending a note to Aram.

Informed consent, I mean definitely the informed consent should cover Telehealth, telebenefits and risks. And that’s something that we could help you work on if you’re not comfortable wrapping in language. But I think the main point is that informed consent has to do with risks, benefits, and alternatives. And we covered that a little bit again in one of the previous webinars.

Does any of the recently enacted federal COVID-19 legislation contain limits on liability? What I have in mind are lawsuits claim that employer negligently caused an illness or death. There are two things that I’m aware of. One is that people who have done things that are deliberate and despicable, that those are being prosecuted as terrorism cases. That’s something you might have seen on the news.

So, this not really limit on liability but that’s actually a way that there’s more liability for doing things that are criminal. But in terms of lawsuits, I did see something in New York which lowers the threshold for … I’d have to go look it up. I think it’s probably on our blog somewhere, but the idea that you can’t be sued for negligence if you are taking care of somebody who has COVID-19. But you could still be liable for gross negligence.

So, what’s the difference between negligence and gross negligence? Negligence is doing something that’s below the standard of care. And gross negligence is higher standard. So basically, they’re making it harder for people to be liable if they are serving patients in the COVID-19 capacity.

[Participant]        

Hi, okay great. First of all, yeah, thanks so much, Michael. I always appreciate. These are fantastic. I just wanted to brief comment, I am really excited that maybe it’s a silver lining but that this COVID-19 unfortunate situation is stimulating so many of our ancillary healthcare workers or people or professionals, whatever we want to call it as general term of everybody who’s in this together which is technically everybody.

But what I’ve noticed is that like with Daniel was saying as a massage therapist in Marin and coming up with maybe an idea on how to give somebody a massage from six feet away. That to me is awesome, really cool, Daniel. If you can figure it out, yeah, more power to you and spread the word because I think massage is fabulous and a lot of people do need that. It’s very therapeutic.

But in response to this new-found interest in everyone like trying to become an expert in immunology real quick and like becoming a practitioner of functional medicine overnight, or whatever it is that I’ve noticed is happening in my own communities with like yoga, and all kinds of people that are all of a sudden throwing up websites and they’re calling themselves experts in immunology because of whatever reason because people need that kind of … People are interested in it. It’s all we hear about all day long.

So, I just wanted, Michael, maybe to comment about something that in our field of integrative medicine, which I’ve been a part of for a long time, has been an issue and especially in the state of California, which is that we have a lot of really cool forward progressive thinkers but we also need to sort of make sure that we all work together as opposed to … Like everyone just says to stick to their training, that’s my point.

Just stick to your training, explore, do really cool things but stick within the realm of your practice because it makes then when patients come to see us at the MD level, then we don’t have to say, “Well, wait a minute, but we learned in medical school or in 30 years,” I’m going on 29 years now of studying medicine and practicing it on and off whenever I can.

And you know what? That’s a long time. I didn’t get to where I am overnight and none of us did. And I can’t give a massage I’m sure half as well as any of my amazing massage therapists or yoga instructors or anybody who’s dedicated their lives to their fields of expertise, their passion.

So, I welcome that but I say, my comment is let’s work together. I’d be happy to like promote. Daniel, you or anyone like up in Marin. I’m down in Malibu just on my website or whenever that goes up which will be very soon. And we can help each other, like I can say, “Hey, if you want a virtual massage or you want like a really cool massage therapist that also cares about immunology, maybe check out Daniel,” and I can plug you in, in a section of Dr. Jain’s referrals or whatever I’m going to call it in my website.

And so that’s my comment. And kind of it’s a broad stroke comment. And, Michael, thank you, take it from here.

[Michael H. Cohen]        

Thank you so much for contributing. So yeah, I would say that one issue that comes up a lot with the practitioners that consult with us is scope of practice. So, if you’re other than an MD, your scope of practice is limited by state law. So, one issue where people have gotten in trouble is, for example, Shalini you mentioned functional medicine.

So, if for example someone says they’re doing functional medicine but they are a chiropractor or a massage therapist and I know what I’m saying is going to push some buttons that’s going to be controversial. Simply telling you the way I call it like I see it. If your scope of practice says you can do X, Y, Z, and you do something and it doesn’t fit within those boundaries and the state interprets it narrowly, you could be in trouble.

Now, we ran into this about a year ago with someone who wanted to do functional medicine. He didn’t like the bad news which is I was simply saying, “Look, this is an area of risk.” And he said, “Well, how can I market myself? We’ve got all these other practitioners and I have to say that I can cure this and cure that.”

And I said, “Look, if you want to do that, that’s up to you. I’m just telling you that your scope of practice is X, and if you put on your website I’m doing not X, pretty much anyone can do a search for a chiropractor functional medicine in your state and they can find you. And if you want to take that risk, that at some point it’s your business judgment to do so. My recommendation is not to do it.”

So, I think that there is a legal and ethical obligation to go within your scope of practice. Now having said that, there’s also a duty to refer. It can be a source of malpractice liability. There’s actually three sources of malpractice liability. One is practicing negligently below the standard of care where the patient gets injured. Another one is inadequate informed consent, not disclosing all the material, risks, benefits and alternatives to the patient and getting that document in writing, well, not getting documented writing. And the third is violating the duty to refer.

So, if somebody presents something that requires a brain surgeon and you don’t send them to the brain surgeon but you say you can do it, you could be negligent for violating the duty to refer. There’s actually a fourth category called negligent referral but I said I was going to try to stay more on the philosophical, emotional mind-body front and practical front and less be answering legal questions.

But just to give you a background, I think that it is important and economically useful at this time to create deep, deep referral networks. And if there’s a way that you feel that we can expand over doing here in support our referral network maybe having a community forum, we’d be happy to facilitate that.

Let me turn now to Jaimi Jansen. Jaimi, you had a question or an observation about some information you see from the California Association for Massage Therapy. So, the floor is yours.

[Participant]   

Thanks for doing this. Just a couple of things. One is, I also am curious about what Daniel is speaking about though he might be able to say that it’s an essential service like the California Association of Massage Therapy Council said they would strip people of their license if they were caught massaging. So, that was just one comment.

But the other thing was, so I am the practice manager for integrative clinic and we’ve worked with your firm and we do chiropractic acupuncture, osteopathy, regenerative medicine and then corrective exercise physical therapy. Being under the guides of a physician, are we able to … I mean, yes, we’re out of six-foot distance. Can we practice in person the physical therapy and corrective exercise, or is it better to just steer clear of that and just do virtual sessions? Because that’s what we’ve been mostly doing but some clients would like to be seen in person.

[Michael H. Cohen]      

So, you’re probably asking me something that we’re going to want to answer on a legal strategy session because I don’t want to give you any advice. But it’s a really excellent question because the advice to everybody has been go into Telehealth in a digital format. If you’re saying but state law requires me to see someone in person because of the relationship between the MD and the PT or standard of care, I mean that sounds really thorny.

[Participant]   

Yeah, we got letters, I think maybe even from you and some other. Like we do insurance billing and we’ve gotten some information about like the relaxation of rules around telemedicine and like Zoom medicines. So, we’ve been doing a lot of that. But chiropractic and acupuncture is technically in our county anyway an essential service, so we’ve been continuing to do that. However, our numbers like people have mentioned have dropped dramatically no matter how sanitized we are claiming we are.

[Michael H. Cohen]        

Yeah, I mean I think one piece of work that needs to be done which Daniel alluded to which is how do people in the manual therapies continue their work when they can’t see someone in person, or can they see someone in person or is there a safe protocol, maybe both wear masks. What’s being done? Who’s looking at this?

I seriously doubt you’re going to see initiatives from legislators because I think this is probably like not on their number one bucket of priorities. Probably the place to go is your national professional association and see what they can do to establish standards for the community, because those standards are getting influenced legislation.

And in the absence of legislation or something on point, if you’re looking at liability, then liability questions default to standard of care. And a lot of times, issues of professional discipline also default to what is the standard of care. And what is the standard of care and who’s going to say what it is at this time, I mean, is very much an open question and something that the community needs to wrestle with.

The other thing I would say, Jaimi, from excellent information that you presented is that people need to be careful about what the insurance company is going to say. You need to have a really top-notch biller and coder who knows the latest rules. You have to make sure that the billing and coding reflects if it’s Telehealth.

And you need to make sure that if the insurance companies have requirements, that they might have their own requirements as to when and how people have to be seen and how they have to get referred. And those might be rules that are completely independent of what the law says. And so if you don’t pay attention to those, then you can get in trouble with the insurance company which can be perilous.

[Participant]   

Yeah, we’ve been there. So, I appreciate that. We’re definitely checking in with all insurance companies in addition to the legal stuff that we’re hearing from the different modalities that they offer.

[Michael H. Cohen]       

Thank you so much, Jaimi. Let me just take Daniel for a quick response and then we’ll go to Debra Scheufler and then we’ll wrap after that. Daniel, did you want to offer a quick thought?

[Participant] 

Yeah, just real quick. I’m not 100% up on the California Massage Therapy Association, nor my insurance provider. But what I have seen to date right now is that both my insurance provider, the Association of Massage & Bodywork Therapies and the California Association, they are not making firm statements that massage therapists cannot practice but they are deferring to the laws, both the state laws and the county laws.

So, in Marin County on their public health website, massage is identified as a practice that can provide service and that the determination of an essential service is left to the practitioner. And that is also seen in San Francisco County that when I last reviewed that website. And so this is a variable issue here that I’ve been tracking it closely to determine if I have the right as a practitioner to make the assessment of what is or is not essential.

Now, in other counties and other states, that’s going to be different. But I don’t have any email from the California Association that said specifically I could not practice and that my license would be stripped. Jaimi, I’d appreciate if you could send that to me because that’s a very important issue because I certainly don’t want … I want to make sure that I’m abiding by rules.

[Michael H. Cohen]       

Yeah, we’re going to republish this call so I don’t want anyone to feel compromised. But perhaps you guys can find each other or write to us so we can facilitate in this reduction. I mean we’re in the non-judgment zone here and this is really a space for people to share cutting-edge ideas.

Look, we’re all in a state of incredible uncertainty. I received something last night from my son’s school and it basically said flat out like, “Don’t expect online education to be the same as in-person education”. It’s not. We create a magical space in the classroom. And I think similarly, when people come to you for healing, you create a magical space.

Now, having studied energy healing, I’m a big believer in remote healing and energy at a distance and quantum entanglement and all sorts of mysteries. At the same time, there is a certain magic that happens in person.

So, we’re all figuring this out and I think the other point of the article is that everybody’s anxiety is incredibly ramped up. I mean it’s just the way it is, like if you did 10 steps before, now you have to do 50. If you meditated for 20 minutes a day, now, it has to be 40. I mean, I’m just speaking for myself like more and more and more.

Let me just take one more comment. We have someone with us, Debra Scheufler. Debra is actually another healthcare lawyer and I have learned from her. And it’s really valuable to have other fellow professionals here in my own space. So, Debra, it’s great to have you on the call and please jump in and offer any comments that you’d like to give us, if you’d like to share.

[Participant]        

Yeah, thank you. And Michael is really my mentor in this field. So, I just wanted to hear what you all have to say. But what my comment was, is that I was on a Zoom call the other day and there’s a homeopath who was saying that she had a remedy for COVID-19. And I just found that a little irresponsible. What is your take? Because remedy is the term used for homeopathic therapies, but it just seems a little misleading to me. What do you think about that?

[Michael H. Cohen]        

Yeah, I think you have to be careful about thinking that remedy is something different than cure because there’s legal language and then there’s the English language and they’re different. And lawyers are going to hear remedy is cure even though technically it’s a homeopathic remedy, and there’s a lot behind that.

There was something that came out from FDA and possibly also I think Federal Trade Commission recently which a good number of companies got in trouble for making COVID-19 coronavirus claims. And let me just see if I can find it. It’s fresh on of the FDA website, pretty easy to find. But what was interesting is it’s like the second wave of warning to others.

And I mean, the kinds of products and things that people were trying to… Let me just find this thing. I found it interesting the range of things that they were going after, and they include things like homeopathics or all sorts of products.

But you have to understand that this also creates exposure for practitioners and if practitioners overpromise the claims of the cure, this can also get them into trouble. So, irresponsible and also I think dangerous from a liability perspective. So, again, I don’t want to give a blanket rule because obviously if you’re a physician and you’re treating somebody, you’re treating them. I mean, you’re treating them for the disease.

If you’re helping people with immune support and you’re within your scope of practice, that’s what you should be doing. If you’re dietary supplement company and you’re making claims that stress your function claims like boost immunity support and those claims can be substantiated, know then unless you’re doing something else, you’re within the law. But you have to be careful. People try to blur the boundaries and that can be dangerous.

Again, if you have any specific microquestions, questions that are tailored to exactly what you’re doing, we’re here to help you. You could do legal strategy session with us. We also have a really extensive blog with lots and lots of resources. And by and large, our content is evergreen. So, the guidance that we provide on the blog was there before COVID-19. It will be there after and the basic lines of the law have not changed. There’s some shifting. There’s some relaxation here and there. But basically, for example, you can make treatment and disease claims for supplements. You can only make stress as your function claims. You have to stay within your scope of practice.

There’s concern about liability. I mean these things were there, privacy and security are still very much a part of the law, so even a federal enforcement is down. There’s still state enforcement. So, I see it all as risk management and finding titrating your risks so that’s acceptable so that you’ve got a good strategy and you’re not blind-sided by something catastrophic. And that’s really how we try to guide people with a rule of reason.

So, let me end with that and I want to say thank you all so much. It’s really great to hear from you and it’s really great to talk to you. And you’ve provided a lot of rich material for everybody. We really look forward to keeping in touch with you and our community is precious. So again, thank you very much and we look forward to connecting with you again on the next one.

Have a wonderful day, everyone. Many blessings.