Winning Isn't Easy Season 3 Episode 33: How Doctors Can Destroy Their Disability Claim, Lose Their License and Go To Jail By Doing Work as A Peer Review Doctor With Attorney Jonathan Rose

Welcome to Season 3, Episode 33 of "Winning Isn't Easy"! 🎙️

In this eye-opening episode, join your host, Nancy L. Cavey, as she welcomes a special guest, Attorney Jonathan Rose. Together, they'll delve into the critical topic of "How Doctors Can Destroy Their Disability Claim, Lose Their License, and Go To Jail by Doing Work as a Peer Review Doctor."

You'll gain insights into:

🩺 The potential pitfalls doctors face when engaging in peer review work while on disability.
📜 Legal ramifications and ethical considerations that can jeopardize a medical professional's career.
🚫 The risks of losing disability benefits, medical licenses, and even facing criminal charges.

This episode serves as a vital warning to medical professionals navigating the delicate balance between disability claims and professional responsibilities. Attorney Jonathan Rose will share his legal expertise, shedding light on the potential consequences doctors may face when they cross this ethical and legal threshold.

Tune in to Season 3, Episode 33 of "Winning Isn't Easy" to discover how to safeguard your disability claim, professional reputation, and legal standing as a medical professional. 📻🩺

Please note that the content shared is for informational purposes and should not replace personalized legal advice or guidance from qualified professionals.

Transcript

ERISA Attorney Nancy L. Cavey: 0:00

Welcome to this week's episode of Winning Isn't Easy. I'm really excited about this episode, which is how doctors can destroy their disability claims, lose their license, and go to jail by doing work as a peer review doctor. Now, you may not be a doctor and you're wondering, why should I listen to this episode? But I'll tell you because this is a problem that arises in the course of disability insurance claims, particularly when there is residual disability benefits, and the professional , uh, has lost their identity. They don't know what they wanna do. They do wanna work, and they come to us and say, Hey , based on my disability insurance policy, is there something that I can do , uh, to give me a sense of, you know, self-worth, but without jeopardizing my , uh, disability benefits? And this is where our , uh, speaker this week , uh, uh, is going to address the practical , uh, realities of doing , uh, work , uh, and potentially finding yourself the subject of a criminal investigation. So, I wanna welcome attorney Jonathan Rose . Jonathan served in the United States Marine Corps , uh, before , uh, becoming an attorney, and he's a , a law school graduate from the University of Miami. He specializes in , um, representing Florida healthcare practitioners in administrative and disciplinary actions with the Department of Health, their boards, their certifying boards, and other agency. And that means that he's involved in white collar crime , uh, cases including healthcare fraud. And that's where we , uh, end up <laugh> having Jonathan , uh, speak with us, because unfortunately , um, I've had an occasion to deal with this , uh, issue. Uh, and I think it's something that's really important for our audience to, to understand and not , and to understand the consequences of making , uh, a , uh, bad decision. So, Jonathan , welcome to the show.

Criminal Law Attorney Jonathan Rose: 2:11

Thank you very much for having me. Glad to be here .

ERISA Attorney Nancy L. Cavey: 2:13

Great. So , uh, can you tell us generally what are the criminal law dangers that a physician or any professional might face when they are doing either peer review work or other types of work while attempting to collect residual disability , uh, insurance benefits,

Criminal Law Attorney Jonathan Rose: 2:32

The, the criminal potential liability , um, for doing any sort of peer review work is, is interesting. It's not, it's not very common, but it's, it's certainly a possibility. The problem with peer review work , um, and the peer review statutes is, is that it re it requires any facility, licensed facility in the state of Florida to have very defined set of parameters to do that in their , they're statutorily defined, they're , they're not negotiable. The problem is, is that most of, most facilities in my experience, don't actually have those specific parameters in place. They're , they're , they do these things more or less on an ad hoc basis. And peer review tends to be problematic in the sense that a lot of the time peer review is, isn't really done on a good faith basis. It's done because there's a grudge against one doctor or another. And if one is engaging in peer review , um, to perhaps , uh, get rid of a whistleblower or get a whistleblower to, to stop blowing that whistle, so to speak. Or if there is, it's, it is a bad faith attempt to remove someone or reduce someone's patient load or something like that. Those, or, or even have an action to get someone's license. Those are property interests and therefore that, you know, those, that action could conceivably be fraud.

ERISA Attorney Nancy L. Cavey: 3:57

So what I typically see is my physician calls me up, or my professional calls me up and says, look, I wanna do something , uh, and I can see that I can potentially do some peer review work. And they , and they go out and they kinda look for companies that offer them the opportunity to do peer review work. Like, let's look at a person's medical records and certify them for a certain type of medical equipment or devices , uh, without ever having seen the patient. Um, it , it kind of looks good, if you will , um, but there are all sorts of traps that anyone can fall into. So can you kind of tell us specific , specifically in the peer review process, what are the traps that physicians or other professionals need to be looking for if they're thinking about doing something like peer review,

Criminal Law Attorney Jonathan Rose: 4:46

If one is going to be doing this? Um, so for a , as on a sort of a telehealth basis electronically , uh, that, that is, that is very problematic. That is, it's actually a , a , a doing any, any sort of document review via telehealth is, or any sort of electronic means becomes very problematic. Um, I've had a number of clients who have been disciplined by , uh, the Florida Board of Medicine. Um, a number of clients have actually had federal criminal action taken against them because they have engaged, engaged in sort of some, some action of that nature. And if there , there are certain circumstances where the , the way that these companies who have shiny websites and seem like they're very legitimate , um, the way that , that they're presenting the records, even , even if the , the , the physician is acting in good faith, if they're not paying attention to the way to the records are presented to them, they're , they could be if they say, well, this person needs , uh, some, some item of DME, or this person needs some sort of, of testing or whatever the case may be, they could be putting themselves in a position where every single record that they signed could be a false statement. And if, if that's the case, then you know, they , it could be, and if they're , if they're being paid obviously for their work, those could also be construed as kickbacks.

ERISA Attorney Nancy L. Cavey: 6:16

So

Criminal Law Attorney Jonathan Rose: 6:16

There , there are any number of different ways where this can be very, very problematic for practitioners.

ERISA Attorney Nancy L. Cavey: 6:21

So one of the ways you've said is looking at electronic records , uh, what is it about the electronic records that leads to problems? And what are the other potential problems other than looking at electronic records and signing off on e equipment or certain services?

Criminal Law Attorney Jonathan Rose: 6:39

Well, if, if one is, what's problematic is, is that the , the records are frequently not legitimate records. And if, if, if one doesn't know exactly what a person has, there is no, there's no, in , in many cases, there is no actual evaluation. The , the physician isn't , isn't doing it except anything, except reviewing records and, and accepting the premise that those records are legitimate. And if, if you're doing a prescription based on that, and then you don't really know what you're doing, then you've created now any, any number of problems for yourself.

ERISA Attorney Nancy L. Cavey: 7:17

So other than the electronic record aspect of it, what , what else are some of the problems that a physician could face , uh, by doing peer review work?

Criminal Law Attorney Jonathan Rose: 7:27

By doing peer review work ? If, if you put yourself in a position where you , you are , you are in a group that is whether , whether you think it is or not, if, if that group has been formed with an intent and in some sense , um, to, on , in , on a bad faith basis, where to again, you know, affect someone's property, right, to patients, to money, to salary , uh, they're , they're , you know, causing them license issues, those are property interest, and those, those can be prosecuted as fraud , uh, I both on a state and a federal basis. Um,

ERISA Attorney Nancy L. Cavey: 8:09

So the typical presentation, I guess is there's a shiny website out there for, you know, do you wanna be a peer review physician? And it looks very attractive. Um, what is it that would signal to you , uh, as a criminal lawyer that this is not something you want to get involved with?

Criminal Law Attorney Jonathan Rose: 8:32

I think that physicians, and this, this is sort of odd to say, because we think of physicians as , as being people who think very critically and, and within the, within the constructs of what they do is physicians. It certainly, they , they normally do. But what I find is that they don't think critically once they leave the office in many circumstances. So when physicians are thinking that they want to do some, some sort of peer review work, and they go, they go to some sort of website, they need , they need to be very, very cognizant about whether, whether that website or that that company is, is actually functioning within the , the parameters of the federal statutes and the state statutes. Um, if, if they're , if, if there, if, if there are, if it's a circumstance where there's providing the , the records, they're , they're , they're not doing anything else, then my advice under almost all circumstances would be that they do not accept that employment. Um, anything that involves , um, and practicing exclusively and through electronic means, ha is, is fraught with problems. And again, that can lead to , uh, that, that can lead to criminal problems , uh, that can lead to civil liability under the Florida statute , that one could very easily be sued for that. So there is very , any, any number of problems. And I think, you know, it really depends on the way that the records are structured and, you know, peer review if there peer, external peer review can be a real thing. But if you're , if one is just signing up through a website to do peer review , that does the potential to be very, very problematic.

ERISA Attorney Nancy L. Cavey: 10:14

So obviously the problem as I understand it, is that this particular peer review service is for a patient to be approved for either medication or a procedure or a piece of equipment. Right . Would that be correct? Okay.

Criminal Law Attorney Jonathan Rose: 10:32

DME . Sure.

ERISA Attorney Nancy L. Cavey: 10:32

Right. So then I have other situations, of course, where physicians can potentially go to work for a disability insurance company or a worker's comp insurance company looking at medical records and rendering opinions about causation or need for treatment. Uh, is that situation any different than the first situation?

Criminal Law Attorney Jonathan Rose: 10:56

It's, it's di it's different in the sense that it's a, it's a different mode of liability, but it's, it's very , it's very similar in the sense that if, if one goes to to work for a company that's doing that kind of work, and you're putting your yourself in a position where you are not abiding strictly by the laws that apply to these things. So if, for instance, if , again, if a doctor is just like reviewing records and making, or making a recommendation or a prescription essentially for testing or a prescription or a piece of DME durable medical equipment, then you're putting yourself in a position to commit false , you know, federal and state offenses. Could be false statements, could be kickbacks, could be any number of things. Again , in , in , you know , the long run could be money laundering. And all of these things have really, really potential dire consequences for people's licenses. The Florida Board of Medicine, Florida Department of Health deal with these things very, very seriously. And the federal government through HHS and a number of other agencies are very, very active at this point. There are their healthcare , uh, crime task forces

ERISA Attorney Nancy L. Cavey: 12:07

Hmm . That,

Criminal Law Attorney Jonathan Rose: 12:08

That are dealing with these things, and they're very aggressive in their prosecution. So it's, it's, it's very important that, that physicians understand these things and the amount of trouble, so to speak, that, that a physician get get in is much more serious than one might think. Because for , let's say for instance, if, if , um, these folks are typically paid somewhere between 25 and $50 per patient for per record that they review, hopefully they're not being paid on a contingent basis if , if they , they're being paid only if they do a prescription, that is obviously prob problematic in and of itself. But let's assume there, there is no such contingency. If the Dr. May think, well, you know, how , how big a deal could it be? I've only been paid $40,000 over a year or $30,000 over a year, which is about what I would expect someone to make doing this. So it's, you know , it's spending money for, for , for a physician, normally that's not the amount of money you're held responsible for. You're , you're held responsible for the amount of money that is, that is the loss to the federal government. So if a company is charging $800 for a piece of DME or $1,500 from some sort of testing, that's, that's what Medicare or Medicaid or Tricare, whatever the case may be, is paying for that. And if you do several thousand patients, well that adds up very quickly. And that can be very serious, you know, millions of dollars of loss that some physician is responsible for really not understanding what they were doing.

ERISA Attorney Nancy L. Cavey: 13:39

This is great, but we're gonna take a , a quick break because when I come back, I wanna ask you about what are the typical state and federal charges, what is the typical sentence and fines, and then we'll talk about licensure. So we'll back in a second. Welcome back. I've got some questions about what happens to a physician who , uh, is potentially charged , um, with violations of state and federal law. So, Jonathan, can you tell us what are the typical charges? What are the typical sentences? How does this kind of play out in real life ?

Criminal Law Attorney Jonathan Rose: 14:22

Well, it's, it's gonna be a very different scenario in state and federal court. In federal court. And honestly, these things are , are typically dealt with in federal court because US attorney's offices are , are built to deal with these kinds of crimes. Whereas your typical, say , attorney's office, they're really, they're really not built to deal with large scale investigations like this . Um , so if , if someone is charged in federal court with something to do with this, you know , they could be charged with Medicare fraud to the , any , any , any number of different types of fraud, wire fraud. They could be charged with false statements. They could be charged with violations of the , of the , uh, anti-kickback law.

ERISA Attorney Nancy L. Cavey: 15:01

So does this typically start out with an investigation, for example, of the DME company who's , you know, offering the services or the equipment equip and then sort of filters down to the physician? How does this all get started?

Criminal Law Attorney Jonathan Rose: 15:16

Actually, it , it typically starts with a physician,

ERISA Attorney Nancy L. Cavey: 15:18

Ah ,

Criminal Law Attorney Jonathan Rose: 15:19

As opposed to the DME company. Because what happens is, typically speaking is a, a , a person will receive some, some piece of , of DME that, that they, they didn't ask for, they didn't want, they don't need. And their , and their, their insurance or Medicare or whatnot will be billed for that. And then they will report that to law enforcement or the Department of Health. And then an investigation is started in specifically into that physician rather than the company. Because people don't think about this through the framework of, you know , this is like, there's, there's, there's some, some large corporate entity that is structured itself in order to do this, they think about bad doctors.

ERISA Attorney Nancy L. Cavey: 16:05

Ah , okay.

Criminal Law Attorney Jonathan Rose: 16:06

So , so there is, you know, typically speaking of what start , what it starts with is actually invest in , in an administrative investigation by the Department of Health and that , and that board. So typically , you know , the board of Board of medicine, board of osteopathic Medicine, whatever the case may be, and they will, they will do their own , their own investigation. Um, you know, depending on the case then the , the , the sanctions may not and may not be horrible in that scenario. But what may happen after that would be , would be a , a part of a larger federal investigation. And if, if that becomes part of a larger federal investigation, then a physician can get caught up. I mean , you know, in in, in a conspiracy case in a RICO case, there, there could be, or , or just, you know, have, you know, straightforward charges of, again, you know, various forms of fraud, wire fraud, mail fraud , uh, you know, kickback violations, false statements, you know, potentially money laundering depending on, on the scope of the situation.

ERISA Attorney Nancy L. Cavey: 17:09

So you , you talked a little bit about the typical charge. Um, so this start with like a knock on the doctor's door at their house saying, you know, what are you doing , uh, what's this initial contact and how do we get from that to a criminal charge

Criminal Law Attorney Jonathan Rose: 17:25

Once a criminal investigation is , has been , uh, started? If , if it's a federal investigation, then yes, the first thing that's gonna happen is probably going to be a knock on the door. And that will , that will be a federal agent who will be delivering a letter to an individual that's called a target letter. It is, it is a letter that says in pretty plain terms from the, some local Department of Justice office, the United States Attorney's Office, that they are the target of an investigation. And the federal agents are typically, well-trained in, in , you know , the, the laws of when, when someone is in custody and when's in custody and one is not, and be , and, and it actually conduct a fairly thorough investigation where the , the physician is making all sorts of inculpatory statements, not, not having, having no idea that these are going to be used in court against them because they haven't been arrested or not this is happening at their house. They're, they're , they're sitting, you know, at their coffee table with some federal agent just chatting and chatting and chatting. Mm-Hmm . <affirmative> . And , and then before you know it, they've made, you know, just monumental, you know, confessions and admissions to these kinds of things. So it, it , you know , it starts with a knock at the door and a letter, you know, and, and frankly, you know, a lot of the time physicians , um, or you know, are again, very, very bright people and they think, I haven't done anything wrong, and they will ignore it. Um, and just think this is going to go away. And I've, I've explained all this, rather than contacting a lawyer with these, with these letters will typically actually suggest to them , and you know, the letter will actually say, like , like , this, this is your chance to talk to us. If you don't do so, we're going to charge you with X, Y, or Z. And many times physicians ignore these things. They , they don't get the letter and think, okay, I've got a real problem. Let me find a lawyer who's competent to deal with this kind of thing and figure this out. They think I haven't done anything wrong. And they just, they, they ignore it. Which is the worst, worst possible thing that, that anyone, especially a physician in these circumstances can do if you're contacted by a federal agent, if you're contacted by, you know, an investigator from the Florida Department of Health, it's really, really, really important to immediately seek representation by someone who is competent to deal with these kinds of things. Because if, if you just, if you ignore the Department of Health, if you ignore the federal government, what's going to happen eventually at that point is there's going to be charges brought against you where, you know, you might have the ability to prevent that if you're dealing with it on the front end. And , and, you know, federal prosecutors make decisions about who they do and who they don't prosecute. Sometimes they prosecute people regardless. Sometimes you , you can, you can negotiate lesser charges, so someone's not getting the complete book thrown at them. Sometimes they'll use a , a physician or someone else as a witness in a case, even if there , there has been some sort of violation. And so there, there is no prosecution against them, but of course, the characters , you know , were the, you know, the head of the snake, so to speak, to go to trial, they would be testifying to that person. That is, that is a very common occurrence. But in order to get to that point, you have to be dealing with it affirmatively. If you're not dealing with it affirmatively, you , you're, you're just opening up Pandora's box .

ERISA Attorney Nancy L. Cavey: 20:53

So what's the typical potential , uh, criminal liability and, and , uh, monetary consequences

Criminal Law Attorney Jonathan Rose: 21:03

There, there really isn't a , a typical , uh, monetary or , or , or, or criminal liability because it really depends on the facts . So if, if , if somebody is in, in this situation in state court or , or federal court, then, you know, it really depends on the amount of loss is that , you know , these, these kinds of cases. And then to what the sense is gonna be is driven by a number of things. But of course, the primary thing is, is the amount of loss that the federal government would've incurred based upon, you know, the , the , the amount of DME or testing or, or drugs or whatever that was prescribed by the physician that , that the federal government paid for in some sense. So if, if the, if the, if the nut , if the amount was $50,000, let's say a physician could still be prosecuted, could still lose his license or her license , uh, but be in a position where they, they might not get much more than a probationary sentence, that's still a huge problem since in that scenario, you know , even , even if the board of medicine board of take mercy on a person, you'd still, you're still in a position where just by , by virtue of that conviction, you, you are not able to renew your license for years and years, 10, 15 years in most cases. So that it's, it's , it's effectively the end of one's career, and you won't be able to go to another state and get a licensure. There either won't happen. So if the , the larger the number gets, so for instance, if I have a client who has, is responsible for about 2.7 million and, and loss to Medicare, tricare, et cetera , and in his case, he might not go to jail at all, but he scores about three years of prison. And, and that's, that's after all the , the , the machinations are , are done with , with this the federal sentencing guidelines. And, you know, and, and again, it's important for people to understand that you are not held responsible for the amount of salary necessarily that that's an issue. But what drives the sentencing parameters is the amount of loss to the government and the physician will, you know, almost never be a part of that equation. They don't have any idea what these companies are, are getting paid by, by the federal government for this, you know, tremendous amount of fraud they're doing .

ERISA Attorney Nancy L. Cavey: 23:25

Alright , let's take a quick break and I wanna come back and talk about the impact on the medical license. You made some allusions to that, but I wanna expand on that. Uh , and then we're gonna talk about what it costs once you've dealt with the criminal liability and the fines to, to defend one of these. So let's take a quick break. Welcome back. Let's talk about what impact , uh, a state or federal charge , uh, will have on a person's ability to practice medicine. So can you , uh, talk about , um, that and how you go about defending people and what the cost there is and the impact on the license?

Criminal Law Attorney Jonathan Rose: 24:16

The, the impact on someone's license? Um, if, well I'll , I'll frame this two different ways. If there's a federal conviction for Medicare fraud and like there's , there's a range of statutes that are included in the Florida statute. If there is a conviction for, for one of those statutes , um, then there would probably be a revocation. And , and in all, in all likelihood that the Board of medicine will probably revoke someone's license, not in all circumstances. There are certain mitigating factors, like depending on one's personal situation that that might preclude that, but the discipline would, would include certainly probably lengthy suspension. It would, you know, make one's employability certainly less than, you know, ultimate. And in terms, in terms of, well , criminal liability, you know, it's the, the amount of liability that someone has in that scenario is, is, is hard to fathom in a certain sense. Now, if, if one is being disciplined by the Florida Board of Medicine and prosecuted by the Department of Health , um, that will go to the NPDB National Practitioner Data Bank, that will go , um, and this certainly will be on their record, they'll probably excluded , uh, from HHS programs, they'll be on the excluded list there. So there , are there any number of problems that this will, will , will bring up in terms of the amount of cost , um, that , that this can incur, you know , if an , an attorney who is competent to deal with these things, if it's, if it's a federal criminal case, it could be anywhere between, you know , depending on, depending on the facts and what happens with the case. It could be anywhere between, you know , $50,000 and $250,000. It , it really depends on, on what the situation is and what, you know , how, how bad the government , uh, wants to put its foot on someone's neck. Um, in terms of what it costs to defend a, a license action, it's really not that dissimilar. 'cause the amount, the amount of work that goes into it is, is, is different. Um, but it's, you're, you're , you're easily going to spend like probably a hundred thousand dollars defending one of these things with the Department of Health, especially if it goes all the way through the process. Because the, the process of defending a claim like this in an administrative action in Florida is, is is a very, very complicated, bizarre process that is extremely time intensive. And it's , it's not, it's, it's not a jury trial. The one has, it's, it's what's called a , a final hearing and , and they're typically done remotely with administrative law judge. But there's, there's, if , even if the judge makes a determination that there is no liability on the part on, on the part of that person, one still has to go before the board of medicine or, or if, if a judge makes a determination that there is a factual or , or a statutory violation, the judge makes a recommendation to the board in terms of what that could be. But the board sometimes will try to actually overturn that and, and , and , and promote more discipline. And, and there's, there it , so it's, it's , it's , it's a seemingly never ending process. So if, if you're really, really defending one of these things that they can be absolutely draining on people financially.

ERISA Attorney Nancy L. Cavey: 27:55

And I presume that this procedure is for the most part, pretty similar across the United States. You've talked about what happens here in Florida, but I would presume that that's generally the process , uh, across the United States.

Criminal Law Attorney Jonathan Rose: 28:09

Administratively, they're very different from state to state, but you're , you're going, you're going to be spending a tremendous amount of money if, if you're defending one of these things, you know , like really all, all the way through, through the board actually making a determination about what discipline will be , um, like very, very different from state to state. But the , the , the , the administrative system is system , my experience considerably less straightforward than the criminal system, even in federal court, which is much more complex than that state court.

ERISA Attorney Nancy L. Cavey: 28:45

So , um, out of curiosity, I'm wondering if a physician loses their license, could they become a physician's assistant or are they just done and done? They're

Criminal Law Attorney Jonathan Rose: 28:54

Pretty much done with healthcare actually. Um, when, when I , every now and then I'll, I'll have folks who are in this position and sometimes people will think, well, you know, I I will just, I I will relinquish my license and I , and I'll just go get licensure somewhere else. And, and my answer to that is, is no, no, that is, that is, that is literally the nuclear option. If, if, if one were to do that, you're essentially making the determination that you're not going to practice as a physician here in Florida or any other state. Uh , and you're not going to attempt obtain licensure as a PA or get , get an ACM license or the air critical need or something of that license or like , you know , some sort of like quasi medical license in some other state. Because if, even if you, if if you were revoked, that's not gonna happen. If you relinquish your license under circumstances where there either is, or you should know that there is an investigation, the boards consider that to be the equivalent of a disciplinary revocation.

ERISA Attorney Nancy L. Cavey: 29:58

Oh , okay.

Criminal Law Attorney Jonathan Rose: 29:59

So you are , you know, in all likelihood, if, if there is a disciplinary revocation or if there is a relinquishment under those circumstances, that that will, it goes to NPDB, that's not a secret. Everyone's gonna know about it, and the chances of getting any kind of healthcare licensure anywhere in the United States is exceedingly slapped .

ERISA Attorney Nancy L. Cavey: 30:24

So in closing, are there any tips that you could give , uh, physicians or , uh, executives who might wanna try to do peer review work in an effort to, you know, to maintain that sense of self-worth as being someone who's contributing to society or even to combat depression that we see associated with disability?

Criminal Law Attorney Jonathan Rose: 30:48

My , my advice , uh, to, to anyone who is considering doing peer review , um, especially through , um, an online platform, is, is, is you need to be very careful. Um, you need to be very , uh, again, think critically. My advice would be to discuss that decision with a qualified attorney before you make it talk, talk with your, talk with a criminal attorney, talk with a professional licensing attorney, talk with your DI attorney, but do not just go and, and do this because you think that you're gonna make some, you're gonna make some quick money and it'll, it'll be something that you may , may be able to keep you engaged, make , you know, lift your spirits, et cetera. You probably need to find something else to achieve that, because the way these companies are set up very, very much lends itself to huge, both administrative, criminal, and potentially civil problems.

ERISA Attorney Nancy L. Cavey: 31:53

Wow. Well, thank you for this , uh, insightful interview today. Um, if anyone has any further questions or needs the assistance of a great , uh, criminal attorney, we've got Jonathan's contact , uh, below. Jonathan, thank you so much for , uh, your time today and your expertise, and hopefully our clients have learned a lesson and that is basically don't do peer review, but if you do wanna do it, consult with an expert like Jonathan , uh, to really get the, the skinny, the right information so that you're ultimately making a decision that's not only right for you, but for , uh, your family and your continued disability benefits. So thanks.

Criminal Law Attorney Jonathan Rose: 32:31

Thank you, Nancy.

ERISA Attorney Nancy L. Cavey: 32:33

All right . Take care.

Criminal Law Attorney Jonathan Rose: 32:34

Bye-Bye.

ERISA Attorney Nancy L. Cavey: 32:36

All right , great. Thank you.