This transcript has been auto-generated and may contain technological errors.
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Hello and welcome to Hospice Insights
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The Law and Beyond where we connect you to
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what matters in the everchanging world
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of hospice and paliative care.
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OMG the OIG is at it Again Bryan great
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title for this podcast I love it yeah
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I'm I you know I I have a a a uh maybe
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another career in marketing or or
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promotional stuff I enjoy these so yes
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yes well it's a good one it's catchy and
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this is really just unfortunate news and
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what we're talking about here aren't
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like the work plan audits that are
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oneoff claim you know polls that that
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hospices get these are the provider
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specific audits we've talked about on
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this podcast before Bryan and I think
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those have you know been extrapolated
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there many millions of dollars they're
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public it's just a lot of concern here
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and the reason why we're doing another
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podcast is we thought that they were
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stopping at 13 but now we have clients
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more recently that have gotten the same
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kind of audit so there's more than 13
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hospices that are going to get this so
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we wanted to get the word out to people
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because these are really serious yeah I
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mean over if you look back at the OIG's
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report over the years you know every so
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often they would uh audit a hospice and
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you can tell that because they make
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their reports public they'll they'll
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publish them on their website and then
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about four or five years ago uh it was a
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whole group of hospices which turned out
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to be 13 and uh they all started around
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the same time and I I think uh there are
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some that are still going through the
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appeal process and I think we thought or
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Our Hope was that okay they're doing
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this group of 13 maybe then they'll go
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back to just the occasional oneof every
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other year or so uh but in the last
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couple of months we've learned that now
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there are three hospices who are getting
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this kind of treatment all in quick
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succession so you know how many more are
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going to be in is this a new group of 13
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or is it a bigger group a smaller group
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that remains to be seen but it looks
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like they're going after hospices again
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in a coordinated way yeah and the reason
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why it's so high stakes is extrapolation
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and we've talked on the podcast a lot
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about
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extrapolation um
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oftentimes it was in upic audits which
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upix can still extrapolate but we're not
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seeing as much of that but these OIG
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audits they're always extrapolating
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their findings and because the universe
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is everything you build for two years if
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your error rate is 50% which when you
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look look at the reports of the 13
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hospices from before the error rates
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were around that probably on average
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yeah yeah on average I think the low
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might have been uh below 20% the high
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was over 80% a lot of them fell within
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that 30 to 40 to you know 60% range just
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look at your revenue for two years if if
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your revenue for two years was 50
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million uh and you got a 50% error rate
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you're going to get a report that says
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you owe half of that 25 million so you
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it's easy to do that math but that's why
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these are so consequential these are Big
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deals in terms of dollar amount but also
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again these are published for the world
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to see and also for decision makers and
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policy makers to react to as well yeah
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well it just I can't say enough how
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incredibly punitive this is
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and you know I I don't know how they're
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pulling their sampling but you know this
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isn't you know a list of the top 10
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criminals in hospice that they're you
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know auditing when you look at that that
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list I mean these are very reputable
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long-standing hospices that that you're
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seeing and it's just very very very
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troubling and I won't go too far onto my
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Soap Box about you know we have
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statutory waiver of liability because
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all of these audits are really focused
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on eligibility of patients for either
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level of care or you know overall
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prognosis and it just it's just very
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very troubling and I think in terms of
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what to do I mean this is sort of an all
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Hands-On deck
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situation where there's a lot of
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formality in dealing with the OIG and
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they follow a process and you know
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oftentimes we've been able to get
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rolling Productions because it's a lot
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of Records because it's going to be 100
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100 patients is what their sample is so
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pulling 100 records and they're doing it
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just for a particular month but
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nonetheless that's a ton of Records to
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produce and then they also typically ask
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for other additional records policies
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and procedures and some other things
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right Brian yeah that's right it's you
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know the the claims are really a a
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burdensome I mean it's a voluminous
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number of claims to gather the documents
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relating to 100 patients and 100 claims
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so the first uh T you know the last
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round of these when there were 13 we
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were representing about half of the
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hospices who were involved with those
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developed a good relationship with the
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OIG where we could uh have them
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accommodate us giving us reasonable
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amounts of time to produce records but
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yeah beyond that they want uh policies
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and employee lists and incorporation
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documents you know they they want to get
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a good sense of the background of the
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hospice last time around none of those
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non-patient records really played a
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large role in the ultimate report that
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was issued but it is clear they're
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looking at those uh and you'll see if
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you look at those older reports when
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they identify an overpayment they're
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usually attributing the cause of the
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overpayment to policies that were
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ineffective uh so they don't go into
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much detail about what was wrong with
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the policies and we asked so we we tried
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to get that information from them but
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really the focus is on those patients
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they'll review them for eligibility
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six-month prognosis uh and kind of
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arrive at their conclusion there was uh
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uh one of those OIG efforts was focused
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on level of care continuous home care
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and
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Gip uh so far we haven't seen that kind
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of an audit in this new round appears to
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be focused more on just uh do they have
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a terminal prognosis or not do the
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medical records support that yeah I I
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can't say how catastrophic these audits
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are when you look at the dollar numbers
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because if you're a large provider I
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mean those dollar numbers can you know
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end up being 50 million 60 million
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dollars I mean there's not many people
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that can withstand that type of
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repayment and stay in business so yeah
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um obviously you have appeal rights and
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we've helped people through that and
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lowering the error rate and I think
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importantly the whole statistical side
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of these cases is important and getting
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a statistician involved you know very
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early on I mean we've won statistical
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cases um but oftentimes if you win on
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the statistics the government's going to
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challenge that and and appeal that and
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try to get that overturned so yeah it's
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a different uh you know there's been a
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number of develop M since the last round
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of these so and and I don't know if this
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is a silver lining but it is a reason to
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continue to have hope is that we were
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fairly successful and are being
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successful in the appeals of these
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bringing that error rate down reducing
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the kind of sticker shock of the sticker
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shock effect on that report and the
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large overpayment but it really takes
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that coordinated efforts you know having
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kind of councel statisticians expert
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Physicians one of the differences now is
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that there are a number of uh court
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cases that are making their way through
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federal courts challenging the
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statistical approach for these Audits
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and other kinds of CMS audits there are
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court cases challenging the way that U
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these reviewers are reviewing medical
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records we know that because because
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we're behind a number of those lawsuits
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we've kind of developed strategies and
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and have filed those a number of
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lawsuits across the country to try to
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push back which as far as we can tell is
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the first time people are pushing back
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at the federal court level against
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hospice audits that involve these kinds
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of
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extrapolations and where the medical
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review really second guesses in a way
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that we think is unfair the uh decisions
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and clinical Judgment of the certifying
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Physicians so I think that hopefully
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those court that Court activity will
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also temper the kind of consequences
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that these OIG reports otherwise are
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going to have yeah well it is going to
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be interesting to see if we can get some
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positive results from some of that
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Federal litigation which is happening
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all across the country so in many
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jurisdictions uh and so we'll see but I
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mean this money comes due I mean you can
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hold to recruitment during the first two
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levels of appeal but after that you have
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a need to have a payment plan or pay it
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so yeah I mean that's one of the one of
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the problems that hospices have faced uh
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and it's kind of facing it on steroids
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with these OIG audits is before you're
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done with the appeal process the
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government gets its money and so uh can
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a can a hospice survive in order to
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appeal survive to appeal the results or
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not and the system is set up to make it
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to allow the government to take those
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funds before you're done with the appeal
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process so yeah I mean there's a lot of
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nuances and and and things that need to
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be addressed the extended repayment
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schedule and how does that coordinate
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with other kinds of advocacy through the
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appeal process and uh any kind of
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negotiations you can open up and there's
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also the public relations aspect the
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last time around uh we worked with our
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clients to be ready for media coverage
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of this and thankfully it wasn't too
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terribly significant I think Meg you and
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I had thought you know after they're
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done with these 13 reports they're going
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to bundle them all together and issue a
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huge press release and really impune the
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hospice Community thankfully that did
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not happen uh but but you never know
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times are different and I don't know if
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there's a change of foot but you know I
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think it's important to look at all
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aspects all implications resulting from
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these Audits and make sure you're ready
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for them well and we have all hands on
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deck I mean we're talking about our
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clients having that I mean we are too in
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terms of we're working on so many of
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these unfortunately and you know have
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yeah a lot of people devoting lots of
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their time to fighting the good fight
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here it's just sad I I I maybe we just
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need to stop talking about it Brian
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because I just there is no this is just
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I don't know what's going on from a
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policy perspective because this is this
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is not I think the way forward in terms
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of you know having a positive impact on
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patients lives and you know the cost
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savings that hospice brings to I mean at
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some point there's just going to be a
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chilling effect with all of these audits
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of there's just too much liability yeah
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um and create access to care issues and
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a bunch of other stuff right I mean you
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CMS does good things you know when
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they're looking at targeting the true
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fraudsters out there f focusing on the
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the mill of Provider numbers that are
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kind of acquired to resell that you know
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good let's get the good let's get the
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bad guys with that but but this kind of
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effort uh and really a lot of the audits
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in general they're casting such a wide
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net that they're they're getting the
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good guys snared in these kinds of
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audits unfortunately because I think it
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does create access to care issues and
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just a huge disincentive for hospices to
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take any
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chances on those patients especially
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those who might live longer than six
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months unexpectedly I it's a way to
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avoid or mitigate risk is just to start
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discharging them and that's not what
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hospice is about and it's a it would be
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a shame if the regulatory enforcement
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environment put the hospices in the
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position of having to make that terrible
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Choice which is so inconsistent with
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what Congress did when it set up the
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benefit yeah it is it is I don't know
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how we got here but it it just is it's
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not uh the right track and I know as an
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industry all of the national
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associations have had meetings with um
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the center for program Integrity which
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that's not OIG um but and I know there's
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been communications with OIG as well but
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those are Communications I mean I don't
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know CMS very quickly
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obviously um with all the changes to
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deal with as you said the number Mill
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and some of the craziness going on in
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those four states but so that was that
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was pretty miraculous but here I I don't
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know those larger
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conversations you know I think it's good
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that we're having them I don't know if
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we're going to see an immediate you know
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change in the audit activity and these
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audits in particular but I wish I had
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like a okay
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Brian there's a happy note here yeah we
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need that local news personal interest
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story at the end of these podcast just
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on the lighter side but yeah well I have
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my new dog Wall-E that I could bring on
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all right yeah so he could we all need
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some puppy time I think yeah exactly so
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but unfortunately no one can see w-e
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right now but so well this is really
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important and I think it's important for
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us to get the word out because we have
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had clients who got these and I think
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didn't realize how serious they were and
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what were the potential ramifications
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because I think when you get this you
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don't necessarily know they're going to
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extrapolate and do all that stuff and so
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um yeah it might it might come it might
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begin with an email from someone at the
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OIG saying hey I want to send you a
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letter who should I send it to and and
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then you get this engagement letter that
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says hey we're going to audit you and
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then later you find out it's 100
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patients 100 claims uh and a
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statistically valid random Le and yeah I
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mean if you if you get any kind of uh
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communication from the OIG it's serious
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stuff and and you need to take it very
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seriously and make sure you're ready now
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obviously work plan things are a bit
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different right that's why really
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focused on you but right if you're
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getting one of these it's going to
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follow the track you you said Bryan
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you're gonna get the email and then it's
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it's a work plan audit I mean maybe they
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give you a heads up with the phone call
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but it's a it's for like one patient I
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mean it's very clear that that is not
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this so but anyway well as always Bryan
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thanks for the the
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conversation well but at least we're
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here we've been fighting the good fight
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now for 25 years so we'll keep fighting
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it as long as as long as there's a need
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so that's we're we're happy to to be
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advocates for the hospice community well
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I'm on going to be starting my 25th year
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practice and you're much older than I am
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so maybe 28th year for me 29th perhaps
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so putting all of our brain power and
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experience
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to over 50 years of hospice well of
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lawyer experience so exactly just
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between the two of us so I know yeah
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anyway
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00:16:54,120 --> 00:17:01,319
old that is true um but just wiser just
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wiser course awesome well thanks Brian
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and until next time very good thank you
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Meg well that's it for today's episode
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of Hospice Insights: The Law and Beyond
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thank you for joining the conversation
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to subscribe to our podcast visit our
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00:17:16,319 --> 00:17:22,160
website at www.huschblackwell.com or sign up wherever
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00:17:19,679 --> 00:17:25,160
you get your podcasts until next time
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may the wind be at your
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back