Christy Street, Horne, LLP, speaks with Ritu Cooper, Hall Render Killian Heath & Lyman PC, about commercial reasonableness concerns in health care valuations and arrangements and the differences between commercial reasonableness and fair market value. The podcast also discusses the definition of commercial reasonableness in the recently-issued Stark Law final rules. Sponsored by Horne.
To learn more about AHLA and the educational resources available to the health law community, visit americanhealthlaw.org.
Christy Street, Horne, LLP, speaks with Ritu Cooper, Hall Render Killian Heath & Lyman PC, about commercial reasonableness concerns in health care valuations and arrangements and the differences between commercial reasonableness and fair market value. The podcast also discusses the definition of commercial reasonableness in the recently-issued Stark Law final rules. Sponsored by Horne.
To learn more about AHLA and the educational resources available to the health law community, visit americanhealthlaw.org.
Support for A H L A in the following message comes from Horn, what's changing in healthcare valuation? The buy-in podcast from Horn engages healthcare attorneys and in-house counsel and lively conversation about trends and best practices in physician comp, hospital mergers, value-based arrangements, telehealth, and more brought to you by Horn Buy-In is available on Apple, Google, Spotify, and wherever you get your podcasts.
Speaker 2:Hello everyone. I'm Christie Street, a senior manager on the valuation team at Horn based in our Mississippi office. Horn is a top 100 national professional services firm with a thousand team members across the US and Puerto Rico. We specialize in healthcare serving over 600 hospital health system, long-term care and physician clients across the country, and providing everything from accounting and data analytics to tax and valuation. Joining me today is Retu Cooper, an attorney with Hall Render in their Washington DC office. Retu, thank you so much for being here. Can you tell our audience a little bit about your practice?
Speaker 3:Christie, thanks so much for inviting me, um, today to join you. I, I really appreciate it. I'm, I'm thrilled to be here. Um, and as Christie mentioned, I'm a shareholder with Hall Renders, uh, DC office. Um, hall Render is the largest healthcare focused law firm in the country. Um, I co-chair the firm's compliance service line. My practice consists of representing healthcare providers such as hospitals and health systems, physician practices, and life sciences companies in regulatory and compliance matters. Um, particularly I I focus on counseling on fraud and abuse, um, compliance related to Star Kickback and the C M P law. And, and then get a chance to work with Valuators like the Christie often, um, with helping to make sure the arrangements need all the, the elements of an exception. I assist with conducting internal investigations that may lead to voluntary disclosures as well as responding to government investigations. Last but not least, uh, I do quite a bit of work with providers who are under CIAs, helping them manage the requirements to ensure compliant.
Speaker 2:Today we are gonna focus our discussion on commercial reason list. In light of the pandemic, several organizations began to evaluate certain physician arrangements less from a fair market value perspective and more from a cost savings perspective. These discussions that Retu and I had, um, touched on many commercial reasonable considerations worthy of note, we've been working together with a few clients on these matters and thought it would be great to share some best practices with all of you. And then in November, right in the middle of us preparing our thoughts for this podcast, c m s released its long awaited final rule for the Stark Law. For the first time, c m s actually defined commercial reason list in the regulation and provided much anticipated clarity in connection with commercial reason list fair market value and volume and value of referrals, as well as other key regulations. As many of you know, commercial reason list fair market value and volume and value are key elements in a number of Stark law exceptions for compensation arrangements. Re two, in your opinion, why is the noted distinction of what C M S has dubbed the big three? So important?
Speaker 3:Uh, thanks Christie. Um, yeah, you know, separating the big three is huge for our clients, um, uh, especially on our clients who've struggled with the three concepts of fair market value, commercial reasonableness and volume and value of referrals when trying to support their, their compensation arrangements with physicians. Um, for the longest time, there wasn't a clear definition, right? Uh, there, there wasn't a definition. There kind of was some commentary that that c m s included in, in the preamble and, and, and some of the final rules. But, but nothing that, that we could say was a concrete definition. Um, so as outside council and valuators, I think we've always definitely understood that there were three distinct elements, commercial reasonableness, fair market value, and volume and value referrals that our PR providers needed to meet in order to satisfy some of the relevant compensation exceptions. Our clients, however, did not always understand the, the clear distinction between the three, primarily because c m s intermingled the language when they were talking about one of the concepts and, and, and with one of the other concepts, right? So, you know, um, and, and so it just made it hard for people to, to understand that there were three, three distinct requirements. Um, so, um, but, you know, and I think that, that it's, it's most evident in the times where I've been engaged to work with clients, and then I say to them, you know, as a, an attorney, I don't opine on fair market value commercial reasonableness. I can help you with the other elements. Have you engaged in an outside expert for this particular, uh, arrangement? And they, oh, yeah, yeah, we've, we've engaged evaluator and we have evaluation, and it's, and it tells us it supports the arrangement, um, and that it's commercially reasonable and fair market value. Well, then you read the agreement and you realize that the agreement, I mean, not the agreement, you realize, uh, that the opinion only color covers FM B, and there is no mention at all of commercial reasonableness. You know, I've found this to be quite surprising in this day and age when there has been so much case law and government commentary that talks about the need for compensation to not only be fair market value and commercially reasonable. Um, so Christie, why is it that that many valuation opinions do not opine on commercial reasonableness? When you and I know that commercial reasonable is a key requirement of a number of the compensation exceptions,
Speaker 2:Often we are asked to only apply on fair market value. And many times I find that the scope limitation can range for, for a number of reasons, but it's often fee sensitivity. Um, the client can also have very strong operations or a compliance team with, uh, the, the proper policies and procedures in place to document commercial reason list. And it may even be that many consultants are not comfortable with a pining on commercial reason list. And so, as evaluator, uh, it, it's been my opinion to view fair market value and commercial reason list as separate concepts and separate requirements under Stark, which typically, typically means different scopes of work for the drafting of set opinion. Um, when being engaged by healthcare providers, we often, we are often asked to only opine on fair market value as a noted, and at the onset of that project, my team and I, um, will probe the client to remind them of the concept of commercial reason list, and to offer to either extend our scope to cover commercial reason list for them, or to have discussions with them to help them understand the importance of documenting commercial reason list, and that it's their responsibility to do that and to hopefully give them the tools to do that on their own if they're not willing to have us aine on that for them. So, and in, in the cases in which a provider, um, doesn't engage us Toine on commercial reason list, our engagement letter clearly states that as well as our opinion of fair market value. Rtu. What's your experience been with in these instances,
Speaker 3:Kristi? Yeah, you know, I mean, as I mentioned, I I just think a lot of providers just don't appreciate or have not to date appreciated the distinction between the two. And, and I think that they assume that when they have engaged an external third party consultant, that that paper that they receive, that opinion covers them for fair market value and commercial ness. Um, some, I think even could probably even just take commercial reason list for granted, right? They think, oh, well, I got an opinion for fair market value, I'm good. Um, I've stated that I have a need, so what more do I need to do? Uh, so I think it's great that Horn is so explicit in, in your engagement letters and, and your written opinions, um, with providers that if they've limited the scope to just F M V, you very clearly state that this opinion or this engagement is for fair market value and not for commercial reasonableness. And, and, and I will tell you, um, maybe I haven't reviewed one one of your arrangements where it's been limited like that, but if I would've seen that, I think then it, it, it would be very clear, right? And then I couldn't say that the, the client didn't know. Um, but, you know, with c M s highlighting the importance and distinction of each of the big three, particularly, you know, as we're talking about today, commercial reasonableness, um, I think more providers are going to understand that the two are separate concepts and that they need to have documentation for both. Um, whether that documentation is something that they do internally or they go out for, for an external, um, assessment, but I, I think they're, they're definitely going to understand the, the difference. You know, as you know, um, let's kind of look at like c m s commentary and how it's evolved related to commercial reasonableness. So in, in 1998, right in that final rule in the commentary, c m s stated that commercial reasonableness is evidenced by an agreement, which appears to be a sensible, prudent business agreement from the perspective of the particular parties involved, even in the absence of any potential referrals. So see, right there in that statement, they've co-mingled the idea of volume and value referrals, right? Mm-hmm.<affirmative>, and I say even in the absence of referrals, but then in oh four, their commentary stated that an arrangement will be considered commercially reasonable in the absence of referrals, right? Again, talking about the volume by referrals, if the arrangement would make commercial sense if entered into by a reasonable entity of similar type and size, and a reasonable physician of similar scope and specialty, even if there were no potential d h s referrals, right? So, so already some of the concepts are, are, are, are being intermingled. Um, but now, you know, if we look at this new definition that c m s came out in the, in this 2020 final rule, it, it looks like they've taken some of the concepts from both of their previous statements and, and tried to synthesize it in a, a more simpler statement, right? So now the definition is, um, uh, commercial reasonableness is, is, uh, an arrangement that furthers a legitimate business purpose of the parties to the arrangement and is sensible considering the characteristics of the parties, including their size, type, scope, and specialty. Um, the added part that they've now also added, um, is that they've made a very affirmative statement in the regulation that an arrangement may be commercially reasonable, even if it does not result in profit for one or more of the parties to the arrangement. Um, so Christie, does this c you know, this codification by c m s of this definition related to commercial reasons, change anything in the way you, um, are gonna do your commercial reason work?
Speaker 2:So the short answer to that is both no and yes. I say no first because in my opinion, I've always looked at, always used CM S'S commentary on commercial reason list as a guiding post for commercial reason list evaluations. I've viewed commercial reason list as an, as an arrangement making business sense, and I've supported the debate that certain arrangements resulting in a profit loss could still make a valid business sense. I'll also say yes, because having the new definition, um, and the commentary accompanying the final rule takes the guessing out of determining what c m s is thinking related to commercial re, you know, to being commercially reasonable. C m s, they shed some light on what provi, you know, what providers should consider when trying to support that arrangement is commercially reasonable, namely, focusing on, as you stated earlier in the definition size type, scope and specialty if applicable of said provider. And so when drafting a commercial reasonable opinion, we have historically asked a handful of questions, um, that address key factors that we consider to support, um, the finding of commercial reason list. So, based on recent guidelines, uh, I'll touch on quickly just a q uh, a few of those thoughts that we think are those key factors, um, for con consideration. Uh, first I think that consideration, if a transaction includes, does that transaction include the consideration or fulfillment of community need or broadening or enhancing access to care, particularly if that's charity care. Uh, I think it's also important to that, that arrangement ties to and ties directly to, um, an organization's mission, vision, and values. Um, it's also important that that arrangement enhances, uh, the ability to fulfill your certain licensures or, um, regulatory obligation requirements such as emala, right? And, um, you know, I think you also need to look at the potential impact or cost reduction that the arrangement may, um, create, uh, or the avoided cost of something often. You know, a a a great example of this is a call coverage arrangement. And you may ask, you know, do you, you know, why are you paying for said call? Well, one, EMTALA re requires that access to care. And two, your only other alternative than perhaps negotiating with a certain physician group for the coverage would be reliance on a locum tenons company for coverage. And, you know, locum tenons coverage is often substantially higher than what you're paying under a physician call coverage arrangement. And that's really a short-term solution. So, in closing, kind of as my on on thoughts on that would be, um, you know, it's very, very important to state why this arrangement or agreement is the best option. And, and so I think if you consider all of those things, then you're really, um, developing a healthy argument for why, um, the arrangement is commercially reasonable. And with that in mind, rtu, as I see it, in my opinion, um, healthcare attorneys play a vital role in facilitating the discussion with the parties to document why an arrangement is the best option. So in your opinion, what is your role counseling clients regarding commercial reason list?
Speaker 3:Um, yeah, Christie, that's a great question. Cause I think it, it, it falls in into a number of different kind of categories, but to me, I think our goal is to help clients understand that commercial reasonableness is a separate and distinct element, right? From a legal perspective, it's a separate element, right? That they must satisfy. Um, and, and, and I think, you know, our role is to help them take what they get from you as the consultant and try to figure out how to operationalize that internally. Um, so if they've received this questionnaire from you, or your opinion has a number of statements that, that summarizes the information you received based on, on the, the questions and the questionnaire, um, then I think my job is to then help the clients figure out how to document commercial reasonableness going forward. So if they didn't in the past, have a process, help them draft some type of process, um, you know, I, I often find, um, with the clients that I work with, I guess I just work with really great clients, but I often find that clients have a commercial reasonableness reason, right? They have a, a, a, a legitimate reason to enter into this arrangement. It's not nefarious, it's not to capture, um, to capture referrals. Obviously, we all wanna be profitable or, or profitable is not the right word. We all want to, um, to make sure that our businesses thrive, and you wanna have the best individuals that are part of your organization, right? No, no one's gonna say, oh, yeah, I'm gonna go choose this terrible, uh, physician to, to contract with. But so I think they, they, they know why, um, right? I struggle is actually figuring out, well, what part of that why, um, do I actually document and how, how do I articulate it? Mm-hmm.<affirmative>. So the questions that they received from you, um, in, in that questionnaire, probably sometimes for the first time is allows them to sit down and think about, how do I actually put this into words?<laugh>? So I, I can't tell you how many times, um, you know, uh, uh, the engagement is, is under privilege, and I'm working with the clients, probing them and saying, okay, you've received this, these questions from Christie and her team. Well come on, let's, let's you, I know you know this, but let's figure out how we put this down on paper. So anyways, so that then springboards, as I was saying, into putting together a, a process in place. And, and oftentimes, um, that process maybe includes them creating a questionnaire of their own that they can pull out to their business team and ask their business team to, uh, to fill out prior to executing the contract. Um, but, you know, one thing that I've kind of seen or heard, um, is that there are some consultants that shy away. And I think you, you mentioned this a little bit earlier, that there could be some that shy away from providing a commercial reasonableness opinion. Um, and then you see in the commentary of the final rule, um, C M S noted that the determination of commercial reasonableness is not one of valuation. Uh, Christie, what does that sentence mean to you? I mean, how does that impact the valuation community
Speaker 2:Read to you? That is, that is a great question, and I suspect that there will be varying answers to that question within our community. Um, we may see some that have the point of view that valuators should no longer provide opinions or document commercial reason list. Um, and rather this should be an analysis for legal counsel. Um, however, in my opinion, the statement further, it really further delineates commercial reason list from fair market value, and it emphasizes that commercial reason list is not a sub-component of fair market value. Uh, I think this statement, that commercial reasonable list is not a question of valuation. It really means that whether an arrangement is commercially reasonable does not turn on whether it fits within the fair market value range. Again, I think it's a further delineation of the two fair market value and commercial reason list. I believe the valuation community can and really should assist healthcare providers with a valuing whether an arrangement is commercially reasonable, in fact, the evaluator's independent role, um, we see many arrangements in the marketplace and we're really in a great position to evaluate, um, one, whether a deal is sensible or not. You know, two, whether, uh, it furthers a legitimate business purpose. I mean, most of us are number, I mean, we're numbers people. Um, if you're not, you probably shouldn't be evaluator. Um, and then, but, but then three, the scope of the arrangement. I mean, we, we, again, we've seen a number of arrangements and so we can help, we can help, um, identify the arrangement, scope, the, the weak areas just based on what, what we've been able to see. Um, and then whether or not that arrangement it takes in, um, it makes sense, um, in light of the entity as the type of entity, the size of the entity and, and perhaps the specialty of said physician or physician group that the arrangement is with. So while the commentary provided by C M S clearly states that the determination of commercial reasonable list is the responsibility of the parties to the arran, uh, the agreement, um, and that it's not the role, uh, and it's not, uh, a question of valuation. Part of our role, again, as I see it, part of our role as independent valuators is to help our clients capture the story, um, behind each arrangements for both fair market value and commercial reason list. And in many cases, valuators can add value to that discussion by helping the parties evaluate the cost associated, um, with other options to the agreement, as well as tie it to the qualitative factors, particularly when a loss is expected, um, with those qualitative factors. And so often, um, the provider's profit loss, um, will drive the desire for an outside consult consultant's opinion of commercial reason list, and, you know, asking us to help them document why that loss makes sense. And again, it's previously mentioned, um, the, in the final rule, it's specifically highlights, and you mentioned this earlier re too, uh, that an arrangement does not have to be profitable to be commercially reasonable. And so while again, I think that the evaluator working an an independent evaluator working with, um, a healthcare attorney, um, is, is is best suited actually to help our clients determine, determine commercially reasonableness. I am curious what your thought, your thoughts on the statement about that c m s clearly, um, made in the definition that an arrangement does not have to make, make a profit, um, to be commercially reasonable. I'm curious on what your reaction to C M S'S commentary regarding the profit and losses and, and why is that so important for c M S to spell that out?
Speaker 3:Christie, I will not lie to you. I think that statement arguably hands down is the most important statement that C M s made. I agree. Um, related to the definition of commercial resource. And you know what? Honestly, I could probably take it or leave all the other pages if I just had that statement. Uh, uh, very seriously. I mean, to me, um, it has been such a challenge working with clients, um, especially for example, related to employment agreements, um, where, I don't know a provider in the United States that can say that they make money off of their employed physicians. Um, it's a necessary evil, right? It, it's something that you need, uh, for your organization. Um, but you're, you, you're doing it because of the community need. You're not doing it cuz you're going make a profit, right? And so we've struggled, I mean, with mm-hmm.<affirmative>, The, the fact that the government previously and, and case law argued that a loss of profits does not make commercial sense and the cases and settlements highlighting that if a physician's compensation exceeds professional collections, then those arrangements can't be commercially reasonable. So to me, that sentence, I mean, I think I read that sentence and I said, hallelujah. I mean, it was, it was, it was huge. So, um, so I, so I think that by c m s doing that, okay, one, I think they're acknowledging that there isn't a hospital in this country that makes money off of their employed physicians, um, specifically, but, you know, in general with, with commercial reasonableness. Um, right. And I think what they're doing is they're acknowledging that commercial reasonableness, um, when you're looking at that, it's not a purely quantitative analysis that there's a qualitative perspective to it as well. Um, and I think this can then really truly allow hospitals to focus on, um, the qualitative aspects and, and, and, and serving that legitimate business purpose and not worrying about the financial impact. Um, because I mean, for years, you know, working on, on defending clients with that have had false claims act cases brought against them, um, or just working with clients that are trying to put together their comp models,<affirmative>, it, it finances has been such a big part of it because they're like, how do we do this? Um, and not have a loss with profits when we know we're going to, but we know it's important to have these physicians on board. So, so I think that, um, the, that sentence, I, I can't say enough about how, how important it is and, and how huge, uh, of an acknowledgement that was from C M S's perspective. So I think now that, you know, those qualitative factors, and some of this comes directly from what you noted in the things that, that you look at, um, but, you know, know reasons could be improving the access to care and, um, improving quality of a, of a particular, uh, client, uh, provider service line, or fulfilling regulatory obligations, right? Mm-hmm.<affirmative>, I mean, some of it's like tala, I, I mean, so, so whatever that might be, I think they now can feel very comfortable that by them saying that, um, and selecting a provider to fulfill one of those needs, um, they should be able to meet the commercial reasonableness, um, uh, requirement. Um, but I think that, you know, one thing that you noticed that kind of struck me is that articulating that why the specific agreement is the best option. Um, so, you know, I don't know if they necessarily have to weigh every single, um, right option out there, right? But, but saying that this one is going to meet one of these needs and, and, and why they've selected this arrangement and, and how they're setting it up. Um, and, and I mean, sometimes, you know, just like you were saying, like the locum tenons issue or whatever, I mean, there, there aren't that many options that that, that are out there that might not even create a further loss for the organization. So, so to me, I, I, like I said, I cannot stress enough how, how excited I was, um, that c m s put this in place. And, and I think that, you know, they, they definitely are, are strengthening the idea that, that we can have a balance between qualitative and, and, and quantitative facts when we're considering commercial reasonableness and, and, and documenting it.
Speaker 2:Thank you for that re too, and, and if it's all right, I, I think let's, let's shift our conversation slightly. Um, and note that the new definition, it clearly states that an arrangement furthers a legitimate business purpose, right? Um, for the parties to the arrangement, and that it is sensible considering the characteristics of the parties, and we've mentioned this multiple times already, but including their size, type, scope, and specialty. Um, I think it's important for one to note that when working with professional services arrangements, um, meeting the new definition of commercial reason list is not explicitly required. However, personal service agreements have to ensure that the aggregate services covered do not exceed those that are reasonable and necessary for legitimate business purposes. My point of view has been that while the commercial, uh, reasonableness requirement isn't explicit in the PSA exception or the personal services agreement exception, um, commercial reason list is still part of the equation for personal services, um, in those agreements. And so I was curious read too, what are your thoughts on that?
Speaker 3:You know, uh, Christie, it's funny you should say, you should ask that because when I was reading the, the final rule, I was actually really surprised to see the government say that, I mean, for my 15 years of practice, um, based on obviously the, the commentary that they had written before and the verbiage that they used when they were talking about commercial reason list, I mean, it, it made me always believe that commercial reason list was part of the PSA exception. Um, so to me, I agree with you. I, I think that organizations should still consider why the arrangement makes sense and they should document, uh, those considerations. Maybe it's not a full blown out commercial reasonableness mm-hmm. Argument, right? Um, but, but maybe it's a mini<laugh>, a mini commercial reasonableness, um, argument. But, but I think that they should, you know, talk about the, the legitimate business purpose that they're trying to advance, which is part of the story for commercial reasonableness, right? Right. Um, but one thing that I, I've, I've been thinking about for the last few weeks since the final rule came out is with c m s investing all of this time in, in the defi in the defining of right or defining commercial and making the statement about, you know, don't have to be profitable in order for it to be commercially reasonable, um, will the regulators now, um, have much more scrutiny over arrangements with regard to commercial reasonableness, right? Because now they've given the tools, um, will, will they? And so that's something I'm thinking I've been thinking about a lot. So, so that's why I agree with you, I think, to, to be, to be safe and to cover yourself. Um, even though commercial reasonableness is not an explicit requirement or explicit element, and the government has said that the statement regarding the legitimate business purpose or the, or the services being reasonable and necessary is distinct from commercial reasonableness. I, I, I think you still want to make sure that you're documenting that and, and you're, you're, you're safer if part of your process is with arrangements where you're triggering compensation with physicians, that you make sure that they're, they're legit for legitimate business purposes, and you kind of have that commercial reasonableness element to it. Um, I think it just bolsters, um, bolsters it. But anyways, I am curious to see the scrutiny that, that CMS is gonna place, um, on it
Speaker 2:As I am. That's, that's, I think that's a very, um, a very valid point and, and one certainly for consideration, and it will be interesting to see what, what happens. Um, we'll read you as we begin to wrap up, you know, our time together. It is, it's been said that the final rule was enacted to simplify things for our clients and to facilitate value-based care arrangements, which is something we haven't really talked about today. And, and something that there will be a significant amount, I suspect, of dialogue, um, within our community in the days to come. Uh, but you know, a again, to simplify, you know, things for our clients facilitate value-based care arrangements, you know, since this discussion is regarding commercial reason list, and as I said, not so much about value, value-based care arrangements, do you believe that the new definition of commercial reason list and the delineation from fair market value in particular simplifies things for a provider? So it, it accomplishes that first goal, if you will, um, at least from an administrative PERS perspective.
Speaker 3:Um, so I'm gonna take one of your answers earlier, yes and no. I, I do think that by having a clear definition of commercial reasonableness, and in fact we even talked about this, but the fair market value definition also looks much cleaner than it ever did, you know before. I think there are aspects of it that, that make it simpler. Um, and then if we look at other things, right? I think the writing requirement, the signature requirement, the, the, the fact, the 90 days to document it and to sign it, and you can use contemporary is document, uh, to prove the writing, the fact that you can use e-signatures, you know, what is said in advance. I mean, I do think those types of, um, headaches that we had before that were like technical issues that really didn't go to the heart of the arrangement. We had everything else together. I think those aspects definitely simplify things. Um, but the value-based exceptions, I don't know. Um, maybe that's one of the reasons why we didn't try to tackle that today. I think they're quite complicated. And, and one of the biggest aspects that makes them complicated is that the definitions for each of the terms that they use in those value-based exceptions rely on the other words that they're using. So, and almost every one of the exceptions, I mean e every one of the definitions, there is a mention of another defined word. Um, so I, I, so I think the value-based exceptions are, are, are complicated, um, and we'll take some time. Now, I do think that the things that, that the government wanted to accomplish in terms of moving from, from volume to value, I think they're weak, right? And, and kudos to the government for getting this out before the end of the year, cuz I, I wasn't, I wasn't sure if it was gonna happen. So, so I think that, that in that aspect, there will be certain things that yes, we see, um, simplicity and it will make it easier for our clients to be compliant and, and, you know, less disclosures that we need to make because of a technical violation. So I think that's great. Um, but I think there's still a lot of work to be done. I mean mm-hmm.<affirmative>, it, you know, it, it, it's just, there's still more to, to unpack related to, to the rest of the rules.
Speaker 2:Well, rtu, thank you so much for your time today and sharing your thoughts and your ideas with us. Um, I have found it to truly be a pleasure of working with you and, and I look forward to serving clients together and, uh, navigate these uncharted waters and these interesting times together. So again, thank you so much for your time and I, it's, it's, it really has been a pleasure,
Speaker 3:Christie. I could not agree with you more. So again, thank you so much for inviting me to talk to you and, and I've really enjoyed working with you and I do hope that, that we can continue to collaborate because I do think that when council and and evaluator work together, we are able to provide the best service to, to our clients. So thanks again and, and happy holidays.