In this episode of AHLA's monthly series on fraud and abuse issues, Matthew Wetzel, Associate General Counsel, Compliance Officer, GRAIL, speaks to Leia Olsen, Compliance Officer, Ascension, and Scott Taebel, Partner, Hall Render Killian Heath & Lyman PC, about self disclosures to CMS, OIG, and DOJ, including the benefits, requirements, and expectations. They discuss the strategies that drive an organization’s approach to self disclosures, how the process works for each agency, types of outcomes, and key challenges and issues that providers might face when issuing a self disclosure. From AHLA's Fraud and Abuse Practice Group. Sponsored by BRG.
Listen to April 2021 episode, which discusses the Advisory Opinion process.
To learn more about AHLA and the educational resources available to the health law community, visit americanhealthlaw.org.
In this episode of AHLA's monthly series on fraud and abuse issues, Matthew Wetzel, Associate General Counsel, Compliance Officer, GRAIL, speaks to Leia Olsen, Compliance Officer, Ascension, and Scott Taebel, Partner, Hall Render Killian Heath & Lyman PC, about self disclosures to CMS, OIG, and DOJ, including the benefits, requirements, and expectations. They discuss the strategies that drive an organization’s approach to self disclosures, how the process works for each agency, types of outcomes, and key challenges and issues that providers might face when issuing a self disclosure. From AHLA's Fraud and Abuse Practice Group. Sponsored by BRG.
Listen to April 2021 episode, which discusses the Advisory Opinion process.
To learn more about AHLA and the educational resources available to the health law community, visit americanhealthlaw.org.
The following message and support for A H L A is provided by Berkeley Research Group, a global consulting firm that helps organizations advance in the areas of disputes and investigations, corporate finance and strategy and operations. BRG helps clients stay ahead of what's next. For more information, visit think brg.com.
Speaker 2:Welcome to the latest edition of the American Health Law Association Fraud and Abuse podcast. I'm your host, Matt Wetzel, and this is the second in a series of podcasts about requesting and receiving direct fraud and abuse guidance from the agencies. Today we're talking about self-disclosure to c m s, to oig, and to do oj the benefits, the requirements, and the expectations with us are Leia Olson, compliance officer with Ascension and a healthcare lawyer with deep experience in assisting providers with investigations and self-disclosure. Also, joining us is Scott Table, a partner in Hall renders Milwaukee office, who advises providers on a variety of healthcare related matters, including guiding them through the self-disclosure process. Lek Scott, welcome. Layoff. We start with you if you want to kinda share your background and experience any, you know, maybe your experience with self-disclosure as well.
Speaker 3:Sure. So I have been, um, a, well, right now I'm not a practicing lawyer. I'm a compliance officer, um, for Ascension, uh, overseeing investigations and incidents, which it, in that role in relevant here includes overseeing any self disclosures that we would have, um, as an organization. But, uh, historically, I, I am a licensed attorney. Um, I worked at Hall Ren for the first 11 years of my career until 2017, um, and really focused my practice on compliance issues in, in the healthcare space. Um, so that span from, you know, Medicare billing and payment, voluntary refunds, oig, G C M S, self disclosures, any sort of government investigations, um, and then, uh, came in-house to Ascension in 2017 and kind of continued that sort of work, um, on an internal basis for the organization. So have done a number of self disclosures, um, over time, you know, working through the, the investigation piece, the, the actual preparation of the disclosure, determining a strategy, um, you know, as, as Scott will attest to as well. Um, you know, depending on the type of issue, you might have multiple different avenues to consider of which way you wanna go, um, and how you wanna address it. So working through that strategy and then working through, um, resolution.
Speaker 2:Um, and Scott,
Speaker 4:Yeah, thanks Matt. And, uh, thanks, uh, Leia, we, uh, we miss you, but we enjoy working with you on the other side.<laugh>. Um, Matt, I've been practicing for, why don't we wanna say how many years? Um, but for, for quite a while. And my practice, um, focuses really almost exclusively on government enforcement. And, uh, self-disclosure is, you know, in advance of that. Uh, and we've seen in many instances, as I'm sure you're well aware, that self-disclosure can be a very proactive compliance risk mitigation strategy, particularly if something could later escalate, uh, into a government investigation. But, uh, work on really both sides of that. Um, we tried to, to do a rough count as to how many of these that, that I've been involved in, and I think, I think we're up, uh, over 120 of them, um, uh, regarding both the, uh, OIG and C M s and on occasion we've even gone directly, uh, to the, uh, department of Justice. And as lay indicated, we're, there's also kind of the voluntary refund aspect of this, which I don't know if we want to, you know, use our discussion to address that type of self reporting strategy, but obviously, you know, um, that's within the continuum as well. But each one of these has its own story. And, and as Lea alluded to, I mean, they have to be fully investigated. The underlying conduct that's in question has to be remediated. Uh, and then the idea obviously is to package it all up, uh, with reassurances to the government that, you know, the conduct in question will not recur. So, um, it becomes a very important strategy, obviously, particularly with the organizations that have effective compliance programs in place.
Speaker 2:I, um, I trust you have some interesting anecdotes from those experiences.
Speaker 4:Like I said, each one, um, is its own story. Um, the, a lot of those are to the oig and I, I will say that we do consider it a privilege working with the OIG staff attorneys on those. We have developed, uh, you know, some rapport, no, some of those folks, I, I think in some cases we've had, uh, a couple dozen self disclosures with the same staff attorneys. So through, through the, the period of time, you know, that we're talking about it, it tends to make the process more predictable. Mm-hmm.<affirmative>. Um, and, and hopefully, you know, there's some familiarity there too that, that, uh, can help with the process.
Speaker 2:A and that gives, gives credibility to the work that you're doing for your clients as well, which is, which is a, you know, a tremendous benefit. I'd be interested in hearing a little bit about, um, you know, kind of the strategy here, right? I mean, I think you, you, you said it, Scott, you know that sometimes these, it, it can be a strategic move to kind of, you know, maybe fend off an enforcement action in the fu in the future. What's sort of generally, you know, Leia or Scott, a strategy that goes into, um, one of these self disclosures?
Speaker 3:Um, I mean, I think, you know, obviously depending on the type of issue that depending on the type of potential issues involved, will sometimes drive the approach, right? I mean, if you have just a, you know, true technical stark violation, your only option for that is a C M S self-disclosure. Um, well, I, I should caveat that with, unless your referrals are so low that you wanna go the voluntary refund route, but, um, if you, if you have a, a high volume of referrals due to a problematic, um, stark arrangement, that's a A C M S disclosure approach, um, there might be approaches with the O I G, um, if you have potential fair market value concerns, you know, combined with, with a stark concern. And so I think you look at, you know, what are the various different options? What are the referrals you're talking about? Um, you know, are we aware of any potential whistleblowers or any potential government action or, um, that they're looking at any particular issues? And as Scott mentioned, each of the approaches has, you know, their own pros and cons of what you get with that, what releases you might have, what sort of publicity or announcement there might be, um, through the different approaches, what the releases would cover. And so I think you have to really think about all of those things, um, based on the specific facts and circumstances of what you have to really advise the client on what the best approach is, um, in that situation. You know, if you have a situation where it might, you know, in normal circumstances you might consider kind of a, a softer approach, but you have concerns of, of, you know, strong concerns about a whistleblower, you might instead deci decide to go straight to the DOJ or, you know, take a different approach, um, given whatever the facts and circumstances are at that time.
Speaker 4:Yeah. Yeah, I think that's a really good description, Matt, and it, it's really kind of a risk assessment, I think, in, in terms of what, what type of, um, behavior or overpayment are you talking about? And do you really want to come out of the process with some kind of release? Um, the, the timing of resolution can also come into play because some of those procedures are a lot more timely than others than I think the other, the other element too, from a, from a timing standpoint is if, you know, if you've identified the overpayment, you probably wanna, um, implement your self-reporting strategy within 60 days after that based on the, um, overpayment refund rule, uh, regardless of, of whatever, uh, particular self-disclosure, uh, self-disclosure procedure you use. So it, it really is defined by the risk, I think, and, and, um, the feeling that the organization has that it could escalate.
Speaker 2:So tell me a little bit about, um, uh, you know, sort of the, to the typical outcome or the typical, you know, end result for a self-disclosure now, and, and you've already said, you know, each one is its own story, so maybe there isn't a typical outcome. Uh, but, you know, what's sort of the, you know, maybe a better, better way to phrase it is what's sort of the spectrum of outcomes that you could anticipate from a self-disclosure and, and, and maybe we think about that agency by agency, you know, c m s, oig G and, and do oj
Speaker 4:Sure. Lay, you want me to start with OIG and you can take CMS
Speaker 3:<laugh>. Oh, I don't, I don't know that I'll have much to say because I don't know that we have much specificity there,<laugh>. Sure, go ahead. You get to cover do OJ though.
Speaker 4:Okay, that's fine. Um, yeah, I think with the oig, Matt, it's actually a very predictable process. Um, you can see right in the OIG self-disclosure protocol, for example, um, there's reference to, uh, most of those self disclosures will be resolved within 12 months. Mm-hmm.<affirmative>, uh, there's actually reference to the standard multiplier that's apo, you know, applied to the damage total. Uh, and you know, we have actually seen, particularly during the public health emergency that, uh, those cases flow through the process actually much more quickly than 12 months. Um, in, in fact, we've seen some here, uh, while the covid period is, has been in place where the OIG has basically given self disclosing providers the option of either to put the self-disclosure on pause or to continue. And for those that where the self-disclosing provider has opted to continue with the self-disclosure, we've actually had some, uh, conclude within, uh, well within six months after submission. That's crazy. So, you know, the end result is a, uh, settlement with the oig, it's the standard self-disclosure template with a release under the civil monetary Penalties law, uh, and a requirement that, you know, the damages be wired within X number of days to the oig. Uh, the other part of it that, that people need to appreciate too is the OIG do post, uh, a summary, you know, the self-disclosure cases that have settled on their, uh, website, um, after resolution of the case. So that, that's kind of the way it looks. You know, the cases are assigned to individual staff attorneys to, to review the submissions and ask any follow up questions that, you know, they think are necessary. But that's kind of, uh, the way it would typically flow. Um, you know, upon submission,
Speaker 2:It sounds as if the process is, you know, very much, you know, a well paved path, so to speak, and you're not going to expect necessarily much contention or conflict in the process.
Speaker 4:Yeah, it, it, um, you know, the, the ideal scenario would be that the OIG essentially accepts the self-disclosing, uh, provider's portrayal of the damages, and then typically, uh, the penalty would be 1.5 times that amount. That is really the best case scenario in that situation. Um, sometimes though, you know, there are questions about how the damages were calculated, the methodology that's used, sometimes additional information is requested, but overall, yes, I think that's a, that's a correct, um, characterization of it. It is a fairly, um, well-identified kind of systematic process to, you know, put those compliance risks to bed.
Speaker 3:I would just add to that though, that I think a key component of ensuring it goes that way is doing a thorough investigation, making sure the issue is correctly remediated and fully corrected before you disclose, and really being forthcoming and outlining, you know, what the issue was, how it occurred, what you've done to fix it, um, and being forthcoming with the information. Because certainly in my years of private practice, we did have situations where, you know, there might have been a client who had taken a, a different approach, um, with kind of their initial approach to OIG kind of saying, I'm not sure, we're not sure that this is really a problem or not. And I think, you know, the OIG is gonna react more favorably, have less questions, and the process will be much smoother if you have a very well prepared self-disclosure and you're being forthright of the information. If you're kind of trying to be cute with the facts, one, your release is only as good as the details you provide, right? So if you're not describing everything, and if you had great facts, you wouldn't be in a self-disclosure situation to begin with. Um, but, but I think that is critical to ensuring that smooth process and, um, you know, showing the OIG that you really take it seriously, that you have an effective program and not trying to, you know, kind of hem and haw about really what occurred. Um, I think they would, would probably not look at that as favorably and might be a little bit more, um, hesitant or ask more questions and, um, it might not be as smooth of a process if you're taking that approach.
Speaker 2:So it sounds like there's kind of a, a, you know, a, an important recipe of ingredients here, you know, in addition to, you know, ensuring good relationships, uh, with OIG with the agency so that, you know, there's credibility, uh, there's also full transparency if you decide to go down this road, you need to be ready to, to show kind of everything. Right? And that means being prepared in advance.
Speaker 4:Yeah, the, I, I think the, the best preparation, Matt, is, um, basically a thorough and probing internal investigation to, to essentially show the government. There really isn't anything else for them to do. Um, and as Ale alluded to, you know, that steps have already been taken to correct the problem. So essentially it's done, you know, it's a thing of the past. Uh, the provider identified it and corrected it on its own. The provider obviously took it very seriously based on the extent of the investigation and the, and the self-disclosure itself carefully, you know, determined what the damages were. Um, and then basically, you know, was they were fully transparent, um, and provided any in information that the OIG needed. I mean, that, those are all signs, I think typically where the government would conclude that it doesn't really have to do anything else, um, to get it to resolution.
Speaker 2:You know, it's interesting. I'm thinking right now, just as a compliance officer myself, you know, I often think the best, you know, prevent prevention is, you know, being able to demonstrate that, you know, we're able to regulate ourselves and we have, you know, good cl clear clean controls, and we enforce those controls and we enforce them, you know, authentically. And it sounds like this is just another extension of that, you know, saying to the government, um, we are able to, you know, regulate ourselves. In fact, we found this, you know, error or issue and, and, and here's the information. How does it work on the C M S side? It sounds like it might be a little bit different. Uh, when it comes to
Speaker 3:CMS<laugh>. Uh, yes. I would say that the, the approaches is slightly different based on the experiences that, that we've had. Um, so the C M S does have a protocol just like the OIG does, that outlines kind of what is required as part of the disclosure. And I think to the point of our discussion about, you know, doing a thorough investigation and being forthright in your disclosure, I think those are all relevant on the C M S side as well. I think that the primary difference is the predictability of, um, of how long it will take and any sort of damages calculation. Um, so c m S does not, unlike the oig, they don't set forth a specific timeline, um, for, you know, for resolution and for anyone that has gone through a C M S self-disclosure, as they are likely aware at this point, um, C M S has a significant backlog of self-disclosure. Um, so we're seeing, you know, mul many years, essentially from the time a C M S disclosure is submitted to where you might might hear from C M S as to that. So, whereas the OIG kind of commits to having that resolved within 12 months, you know, give or take, once it's accepted into the protocol, um, you know, there's, there's many C M s disclosures that have been kind of been pending for a number of years. The, the challenge with that too is that, you know, someti C M S laws have changed over the past number of years. So if you have a disclosure that was submitted in 2014, some of those laws have changed since then. Um, C M S does, similar to oig sometimes come back with questions, um, and then they don't really have an established settlement, um, you know, approach to determining a settlement amount. So you can't really anticipate in advance what the settlement amount will be, the same way you can with the OIG who has a standard 1.5 multiplier. And, and in some sense that makes sense because, um, from a C M S perspective, again, those are technical stark violations. And so while the referrals may from a, a true legal perspective, be prohibited, if you have a, a problematic physician arrangement that doesn't meet a stark exception, you don't have a fair market value concern. You know, it might be a late signature, the contract was never signed, but you were still paying fair market value. And so it, it does not appear based on, you know, the settlements that have been resolved over time and even the kind of the summaries and statistics on C M S'S website that the settlement amounts are tied to referral dollars. Because if you think about, you know, you have a, a technical violation related to a, a contract with a neurosurgery group, well, your referral dollars could be extremely high, and if the settlement was based on that, nobody would wanna use that disclosure approach. Um, so, but there's really no way to foresee or anticipate what the actual settlement amount will be, because c m s doesn't really give information on how they calculate or what they do to come up with a proposed settlement approach. Um, similar though, there's, there's a settlement agreement, um, you know, that, that would be signed. They, they can ask follow up questions. Um, and then, um, on the OIG side, they do a small, you know, small summary description on the OIG website. On the C M S side, I think it's just the, the general statistics overall. There's not any, um, you know, specific announcement related to any one self-disclosure or, or settlement.
Speaker 2:It almost seems to me as if, um, I don't wanna say that the, the processes are sort of opposing in nature, but, you know, there's something about the OIG process that, you know, speaks to uniformity, you know, consistency, predictability, transparency. And on the c m S side, what it sounds like is it's, you know, a little bit more of a black box, so to speak. And, uh, you know, my reaction is, you know, maybe that would discourage providers from self disclosing under Stark or to C M s and I, I don't know if, Scott, if you have any thoughts on that, whether that goes into the client's calculus, but, um, it, it seems to be, it seems to me it's almost like a, a, a disincentive to, uh, to disclose to, to c M s.
Speaker 4:Yeah, it's an interesting point, Matt. Um, you know, as an example, and, and I I wanna say too, I, you know, I assume C M S is doing everything they can to try to move through the queue that Yep. Um, Leah described, and, and I'm sure there's, you know, there's challenges, um, with resources because I think providers, you know, with technical stark violations, unfortunately, you know, the recent rules are helpful, but, you know, there really isn't an option other than to self-report. And as lay indicated, a stark only, um, violation has to go through the c m s process. But, you know, in reality for someone who's looking for resolution of a self-disclosure, I mean, you were asking earlier about anecdotes. Um, we have one that was pending with c m s for eight years at, with really no, um, follow up since the submission that we just recently, you know, received some, uh, questions about. And, you know, that's a tremendous span of time to try to gather information at this point. And it's really hard, you know, um, to, and I, and I think C m s understands that. Um, but it would be great if, if some of those pending c m s self disclosures could start moving through the process because it, you know, the access to information, the turnover and the staff involved, and just the desire to kind of get those off the books. You're, you're absolutely right in that regard. I think the two, uh, processes are completely different.
Speaker 3:I would say though, um, kind of Matt, to your question of is it kind of a disincentive? And I, I really don't think it is, because if you have a strong effective compliance program, I mean, the alternative is that you have a, a technical stark violation and you have prohibited referrals and absent, you know, a stark self-disclosure, you know, there is the reverse false claims Act, you now have knowledge, you have those referrals, you have an a repayment obligation for those referrals. And the C m s disclosure process does, you know, kind of toll all of that. Once you submit the disclosure, you, you don't have to refund those referrals. It kind of pauses that 60 day refund obligation. And while it's, it's can be frustrating to have to wait so long, it is generally, and from what we've seen with settlements in, in private practice as well, is that they're, they're much more reasonable than having to refund all the referrals. So I think that, you know, should still be an incentive to make sure that you're correcting the issue and, and taking the steps and, and considering that as a valid, um, and desirable, you know, option.
Speaker 2:So in other words, it may not be a disincentive, the process may be tough, but at the end of the day, it's, you know, probably better to go through the process than to, you know, kind of take your chances, which, you know, obviously we wouldn't advise our clients to do. But, um, uh, tell me about the DOJ process,
Speaker 4:Uh, that process. I, I think Matt is, is very specific to each local office of the A U S A. Um, some providers are, you know, have worked with the, the local office for years and years, and that there's very little turnover. There's, you know, healthcare expertise, and that can be a preferred option. Um, but it, it's very, I think, local office specific. And it's a little bit, um, undefined too in terms of, you know, the timing, the, the damage amount, um, standard procedure, that protocol is really much more recent. Um, it used to be, you know, without, um, specific guidance to the provider community. And so I, I think it's, it's a little bit more individualized than perhaps the other.
Speaker 2:And when would you consider a disclosure to, uh, DOJ in connection with a disclosure to OIG and or c M s?
Speaker 4:Yeah, I, I think it, you know, again, if there's a, if there's a strong relationship that, you know, was built based on past activity or, or prior case where there's kind of, it's an old quantity and you want to kind of go back there, maybe, maybe it's related to a matter that you had with that office in the past. Um, I think it, it, we've seen it where there's past, um, um, dealings with, with the office that gives the provider comfort that they will be essentially treated the same way, um, going forward. So it, again, it, it has a lot to do, I think, with who the individual players might be, uh, both on the provider side and, and then, you know, with the local office of the A U S A, the other, the other thing I think I would add there too, Matt, that some folks are, are very, um, interested in obtaining an actual F C A release, and you won't get that directly from the oig. For example, you'll get a, uh, civil monetary penalties law release if you want an actual release from the False Claims Act. You know, you're particularly concerned about a relator, for example. Um, the DOJ has to be involved with that. And so I think there are cases where folks are very, um, focused on that being the final objective. And that really then would presumably start with the, you know, the local office of the A U S A.
Speaker 2:How often do you see that that DOJ will, you know, issue a, a false Claims Act waiver?
Speaker 4:And that's
Speaker 2:Self-disclosure?
Speaker 4:Yeah, I mean, you know, it's the, it's the end result of a, for example, an investigation, a self-disclosure, you know, false Claims Act investigation. It, it could be the end result also of a self-disclosure to the, uh, DOJ directly. And then on occasion doesn't happen very office often, but, um, the OIG will alert the local office of the U S A that a self-disclosure has been submitted for a provider in that district. And we have had very few, but you know, there were some in the past where the, the DOJ actually opted to get involved in the OIG self-disclosure, and then the DO OJ drove the case, the local office of the U S A drove the case from there, and the end result ended up being a false claims release. So that can sometimes happen. I think the OIG is a courtesy, uh, alerts the local office that a self-disclosure has been filed, and then, uh, the A U S A can determine whether or not they want to get involved doesn't, again, very rare in our experience, but it, it has happened.
Speaker 2:Um, anything else you want to share about self-disclosure? I mean, any sort of, you know, key challenges that providers might face, issues or process concerns that a provider might face when, when, when issuing a self-disclosure?
Speaker 3:Um, so I can start with that. I think it, it goes back to the complete and thorough investigation. Um, definitely have had situations during my practice where the, the client was really anxious to, to, to self disclose, right? They, they know there's an issue, they have concerns, maybe there's chatter among staff or, or something about an issue that's going on. And so they really wanna address it and they really like, okay, let's disclose, let's disclose. And I think sometimes, um, you know, as counsel for, for a client, you have to kind of get them to pause. We have to think through the actual issues and make sure that we're addressing kind of every element and every piece that might be problematic, making sure we have a, a corrective action process that actually works. Um, I think that's key because you don't wanna be in a situation where you kind of rush to disclose, um, but the issue isn't really fixed. Um, or you don't really understand what led to the issue or all of the different facts about the issue. Um, I think that can be really problematic, particularly if, you know, the OIG G asks follow up questions. You don't wanna be in a position where you have to go back and say, well, we said this in the disclosure, but now that we looked at it more, you know, something is different about that. Um, I think too, in, in that same vein, is the data that you are, are looking at, it's really important to make sure you contemplate all sources. I mean, OIG disclosures can be used for, you know, stark and anti-kickback concerns, but they can, it can also be used for billing and coding issues mm-hmm.<affirmative>, um, and, and, you know, false claims that kind of overpayment concerns depending on those issues. And it's really important to make sure you've done, particularly with a billing quoting review, you've done an, an appropriate investigation, a review, you have, uh, an appropriate method for, you know, if you're extrapolating kind of a result that you have all of the data and the universe of claims that are actually impacted. Um, you know, we've had situations historically, um, when I was in private practice where the do, or excuse me, the OIG came back and said, this data doesn't, we look like we have more claims than what you have. And it turned out that the client had inadvertently failed to pull data from an archived system, and so they ended up missing claims. So I think really kind of slowing down and thinking about the process and making sure you have everything, because that all goes to credibility, right? Mm-hmm.<affirmative>. And so, um, to have the best result and to earn that trust and to build those relationships, you know, I, I've worked with Scott A. Long time and I think he has done a great job of building that rapport. And it's because with the self disclosures, they're very thorough, they're very detailed. It's, you know, there's a comfort level. Knowing that the process has that has occurred is going to be a strong, valid process. Um, and I think sometimes just trying to realize that it's, it's better to take a little bit more time and actually do a thorough investigation than kind of rush to it and miss something, um, is gonna be a better result in the long run.
Speaker 4:Yeah. I guess Matt, and, and thank you for that, Leah. I, I would add two in terms of the timing, it's kind of a, uh, delicate balance, because on the one hand, as Leia indicated, you wanna make sure your, your investigation, um, is, is in depth and, and covers the basis because really your self-disclosure is only as good as the internal investigation, the data that you use. On the other hand, you know, sometimes there's a concern that, that somebody is going to blow the whistle. Um, and we've literally had, you know, we've had providers working on self disclosures where, and they were very close to submitting when they get a C I D from the doj. So it's a delicate balance, um, to, to make sure, you know, you're, you're thorough and probing to, to uncover everything as opposed to, to, you know, sometimes or not allowing the issue to get outside the organization. Um, the other thing too, I think we already alluded to this. Once it's in, you know, you, you really don't have the option of like saying, well, maybe, maybe it wasn't an issue,<laugh> or, um, you know, maybe it's not that bad, or maybe we overstated the damages. It, you know, that that just goes to what Leia was saying, the credibility mm-hmm.<affirmative> that's not received well, you know, um, so you, you, you basically have to be all in and then, um, you know, be as responsive as you can once the, you know, the questions start coming in to to, to make sure you answer the agency
Speaker 2:Question. And I, I so appreciate that. I appreciate the, um, the concept of the fine balance too. It's, you know, a race to the finish line, but before you get to that finish line, you better make sure what it is you're delivering is, like you said, Leah and thorough and you know, well conducted. And you need to have a good understanding of the facts. We want to thank Leia Olson of Ascension and Scott, uh, table of Hall render for joining us today and for sharing their experience and their expertise. We also want to send a huge thank you to our podcast sponsor, the B r G group, and finally to you, our listeners, and we'll see you next month.
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