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TRANSCRIPT

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Clara Salvai:

Good evening and welcome to our webinar. My name is Clara Salvai, and I’m the Chief Operating Officer of Cohen Healthcare Law Group. I’m excited to have you in here today with our attorneys for these first webinar that is on MSOs, which is going to be a series of MSOs and this is literally the first portion, which is a general overview of such. Today, we have thought about how to bring you a webinar in a structure and in a manner that is a little bit more creative and we thought that it will be a great idea to actually show you how we function internally on the firm, and since we always have conversations about every matter that is placed in our hands and we all know our clients by name, we thought that it would be great to show you how we usually address different questions and matters, every specific topic that is handed to us.

Clara Salvai:

So, our webinar today is going to be more a conversation between the attorneys and a lot of questions that you guys had submitted and you want to have us address, and at the same time, after we end with the person on the questions, we are going to go to a brief Q&A so that you have a chance to actually place your questions over the chat, and the attorneys are going to be selecting some of the questions randomly so that we can address them live. Of course, as always, if you have any questions, and we can address them today, you are more than welcome to reach out to our team over the webpage, which is cohenhealthcarelaw.com, and we will be happy to basically get in touch with you and offer you solutions and answers that are fit for your specific matter.

Clara Salvai:

On our website as well, you’re going to be able to find a lot of resources such as articles, blog posts. If you want to know more about our team, our bios, and testimonials of clients that have become friends at this point and we have been walking next to them on their own venture paths for a long time. So, today, I’m going to be introducing you to my attorneys, Molly Fashola and Matt Stokke. Aside from the fact of their qualifications and their experience that they have on healthcare, the most important thing about our attorney is that they are amazing human beings and they enjoy a lot to do what they do. So, I want to actually give them the opportunity to share this time with you and for you to get to know them as well. So, without further ado, I’m going to give you Molly and Matt. Thank you.

Molly Fashola:

Thank you, Clara. We’re very excited to be here and give some information, at least a brief overview of what MSOs entail and some of the starting points for deciding if this is a route that you would like to go with.

Matthew Stokke:

Yeah, and thank you everyone for coming. As Clara said, this will be the first of a series of webinars on MSOs. So, today, we’ll cover the basics with you and I hope that helps in getting a firmer understanding of how this arrangement works.

Molly Fashola:

So, Claire, did you want me to go ahead and get started? The first question that we get a lot is what is the corporate practice of medicine? I do want to preface all this by saying that everything we’re going to talk about today varies by state. A lot of this is very state-specific. There are state-specific exceptions and various things that go along with the individual state that you’ll be practicing in or having your clinic in. So, I just want to let everyone know that, and it’s very most basic terms. The corporate practice of medicine is essentially a doctrine or a law in a given state that prohibits someone who is not licensed in the type of service that the practice will be working under from owning or having an ownership stake in that practice. So, for example, if you are a registered nurse and you want to open a clinic with a physician, unfortunately, you would be barred in some states from having any ownership interest in the clinic itself.

Molly Fashola:

There are some states where there’s a certain split of ownership that might work. For example in California, physicians, as long as they have 51% ownership, there is some leeway for non-physicians to have ownership in the practice as well. So, again, it’s very state-specific, but generally, if you’re not licensed in that service or if you are a corporation trying to own a clinic, a lot of states will prohibit that. Not every state is a corporate practice of medicine state. Some of the big ones that are pretty strict on it are California, Texas, New York, and then there are some states that don’t have this at all and so it’s a non-issue, but one thing to just keep in mind is that in those states that do have corporate practice of medicine, there are a lot of regulations around ownership and even the way that you register the entity whether it’s registered as a professional corporation or some other mechanism, but the key thing to remember is in corporate practice medicine states, if you are not a physician, you cannot have at least 100% ownership in the clinical practice.

Matthew Stokke:

I’ll add something to that, Molly, just about the actual operations of the practice as it relates to the MSOs involvement, and thankfully there’s some pretty handy guidance out there, one of which is in the medical board of California publication, and I think they list out certain services that in their view should be provided exclusively by the medical practice. So, those services are determining what diagnostic tests are appropriate for the particular condition, determining the need for referrals to or consultation with another physician. Responsibility for the overall care of the patient, including treatment options available, and finally, determining how many patients a doctor must see in a given period of time and how many hours a day or week the physician needs to work.

Matthew Stokke:

So, there’s some other conditions and situations they mentioned as well, but California Medical Board, as strict as they are, does have some pretty good guidance out there.

Molly Fashola:

Yeah, thank you, Matt, and on that same note, I just also want to mention one thing that we see a lot in what we do every day is questions related to medical spas where you might be doing some sort of IV infusions or injectables like Botox, and in some states, those items are considered the practice of medicine. So, they would fall under the same corporate practice of medicine doctrine. So, just keep that in mind as well.

Clara Salvai:

Perfect. That is really helpful, and with that first question, we are going to tie it up with the second, which is what exactly is an MSO? A must ask question too.

Matthew Stokke:

Yeah. So, an MSO, and some of you may already know what this is, but it’s not a term most people use, I would say. It stands for management services organization and an MSO compared to the medical practice is its own separate company, separate and apart from medical practices operations. So, in this arrangement, there’s two companies, company A, company B. The management company for short provides all of what it sounds like, management services, administrative services, billing services to the practice, as well as receptionist services, front office staff services, everything that you think of as nonclinical services when it comes to the operations of a medical practice. So, that’s what their exclusive domain is. Some other areas where MSO gets involved that MSO will often own the real estate where the practice is operating or they’ll be leasing it from a landlord and subleasing it to the practice.

Matthew Stokke:

They can own some of the non-medical equipment and supplies also. So, those are just some common services and ownership abilities the MSO has in its arrangement.

Molly Fashola:

Great, and just to add to that, Matt mentioned staffing. Another thing that we get asked a lot is to what extent can an MSO staff or clinical positions, and it’s a little bit complicated, but I just wanted to point out that for clinical positions, a physician still needs to have primary oversight over those positions. The MSO might be able to assist in some mechanism with regards to staffing, but the as long as it’s a clinical position, the physician will need to have the oversight over the training and onboarding of that position.

Clara Salvai:

Great, and with that being said, the next one that is related to this one is who can actually own an MSO? What is your take on this, you guys?

Molly Fashola:

So, an MSO, generally, again speaking in general terms, can be owned by a nonclinical person and I think that’s typically where we see the ownership questions come in. They can be owned by a clinical person who’s not a physician. For example, an RN, a nurse practitioner in certain states depending on what rights that nurse practitioner has to operate on their own, and it can also be owned by a physician. So, we do see sometimes someone who’s not clinical at all who will have ownership in an MSO and then a physician who will also have some portion of ownership in the MSO and so that depending again on the state is perfectly fine. So, there’s a lot more movement and flexibility when it comes to ownership in the MSO because you’re not necessarily bound in that case by having to be clinically licensed.

Clara Salvai:

Great.

Matthew Stokke:

That’s… Yeah.

Clara Salvai:

Matt, do you want to add anything to this question?

Matthew Stokke:

Yeah, I think Molly covered it well. I think I would just add too that it’s a subset of this question. Because MSOs are more flexible in terms of who can own them, they also tend to be more flexible in the kind of business entity that’s used to house all those MSOs services, LLC corporation. There’s no real limit like there is for the medical practice, which depending on the state again will have its own quirky rules and regulations about what kind of business entity that can be.

Clara Salvai:

Great. That is an amazing answer. So, one of the questions that we also got asked in different variations, but the substance, it was the same one. It was does the MSO help me to get around laws prohibiting non-licensed people from owning a professional practice? So, what are your thoughts on that?

Matthew Stokke:

My take on it is, and I get this question a lot. I don’t know about you, Molly, but I sometimes find that there are misconceptions out there, and there’s a lot of information floating around online about what an MSO can do for a non-licensed person exactly. So, the short answer here is that no, nothing will help anyone get around a certain law. There can be strategies, but in this case, no. The actual practice as we’ve been talking about, with regard to the corporate practice of medicine, would need to be owned by a physician. Sometimes, other licensees can own it, but at the end of the day, ownership in an MSO and setting up an MSO, practice relationship is not a way to get around any restrictions like that. So, that’s my take.

Molly Fashola:

Right, and I completely agree with that. I think it’s important to remember that in its truest sense the purpose of an MSO is to help with managing the administrative needs of a practice. I think in recent-ish years, people have realized that it’s also a mechanism for allowing nonclinical personnel to have ownership or have some investment opportunity in the practice and that’s great, but its true purpose is to administratively support the practice. I think that’s a good thing to keep in mind.

Clara Salvai:

Fair enough. The next question is for people who really are trying to get into the venture or people who actually are setting the structure, and so they submitted the question, how should the money flow starting from the patient visit to the MSO management fee? So, what are your thoughts directly on that question?

Matthew Stokke:

Yeah, so this is another big question, another big part of my time with clients that I dedicate to because again, I think there’s a lot of misinformation out there or rumors about how this can be set up really, but really, at the end of the day, what you want to have happen is the practice that the doctor’s operating under the practice much like a normal practice that does not have an MSO, because a practice is not required to have an MSO doing its management services. In a practice like that, patient goes to the practice site, receives a professional service, and they may have taken care of it before the professional service, but patient will pay the doctor or the practice for those services, and that’s because many states have a prohibition against professional fee splitting. So, it’s got to go from patient to doctor and then doctor/practice will then pay the management company according to the terms of the management agreement, typically on a monthly basis based on whatever the agreed upon fee is.

Matthew Stokke:

So, that is the general flow of money there that we… It’s really important to have that sit-down moment and make sure that is truly happening.

Clara Salvai:

Great. Molly, anything that you want to add on to this?

Molly Fashola:

I mean, I think Matt really covered it well. The only thing that I would add is we get a lot of questions about clients wanting to know exactly what the fee should look like or an exact number and there really is not an exact number. It’s really based on what fair market value for the services are, what makes sense in terms of what is being done by the physician versus what’s being done by the MSO. So, while I wish I could tell in California this is the exact amount, there really is nothing like that. It really just depends on the services being provided and the relationship and the agreement that’s made between physician in the practice and the MSO.

Clara Salvai:

Great answer. Thank you. So, we are heading into the last question of this round, and the last question that we have submitted for a bunch of people, it was, how can the MSO protect itself in this arrangement with a professional strategy? This is something that you guys deal so much on a daily basis. So, I’m pretty sure you have a lot to say about it. So, please.

Molly Fashola:

So, I think the best way to protect yourself especially if you’re going into this type of arrangement either as the physician who will be owning the practice or as the owner of the MSO is to consult with an attorney. I know you’re probably thinking, “Well, of course, you would say that,” because I’m an attorney, but it’s true. We do this every day. We see clients who are going in to these situations every day. We’ve seen a variety of different types of ways that this can be structured and different agreements and every agreement is different even if slightly. So, I would say that as the first and foremost best way to protect yourself. Another thing we help with is just making sure the structure is compliant. It can be really easy to just enter into this type of agreement with two parties and as long as you agree on the money, everything else falls by the wayside, but it’s really important to make sure that you’re structured in a way that complies with the laws.

Molly Fashola:

There are penalties both for the MSO and position if it’s not done correctly and it can affect things like licensure and there can be fines and different things like that. So, it’s really important to make sure that your structure is good, that your ownership composition is compliant. So, I would say that that is really the best way, making sure that your agreements are drafted well. We do have clients who a lot of times come to us and they say, “I found this agreement online,” and I tried to rework it and that’s what I’m using. While there are probably some great agreements online, it’s really important to make sure that your agreement addresses the specific concerns that you’re going to be having entering into this type of partnership. So, making sure that you really are consulting with an attorney who’s experienced in MSO structures, who’s experienced in healthcare law, that’s the best way to protect yourself truly.

Matthew Stokke:

Yeah, I agree with that, Molly, and I’ll be the second attorney to say there’s a million different agree minutes out there, form agreements you could find, but there’s also a million different ways those agreements are written. There’s different versions depending on who the attorney is representing and even below that, there’s different custom clauses that some MSOs might want that not all the others want. So, I think it’s really important to… Some examples of different clauses in those agreements that give the MSO a little more protection. One of them is the term of the agreement. Sometimes they want it to be… We always recommend a minimum of one year to support healthcare laws, but some MSOs want a longer term, three to five years, for example, because they want to remain locked into this relationship.

Matthew Stokke:

If it goes too high, it also gets problematic in different ways. So, that’s one way to protect yourself. Another way is who can terminate the agreement. Can it be terminated with cause, without cause? How much advance notice should be given? Those are just a couple ways of basic terms to the agreement that people often think about and sometimes if they sign a form agreement they found, they realize it may not have been the best way for them, and of course, there’s going to be other clauses throughout regarding liability and the different sharing of those liabilities that you’ll also want to be aware of, but yeah, I thought that was good answer for that, Molly.

Clara Salvai:

Thank you guys. That was really encompassing a lot of different and aspects. So, thank you. So, right now that we have gone through our round of questions, this is the moment when you all are invited to actually post your questions on the Q&A section or the chat section so that we can select some of them and hopefully we can give you some insights into your specific questions. So, we are going to take a couple of minutes so that we can just make sure that everybody has a chance and then we are going to start answering them. So, thank you, and I hope that you guys are enjoying this webinar so far.

Matthew Stokke:

This is not responding to a question yet, but I know there was some diagram that we may have rushed through. I was wondering if that can be put back on the-

Clara Salvai:

Yes, absolutely.

Matthew Stokke:

Just so people can see. It’s a helpful structure there.

Clara Salvai:

Yes. So, as you are actually placing your questions, do you want, Matt, Molly, to walk our viewers into this chart a little bit, explain the purpose and the information that is in there?

Matthew Stokke:

Yeah, sure. Molly. Do you want to take it first?

Molly Fashola:

Sure. It’s very small on my screen. So, I’m just pulling it over so I can have it there. Yeah, so this chart is really… Again, it’s not specific to any particular state. So, please keep that in mind, but it just gives an overview of the general structure of the MSO. It’s written from the point of view of the MSO owners. So, that’s why it says MSO, owned by you and LLC. Typically though, it can take other structures depending on the state, but that’s the starting point. So, you would form an LLC and have it be your MSO. You would also identify at that point a physician that you are going to be working with who will be the owner of the practice and so as the MSO, you’re going to map out exactly what services you’re going to provide. You can provide a wide variety of administrative services, billing, staffing, marketing, just collections.

Molly Fashola:

There can be so many things that you can provide to the practice. So, you want to map that out when you’re considering starting this MSO, and then once you partner with the physician, you’ll also want to identify what the physician responsibilities are going to be, what type of practice it is. We see a variety of practice areas, but we make sure that the physician is well-versed in that practice area, because again, they will have to have oversight. We do see sometimes people who are wanting to start for example an IV hydration type of clinic with the physician and the physician has maybe never done anything remotely related. So, for the sake of the physician’s ability to provide oversight, it’s important that they do have some sort of knowledge about the type of area that they’re going to be working in and overseeing.

Molly Fashola:

So, once you have that in place, then an agreement would be drafted where it outlines the responsibilities, the payment structure, and it also gives a guideline as to how the flow of money is going to work, how the flow of control over various aspects of the agreement are going to work. So, that’s the very basics of an MSO structure. As I said before, each structure is different. So, this can all be very different depending on what it is that you’re actually trying to do and who you’re partnering with and what type of services you’re providing, but in its most basic sense, you are the MSO owner. You work with the physician-owned clinic. There’s a transfer of administrative services in exchange for some portion of fee and the money flows from the patient to the physician, to yourself as the MSO.

Matthew Stokke:

Yeah, and I would add to this that in this chart that we have up here, it lists the physician-owned clinic paying the MSO a percentage of revenue. We’ll get into fee methodologies in a later webinar on this, but this just so you all know is available in some states but not others. So, New York being one of the quirky ones out there that last time I checked, a percentage would not be available there. So, that’s just something to be aware of as you look through this, but overall, I think this provides a really good flow chart in terms of how this relationship works. So, this is always very helpful for me.

Clara Salvai:

I hope that all the viewers are finding this chart and the explanations really interesting. I know that even I was replying some questions and comments on the chat, asking to really go in deep with the explanation on the chart. So, I think that you guys who are watching the webinar are finding the chart really enjoyable, so hopefully we are going to make this recording available so that you can always replay it should you have any questions about the questions that we addressed earlier and maybe you wouldn’t hear by then. So, that’s that. You guys, is there anything else that you want to add about the chart? No? Great. So, then, Matt, do you want to head into selecting on the Q&A some questions and Molly as well?

Matthew Stokke:

Yeah.

Molly Fashola:

Sure. I actually do see one that we get asked a lot. So, I might go ahead and address that, and it is does the position need to be local and in the area of the medical spa? We get this a lot especially in the post… I don’t know for post, but in the COVID era, there are a lot of questions related to telehealth and to what extent the physician needs to be in the area, and I can say in the most basic sense, the physician for sure needs to be licensed in the state that the medical spa is going to be operating in. Sometimes, I’ve had questions where physicians live in New York, but the medical spa is in California. Can the physicians still be part of this MSO structure? If they’re not licensed in that state that they’re going to be operating in, then they definitely should not be.

Molly Fashola:

That being said, if they are in the state, and they are not necessarily on-site every day because there is no requirement that they have to be on-site every day, but they have to be within enough proximity and reachable enough to provide that level of oversight. So, one example that I give to clients all the time is if you’re seeing a patient in a medical spa and they have some weird adverse reaction to a treatment that you’re providing, you should be able to reach the physician within some reasonable amount of time. So, for emergency situations, it’s really important that they are either reachable or nearby. So, all that to say they don’t need to be on-site every day, but they do need to be able to say with reasonable certainty that they can provide the level of oversight that is required to be a physician working in that practice.

Clara Salvai:

Great.

Matthew Stokke:

I’ll pick a question here which goes back to the flow of money. Can the MSO process billing for the practice, including credit cards, et cetera? I get that one a lot also. Yes, that is one of the services an MSO can provide is the billing services, but again, the important thing to keep in mind is it’s much like a normal front office person taking the credit card, processing it. Maybe there’s a copay. That money should hit the professional practice’s bank account first before a portion of it is paid to the MSO as the management fee based on the schedule in the management agreement. So, that’s the general answer there.

Clara Salvai:

Thank you, Matt. Molly, do you see any other that you want to address?

Molly Fashola:

I see a couple related to nurse practitioners, and I do just want to address it because there has been a recent change. I’m not sure if the people asking are in California, but there was recently a bill passed where as of 2023, nurse practitioners in California will have the ability to independently practice. So, I have had a few clients who have asked, “Does that mean that they can also then have ownership or work in an MSO structure essentially?” I did do some research specifically for a client about this a couple of weeks ago and I did not find any definitive research that said that they could not. In my mind, and this is strictly my opinion. I’m sure more will come out about this as we get closer to 2023 because that’s when the bill goes into effect, but if there are no restrictions and they are given the freedom to practice independently, then my thought would be that they would be able to be involved in a structure this, but again, we’ll have to wait and see as the law actually comes into place and if any additional guidance is provided to actually really truly understand to what extent they are allowing nurse practitioners to operate independently.

Clara Salvai:

Great. I saw some people actually addressing the same question on the chat asking it was like a repetition, like a little fan club in there asking for the same question. So, I’m hoping that whoever had asked that question is happy with this kind of oversight. Of course, we always stress this enough and I think that it’s valid to say it that just like when you go to a doctor because you really want to have a solution that’s specifically tailored for your medical condition, remember that when dealing with legal advice, which is not considered a webinar, it’s not considered legal advice, but when it comes to your particular matters, we always tell you that every little aspect of your business and everything that is involved in there is very specific. So, it deserves to be analyzed in a very specific manner too.

Clara Salvai:

So, even though sometimes you may think that something is similar in writing doesn’t necessarily mean to be like that, that’s why you always need a professional working with you so you can walk your path safely, right? Which is what we all want for everybody. Whether you become our client or not, we want you to be safe and to have an amazing future with your ventures and to be happy with it, right? So, I think that is valid to mention this. So, thank you, Molly. Matt, do you see any other question that you want to address?

Matthew Stokke:

Yeah, I think just two more quick ones. I’ve seen a couple questions here about if MSO is providing only non-clinical services, why does a licensed person have to own it? That’s not true. Anyone can own an MSO. You don’t have to be licensed and some other questions about… Let’s see. I’m looking for the other question here. You do have to be licensed however to be in a practice as we’ve been talking about. The other question I saw here, can a physician hold equity in a practice that is in a captive relationship with the MSO? They’re called captive PCs and captive professional corporations. Whoever asked that is sophisticated and has heard of a lot of different ways people are trying it out there, but generally for people who don’t know what a captive PC is, it is where an MSO through one way or the other, some sort of an agreement on paper or off paper basically has more control over the medical practice’s corporate affairs.

Matthew Stokke:

So, who’s going to be the CEO? Who’s going to be the new doctor if this doctor leaves? MSO has to approve all new shareholders of the medical practice, things like that. People are trying it out there. It’s a risk because it goes against the corporate practice of medicine prohibitions in these states where an MSO just should not have any influence like that over who’s hired, who’s fired, who gets to be the owner, things like that. So, though there are people trying it, don’t believe everything you hear in terms of this is okay. I think it’s like speeding on a freeway. You’ll see people going really fast, going really slow. You might get pulled over. You might get not. So, take it with a grain of salt what you hear out there.

Clara Salvai:

Great. Thank you, Matt. So, I think that we are nearing to an end, so Molly, a last one that you want to choose?

Molly Fashola:

Sure. So, I actually have a couple quick ones if you don’t mind that I just want to make sure-

Clara Salvai:

Of course.

Molly Fashola:

… we’ll quickly answer as many as we can.

Clara Salvai:

Go ahead. I’m pretty sure everybody will be happy about it, so please do.

Molly Fashola:

So, someone asked, “Does the MSO need to have malpractice insurance?” No. I mean, you’re not supposed to be doing anything that’s related to the practice of medicine. So, you don’t need to have malpractice insurance. You might want to consider strongly general liability insurance or some other type of business-related insurance, but malpractice would not be necessary. That being said, you can in an agreement agree to… And especially if a physician is an owner in the MSO, agree to covering some portion or some amount of his malpractice insurance as part of that, but the MSO itself would not need malpractice insurance.

Molly Fashola:

The other thing that someone asked is there a statute of limitations for stark or anti-kickback violations? This will vary, but generally, there isn’t. I mean, a lot of this is regulated by the government, so they can, and essentially, as it’s discovered is really when the statute would start running in most cases. So, you could have been doing it for 10 years, but once it’s actually discovered or reported, that can be the point where the statute of limitations would kick in. I have seen in some states that there is like a six-year statute limitation. So, that is something to keep in mind. Again, very state-specific, and then the very last question I guess that I wanted to address was someone asked if we had ever seen an MSO involved in litigation and what the general issues were.

Molly Fashola:

So, one thing with MSO litigation, I think Matt had mentioned it early on, that we see a lot is disagreements on termination, disagreements on payments, disagreements on responsibilities, and maybe one party feels like the other dropped the ball or didn’t live up to their obligation. So, yeah, there can definitely be litigation when working in an MSO partnership and so that’s again another reason why you want to make sure your agreements are as airtight as possible in terms of protecting yourself before you go into these things.

Clara Salvai:

Perfect.

Matthew Stokke:

And the funny thing about what Molly just said is that the way a lot of people try to get out of these management agreements is by saying that it’s an illegal agreement for some reason, whether the fee was illegal, or some aspect of it was illegal, but I just always have thought that’s a pretty funny argument to make because they entered into this legal agreement.

Clara Salvai:

Yeah, that’s fair. So, I mean, I’m seeing that people are still putting questions, so we are going to do one last, I promise, one last. So, Matt, please feel free to choose one last question so that we are closing the webinar with this one.

Matthew Stokke:

Let’s see.

Clara Salvai:

And also in the meantime, please let me remind you that we are going to make this recording available. For some of you who are making questions about like the questions that we addressed earlier, you’re going to have a chance to actually receive this recording on a newsletter so that you can replay it and hopefully you’re going to have your answers to the questions that you’re asking which basically were addressed earlier. So, again, if they are not addressed in this webinar, please keep on tuning in for the next ones who are going to also be on MSO. So, back to you, Matt.

Matthew Stokke:

Okay. Let’s see. A California-specific question. Does California allow for a percentage of revenue to be paid to the MSO? Yeah, we’ll address it more in the next webinar, but yes, there is an allowance for that. It’s in business and professions code 650 in California. It’s a complex area of the law. As Molly pointed out at the beginning, she used the term fair market value. That is the magic word in all these arrangements that no one really knows what it means because a bunch of legislators thought that that was the best way to phrase it as the going rate of what a management services organization providing the amount and type of services it provides would be paid. So, California does have an explicit allowance for that. It’s got to be a percentage of the gross revenues. I saw another question about net revenue. Gross is always the recommended way to go there.

Clara Salvai:

Perfect. Okay, so I think that it’s safe to wrap up our Q&A at this stage, and we hope that you had found the webinar interesting and you have learned a little bit and hopefully also had fun with us today, because we love what we do and we love to talk about these things. So, for whoever is out there and was seeking for some answers, we hope that you felt they were addressed, and the recording is going to be made available. We have a series of MSO webinars. Please stay tuned for the next ones, and another thing that I want to tell you is that we are beyond happy to have you here today with us. For all the family of Cohen Healthcare Law Group, we are looking forward to get connected with you, so please reach out. If you have any other questions, go to our webpage, which is cohenhealthcarelaw.com, and you’re going to see all the resources, articles, recordings, past webinars, our bios and so much more that we had placed with a lot of love and care into our webpage, and we hope to see you soon. So, thank you so, so much for being here with us today. Thank you. Bye.

Matthew Stokke:

Thank you all.

Molly Fashola:

Bye. Thank you.