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AHLA's Speaking of Health Law
Private Equity Is Not Private Anymore
Chip Hutzler, Partner, HMS Valuation Partners, speaks with Robert Homchick, Davis Wright Tremaine, John Kelly, Barnes & Thornburg, and Kim Harvey Looney, K&L Gates, about some of the special considerations facing private equity in health care. They discuss the regulatory environment private equity faces, diligence concerns, and managing risk. Robert, John, and Kim spoke about this topic at AHLA’s 2023 Health Care Transactions Program in Nashville, TN. Sponsored by HMS Valuation Partners.
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Speaker 2:Hello, everyone. My name is Chip Husler. I'm with, I'm a partner with H HMS Valuation Partners based in Nashville and Florida. And I welcome you to our podcast today. Um, this podcast is gonna take a look at a session called Private Equity is Not Private anymore. This session took place at the HLA Transactions Conference in Nashville in April. And the panelists from that session have been kind enough to join me on this podcast to talk a little bit about the topic and what , uh, they talked about and what we learned from it. Let me introduce those panelists with us today. We have Kim Looney from k and l Gates. We have Bob Holick from Davis Wright and Tremaine . Uh, Kim's in Nashville, Bob's in Seattle. And we have John Kelly in Washington from Washington DC He's with Barnes and Thornberg , uh, there. One . Welcome, all three of you. Thanks for being with us.
Speaker 3:Thank you.
Speaker 2:Let's dive right into this. Private equity is not private anymore. That's was, that was sort of the theme of your talk . Is that the worst problem private equity has? Bob, any thoughts on that?
Speaker 4:Uh, nope . Not its worst problem, but certainly , uh, I think they can expect, or private equity in general and owners of our investors and healthcare operations can expect more scrutiny. Private equity's biggest problem, I think now is a PR problem where , uh, there is a assumption around private equity , uh, being , uh, money being inconsistent with some of the , uh, thematic goals that the not-for-profit or even the , uh, traditional for-profit healthcare systems have embraced in terms of , uh, commitment to the community , uh, patient care and so, so forth. Um, my , uh, I think as with all generalizations , um, it's a bit misguided. Uh, there are , uh, private equity, just like not-for-profit providers, just like for-profit providers come , uh, in all shape, sizes and stripes and , um, private equity does a lot of good in healthcare. Uh, it can also create problems , uh, when , uh, as any provider who's not paying attention or who goes in with , uh, a , you know, a a misaligned intent , uh, could have negative implications for the delivery of care in a community or for a particular system or down the line.
Speaker 2:Well, you raise a great point. It , it , and , uh, Kim, did you have something you wanted to add?
Speaker 5:Yeah , I was just gonna say that one of the reasons that we talked about it not being private anymore also is just that there's additional government scrutiny on that. And the first sort of provider group that's come up is your nursing homes and your skilled nursing facilities that, you know, they want to see who owns those. And that's something that private equity has always kind of private itself on the fact that it's investors are private, they're not necessarily disclosed to anyone, much less the government, where all of a sudden it becomes public records . So that is something to be watching. I think that that's something that is probably gonna spread to the other provider groups. Provider types .
Speaker 4:Yeah . C m s is certainly signaled that , uh, the , the step that it took with private equity and requiring , uh, disclosure of all , uh, of owners , um, is going to , uh, be , uh, probably the standard for other healthcare facilities, providers and so forth.
Speaker 2:Yeah. Picking up on the theme you raised , Bob, that maybe not all private equity deserves the, the wrap that they're getting in the press isn't more healthcare, more investment in healthcare a good thing. I mean, that's really what they're doing is bringing more capital to the table. Uh , healthcare's historically been strapped for cash. Isn't that a good thing?
Speaker 4:No, I think so. Oh , go ahead Kim.
Speaker 5:I was just gonna say it depends. I think Bob was about to say the same thing. I mean, it can be good, it can be bad. I think when Bob also was talking about the PR issue, you know, it's, it's, some people assume that just because the money's coming from PR that it's somehow tainted and that there's an assumption that it is not going to be providing the best care. And so, you know, that's sort of the bad side. But the flip side is what you said. I mean, a lot of providers and a lot of , uh, healthcare entities need money and the money needs to come from somewhere, and private equity has some money to spend. So, you know, in a lot of ways it allows for innovation, it allows for more healthcare in different areas. And, and I think the innovation's one of the big pieces that providers all of a sudden have money to do things they weren't able to do before.
Speaker 3:Yeah. And I think , I think that's also why it's somewhat attractive to private equity, right? The c opportunities for innovation, which creates opportunities to, to have a very positive cashflow investment. Right. And, and to Kim's point , um, I I , I feel like you sometimes see the government sort of feel that there is something wrong with being profitable or making money. And what people tend to forget is that you need money to create new therapies, to create new products, to provide new services and be innovative, right? And, and so it is a very interesting balance. So I think everyone's right. It can be good, it can be bad, but when it's good, it's real good.
Speaker 4:I I think one of the, the issues, I'm sorry , uh, chip, but
Speaker 2:No, that makes sense.
Speaker 4:Is no one argues that our system is operating efficiently or operating at, you know, it's highest and best. And I think private equity funding can help us explore some changes, some models , some new , uh, innovation that otherwise the , the money wouldn't be there. Uh, what do , uh, the money wouldn't be there to, to experiment in that way. And I think that is one of the great things that private equity is doing for the , uh, for healthcare that it's not really getting much credit for on the PR front.
Speaker 5:They're taking a lot of risks when they put their money in and, you know, they've got the ability because they have enough money to be able to take those risks, but a lot of your healthcare companies do not have the flexibility to do that. So that is definitely, as Bob says, and as John said earlier, when when it's good, it's really good.
Speaker 2:Yeah, that's tho those are all great points. I mean , it kind of leads into the discussion that y'all had in the webinar about, or , or rather in the , uh, in the live session ab about the idea that there is some concern, obviously that there is a lot of profit taking that goes on with private equity. Private equity is looking for a certain rate of return. It's generally higher than maybe the return on investment of other types of investors and that, hey, we might rather that money gets spent on healthcare. But , um, is there anything that anybody can do about that? I mean, the idea here is they take more risk , they should get more reward. So, you know, is that a problem or is it really a red herd ?
Speaker 3:You , I I , I , I'd be interested to , uh, to hear what Kim and Bob think. I mean my, my impression has always been that this is the exact spot where private equity gets in trouble in healthcare, right? Is there is risk. They are making an investment if they don't appreciate the risk and understand the risk the way they should. Cuz healthcare is completely different, as we all know than most other industries in terms of regulatory oversight and complexity of regulations and rules. Then , then that's the problem, right? I I , I don't even think it's about making or not making money. I think it's about not appreciating the risk that you're getting yourself into when you have private equity and doing all the things you're supposed to do on the front end and then on the back end after you invest
Speaker 5:It is one of the things you ask your clients. I mean, if they're looking at some sort of a private equity deal and it's a healthcare client, what experience does this private equity entity have in healthcare? Because if they don't have any experience in healthcare, then there's gonna be a little bit of a steeper learning curve because , you know, I think as we mentioned in the conference also that, you know, what can make good business sense in any other industry? It's not, and , and it would make good business sense in healthcare. You just can't do it in healthcare because of all the government regulations. And you know, somebody asked me one time a long time ago, well why does the government, you know, pick on doctors or something? And it's like, well you know what, if you didn't get, you know, 30 to 50% of your reimbursement from the government, they wouldn't be able to quote pick on you. But you know, they're spending the money so they get to make the rules.
Speaker 2:Yeah. Uh , great , great points indeed. Uh, I I think , um, it raises a couple of good points and we'll probably come back to the one , uh, that you mentioned Kim a little bit. But , uh, j John mentioned the regulatory concerns, right? Um, you know, I think there is a concern about maybe private equity not understanding the regulations very well, cuz they are very complicated. But are they saddled with as many regulations as other parties in healthcare part of the allure for private equity that they don't have some of the regulatory requirements that say hospitals have or pharma companies may have , uh, because they're billing the Medicare program a lot? Well,
Speaker 4:It depends on what private equity is doing. How are they playing the game? If they're coming in as a provider, they're gonna , you know, have all of the same issues that another provider would have with the same licensure. You know, if they're investing in hospitals, investing in ASCs or whatever, if they're more upstream , um, you know, doing some sort of , uh, case management or, you know, even farther upstream. So , you know, digital health , um, in terms of the infrastructure, I , they may have fewer regulations than people who are directly laying on hands. But competitors are also, you know, in the same spot. There, there are some advantages that private equity has that I think we're all aware of in terms of if you are a hospital or health system trying to buy a physician practice, for example, or employee physicians , um, you've got more regulatory constraints than a private equity new I investor will have if it tries to buy the , the same physician practice or employ the same group of physicians or physician or physicians.
Speaker 5:So yeah , there's no referral source or referral relationship between the private equity and the physician group, whereas there is with the hospital. So sometimes it's very hard for the hospitals who want the physician practice to be able to compete with the private equity. On the other hand, if the hospital and the physician practice are still pretty well aligned , it's maybe somewhat to the hospital's benefit for the private equity to get in the mix and to be the one providing the money because they're able to save their money to do other things. But y you're right, there are, and Bob's right, depending on what the private equity is investing in, there can be fewer regulations or there can be the same regulations in the same regulatory framework.
Speaker 2:And then once they buy it, obviously maybe on the buy-in they don't have the regulatory concerns that , uh, other buyers would have. But once they buy it, there are some regulations right, that apply that they have to be careful with. And that's where, to John's point, sometimes they get into trouble cause they're not familiar with those, right,
Speaker 5:Right. No ,
Speaker 3:That , yeah, I think , yeah, sorry Kim , go ahead.
Speaker 5:No, go ahead John . Yeah ,
Speaker 3:No, I was gonna , no, I think that's right. Um, that is where that, that is where you can have an issue, right? If you're not getting people with the right expertise and the right knowledge to come in and advise you and guide you through that transaction and then post-transaction , um, you know, what are the expectations? What are , what do you do from a compliance perspective? Did you identify anything on the front end that you need to clean up now on the backend post acquisition ? And then just sort of going forward, and as we talked about during our presentation, right, there's all these things that the government's looking at as they're starting to focus not just on the portfolio companies when they get in trouble, but on the, in the private equity investment fund and taking a look at how much involvement they have, how much knowledge, just day-to-day , uh, information and, and direction and all of that can start to factor into risk.
Speaker 2:Yeah. And you government had ,
Speaker 5:They'd go all as far up the chain as they could to get as much money as they could,
Speaker 3:Right ?
Speaker 4:I , I think we're private equity , um, gets a bad rap or, you know, it , uh, I shouldn't say gets a bad rap , but the mistake that can be made is to underestimate the importance of compliance. Um, and yes, there's a problem. Uh, and I think people in , uh, startup phase are used to taking a fair amount of risk, and I don't think they're necessarily always distinguish between the risk of loss and the risk of enforcement activity. Uh , you know, this might not work from a business standpoint is different than I know I'm billing the government in a way that is questionable or wrong. I can't, I don't have the funds to fix that right now. I'm just gonna wait. That sort of decision has more significant implications in healthcare than it may in in other industries. And I think that's where not only having the right advisors, but really understanding the risk you are running by , um, actively making a decision that it , a problem that's come to your attention doesn't need to be addressed in the short run or maybe ever.
Speaker 2:Yeah. And that's a topic obviously lots of healthcare people are familiar with , um, of course. Um, and we've talked about it many times , uh, those of us on this call about how it's not just the cost of the mistake, it's the cost of defending even if you didn't make a mistake , um, and so on and so forth, right?
Speaker 5:Right. And it's not just like the risk of just losing money because it was a bad business investment. There's a risk of maybe it was a good business investment, you didn't operate it appropriately. You allowed, as Bob said, you don't fix the compliance issues on the front end. And, you know, just the amount of time, the amount of claims, everything that that gets ends up getting billed and appropriately just increases the loss just exponentially. And, you know, and, and if it's clear that you've done something wrong, there's really no hiding from that. I mean, you know, it's kind of hard to defend some billing practice that was totally inappropriate. If there's something that's, you know , questionable or could have been subject to interpretation, then, you know, a lot of times there's something you can do to defend it, especially if you have a robust compliance program. But you know, Bob , you wanna take, okay , what if they don't have a robust compliance program?
Speaker 4:Well, yeah, I, I think private equity investing in , um, a fast growing , uh, but relatively new , uh, provider group of whatever sort that had, you know, maybe operated on a shoestring, they, they have evaluated this , uh, uh, the cashflow and everything else based upon that skeletal infrastructure rather than maybe what the entity needs to really be a long-term sustainable. And there you're talking about, you know, is there a compliance program in place? What have you seen in due diligence? And do you have, are you asking the right questions with the right level of expertise to know whether or not this is a good investment if I fix this or this is a good investment straight up , uh, with, because they've already, you know, got their ducks in a row and have been paying attention on the , uh, compliance side.
Speaker 2:But you raised the diligence question, which is an interesting one. Uh, I mean, obviously when somebody buys something and they're paying a , a large multiple, they hope it isn't a fixer upper . But , um, shouldn't private equity firm be really good at diligence? I mean, isn't that what the Wall Street world is all about, doing a good job on the diligence and uh, you know, something they should know how to do maybe as well as any buyer out there. Um, but, but yet what I see is the idea is that, well , a lot of the reporting anyway suggests that that's sometimes where there's a breakdown, right?
Speaker 5:It depends on how familiar the private equity entity is with healthcare. I mean , you really have to know what you're looking for. I think that's really where, you know, the rubber hits the road is if they're not at all familiar with healthcare and they start out with what they would normally do for any type of, you know, like a , you know, a retail operation where you might pay people commissions to do certain things, you know, that is not something that's appropriate in healthcare. So you really have to know what you're looking for.
Speaker 2:Yeah. Healthcare has a lot more closets, doors that you have to open, right ? To look behind maybe , maybe the way of thinking of little rocks you gotta pick up that other industries maybe don't have .
Speaker 3:Yeah, well it's also, I mean, there's also kind of an irony to it, right? Because when you think about private equity, they're betting on this asset, right? They're betting that it's gonna be, it's gonna make money, it's gonna be successful. But yet at the same time, if you're thinking you're gonna get through on a quick turnaround or you see an issue and you're not , and you're not addressing that issue, as Bob was talking about from a compliance perspective, all you're doing is hurting the value down the road, right? I mean, those are the things that sneak up and bite you later , uh, a as any company in healthcare. So, you know, to answer your question, yes, they , they should be good in due diligence and I think a lot of them are very good at it. But it also depends on, as Kim mentioned, the experience they have in that particular industry. Cuz everything's a little bit different , uh, and also the counsel that they're using to guide 'em through the transaction and afterwards.
Speaker 4:And you've got the state law differences too, where, you know, you launch in , uh, the northeast and then you decide I'm gonna move into the Midwest and to California and so forth. And every state's gonna have its own wrinkle , uh, or wrinkles in terms of how , uh, healthcare can operate. Uh, and that, you know, that's a challenge , uh, for any company really trying to take something to scale.
Speaker 2:Yeah, the podcast probably too short to get into all the different state law issues. Obviously corporate practice is a big one in some states that can affect private equity investments. No doubt. And you guys covered that well in the session if anyone wants to watch the recording of the session, that's , uh, something you guys talked a little bit about and some other lots of sessions do mention that issue as well, that talk about private equity topic. I wanna move in the direction of one of the things you said in this session. Kim alluded to it earlier in our podcast, this kinda idea that health law doesn't care whether something makes business sense. Um, now my first thought was, well, yeah, they do, there's this commercial reasonableness idea, right? But commercial reasonableness is sort of a hypothetical construct at times. It says, well, but in the, you know, in the absence of referrals, right? Even if there were no business between the parties, well, that's not the way private equity is thinking about what makes business sense, right? Uh , so it's a little bit of a hypothetical construct sometimes. Um, but does it, does that get in the way of some of these transactions that, that private equity is focused on really needing to make sure the business is viable and understanding where the revenue is coming from, which is kind of cuts against the health law. Obviously
Speaker 4:The moral hazards in healthcare are different than the moral hazards that are addressed by other public policy considerations. And I, I don't know if that's always appreciated, nor do I necessarily agree that the , the statutes and regulations designed to address the moral hazard of a physician be having a financial interest in the entities that it's referring. Uh , he or she is referring to, that those laws necessarily work or make sense. And one of the really difficult things I think in working with anyone who's new to healthcare is explaining something like Stark. It's like, it makes no sense. It , it oftentimes is counterintuitive and yet it's strict liability. And you know, it, it's the type of , um, regulation that makes people hate government , uh, and think this can't be the law that's just stupid. Uh, unfortunately, for those of us who've been around a while, we know because it's stupid. Doesn't mean it's the law and not the law. I mean, you know, we, we live with this every day and , uh, kind of get used to the fact that the regulatory environment often is at odds with what , uh, what government and others will say should be our , uh, patient care and , um, you know, efficiency and other , uh, priorities in terms of health , the healthcare system and healthcare delivery.
Speaker 5:Well, and I think even Pete Stark before he passed away said if he had had any idea what he had started with what was called and has still called the Stark Law, he would not have done it. And so there are legislators who do feel like it goes a little bit too far, but I've seen nothing really trying to carve it back. And it is the one thing because it's strict liability. It's , it's the one that's more of a bright line. You know, you if, if you have X and you don't, you know, it , it just is something that's gonna be controlled. You have to be very careful with those relationships.
Speaker 2:Yeah, maybe a little bit outside the scope of what we o of your session and what we're talking about, but no doubt , um, there's been a lot of controversy over whether that law should be scaled back, kept the same. It obviously is a source of a lot of recovery and so on. Um, but it, it strikes me as the , the conflict that I was getting at was really the idea that on the one hand, private equity, if they act like a , a good business actor would act in other industries, it would be sort of a fiduciary duty to, to ensure that the revenue is , is, you know, is viable so that you know, you're buying a business and you can deliver the returns you want. You need to know something about where the revenue's coming from over in healthcare. Just be very careful with that tightrope , uh, as we all know. So , uh, how do they square that up? As Bob points out, they don't always realize that going in, but they learn it quickly if they, they don't know or they won't. Let me ask this question, kind of related to that is, if , if that's not the worst thing that keeps you up at night, what is, when you think about private equity transactions, you guys have, have a lot of clients you've had to deal with on these, whether you've set up the transactions or defended them. What keeps you up at night? John, let's hear your thoughts on that.
Speaker 3:Um, I think the, the thing that would keep me up at night would only be some of the things we touched on already, right? Is, is identifying red flags or compliance issues and they're not being an appetite to fix them. And, and I've been fortunate not to see that very often , uh, in my, in my career. And, and you know, I think sophisticated , uh, private equity firms that have sophisticated counsel will, will do their best to make sure they get the ducks in a row. Cuz you have to remember, one of the things we really haven't talked about too in this industry of healthcare is you're buying into a business where the federal government is financially encouraging people to identify problems with your business to the tunes of millions of dollars, right? Not just like $50 millions of dollars right. Under the False Claims Act. So , uh, again, I think what would keep me up at night is, is folks making investments who don't understand the business and don't address the issues when you see them thinking, we'll deal with it later, or it's not gonna hurt us later. We've never been hurt before. That's, that keeps me up.
Speaker 5:Yeah. They don't wanna listen to the advice that you're trying to give. Yeah. You know, sometimes the only thing sometimes that might give them pause is, I am not going to be the one wearing orange if you do something wrong. And the government now is also not just going after companies, but the people behind the companies with, you know, the eights p m o . So that's something that really hopefully does give them pause. You don't want someone, you want a client who wants to be compliant, so you want private equity if they don't know on the front end that's willing to learn and listen to you about what they need to do. I mean, yes, it's not always clear. There are different risks, there are different levels of risk , but someone that will understand and appreciate those and, you know, really I think listen to you in what you're trying to tell them .
Speaker 4:The the related issue that I think , uh, you know, all of us struggle with is am I talking to the right person or have I advised the , uh, right , uh, section or portion of, of this organization? And when does something need to go, you know, up the chain and am I destroying a relationship if I in fact , uh, try that. And I think private equity, this isn't unique to private equity, but private equity often complicates that.
Speaker 2:That's a great point. One more kind of new one to think about. Um, I've seen some commentary that sort of think of the private equity investment in healthcare sort of looking a lot like the, the nineties, right? A little bit of a house of cards . They're paying these huge multiples, maybe in some cases paying the doctors lower salaries than they made before and hoping they don't remember that a few years from now and wonder why they, you know , uh, I hope they do remember it rather than wonder why they're not making what their colleagues might make and all that sort of thing. Do you see that as a danger with private equity that we sort of head down a road that looks a lot like the Phi core thing in the nineties where , um, where we , we went down a road that just wasn't sustainable and then it all kinda fell apart?
Speaker 4:Well, my silver ball or crystal ball is a little bit hazy on this <laugh> . Um , I do think that , uh, folks learned something from , uh, the fico , uh, model and that there is probably a greater appreciation on the need to change practice patterns, not just, you know, walk in , uh, with a new management contract that takes something off the top. So time will tell whether, you know, they can, you know , uh, achieve the efficiencies in what still is in many, many areas. The cottage industry, you know, or , uh, uh, you know, small mom , uh, smaller groups certainly changing, but becoming bigger groups that aren't necessarily managed or, you know, the informatics aren't as sophisticated as they need to be to really manage , uh, the increasing demands that are put on physicians as they, you know, write orders and , uh, determine how the rest of healthcare is gonna spend its money.
Speaker 5:We like to think people learned from the mistakes and are not going to at least duplicate those same mistakes that would be made. There may be new ones, but hopefully not those same ones.
Speaker 2:Certainly new doctors now that weren't around then , but , um, but yeah, I hope there's some, some advisors who remember back that far. I'm barely old enough to remember back that far <laugh> . Um , but in any event , uh, one more and then we'll wrap this up. Um, anybody worried about what's going on with the FTC with respect to private equity transactions? Didn't, you guys talked a little bit about it in your session, but
Speaker 5:Yeah , I mean, there's more antitrust scrutiny too. I mean, just, you know, it's almost like as soon as you almost have manageable risk and control in one area, you know, kind of like the, you know, it's not private anymore. The government wants to know all the way up the chain who owns what it's crust, they're gonna scrutinize who's putting money in where. So, you know, it's kind of like just when you've gotten one piece, it's kinda like playing whack-a-mole where something else is gonna come up. And I think that's sort of where we are, that you do have, you do have more scrutiny and antitrust also.
Speaker 4:Yeah. And the , the state ags playing an increasing role in reviewing, you know, any sort of material transaction in healthcare. Um , certainly along the west coast, Washington, Oregon, California, they're all , uh, all have material transaction statutes. New York recently came up with a , uh, its own, and there are several other jurisdictions , um, Massachusetts and the like. So , um, they , whether it is, you know, D O J F T C or the State Attorney General , um, the odds of your deal closing with no one looking at it , um, are , uh, are declining, let's put it that way, which , um, makes it more challenging to do kind of what private equity does best, which is come in and close a deal quickly.
Speaker 2:Yeah . I wonder, do they have to build that into their cost then?
Speaker 4:They will need to. I mean, I, it's not just private equity that faces these material transactions, true requirements. There's, you know, the , some , uh, you know , the , each of the statutes has its own sort of flavor of the month. Uh, but it , uh, it ev it's a increased cost of business for everyone , uh, really.
Speaker 2:Mm-hmm. <affirmative> Kim, did you have a thought? Sorry, we might have , I might have covered ,
Speaker 5:Um , yeah , I think y'all covered it in between, but there there is just more kind of going on. I do think that you have to consider the cost of dealing with all of that.
Speaker 3:Yeah. And that that's right where we started, right? That's why it's not private anymore, right ? I mean , look at us coming full circle.
Speaker 5:Well , I guess the one thing I was gonna mention is when you're doing a private equity transaction and you're trying to disclose, you know, ownership of the chain, private equities goal goal is to disclose it as far down the chain as you can. And, you know, you frequently have discussions with the government people who get to decide how much you have to disclose about at what point can you cut it off because there are, you know, even if you're the lawyer working on a deal, you don't even know who all the owns are of the chain in private equity. I mean, it's, it's that private for the private equity people who are investing, you know, I think even the people you're talking to don't know all the investors. They just have all these different entities and some of the , the work charts for private equity and deals are just some of the most complicated things that I have ever seen. Just amazing how all the ownership branches out.
Speaker 2:Yeah. And I can imagine, you know, blowing that up in some big action somewhere on a courtroom, in a poster board, getting to be a real mess and the cost of spending time explaining it all later is certainly one we'll all be talking about. The next time we do this podcast, well wanna thank my three guests, Bob Hoick , Kim Looney , John Kelly for being on today. Thank you all for joining and thanks for the session you did at transactions. It was a terrific session. Raised so many interesting issues about this topic that were ones I hadn't thought much about before. So I appreciate that and really appreciate everyone being on today. Check out their session if you can, and we're glad you joined us for this podcast, podcast , and we'll see you all again soon. Thanks everyone. Thanks everybody. Thank you.
Speaker 1:Thank you for listening. If you enjoyed this episode, be sure to subscribe to a H L A speaking of health law wherever you get your podcasts. To learn more about ALA and the educational resources available to the health law community, visit American health law.org.