The Employers Secret to Workers Comp Defense: Attorney Ted Ronca Tribute

We recently learned some sad news that one of our long-time contributors to Workers’ Comp Roundup, Attorney Ted Ronca, has passed away due to health complications.  Ted was a wealth of knowledge in representing employers in workers’ compensation and a frequently used legal resource for questions and clarification by our primary blog writers, Michael Stack and Rebecca Shafer.

 

We pay a tribute to him with a compilation of some of this extensive writings. Because his library of articles is so large, and the information so valuable, we have broken it into 3 parts. Employers are recommended to use this information as a reference for workers’ compensation defense best practices.

 

Part 3 of 3:

 

Little Used Federal Laws Give Employer Disability Management Control

Employers interact with employee disability through a number of laws. Until now, there has been little attention focused on how to coordinate statutory compliance to achieve better overall results. Workers compensation, in particular, has operated with little or no coordination with other laws.

 

Three Critical Times Employers Should Seek Workers Compensation Advice

Work comp is a real time problem in progress. If you’re an employer, chances are you could use some, or much, advice. But advice often comes with an expiration date and, if not taken, will spoil faster than an open container of milk on July 4th weekend.

 

Employers Can Spot A Claim Months Before It Occurs

A witnessed, sudden, accident presents far fewer problems than a claim without a witness. Yet, many un-witnessed claims are quite real, stemming from long term degenerative conditions. Many of these claims are filed and flagged as highly suspicious.

 

3 Types of Medical Exams Employers Have Not Heard Of

Employers who are willing to make better use of claim tools already in existence around them can achieve precisely what they have been hoping, in vain, that their carriers will do for them. The tools are: Occupational Health and Safety Administration(OSHA) physical exam, Department of Transportation (DOT) medical exam, Americans with Disabilities Act (ADA) medical exams

 

The Employers Secret to Workers Comp Defense Lies in these Three Quotes

Three quotations are all an employer needs to understand handling difficult comp claims. Two are actual quotes, but the third – and best – was made up and appeared in a 1917 newspaper story.

 

Author: Attorney Theodore Ronca was a lawyer from Aquebogue, NY. He was a frequent writer and speaker, and represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years.

Defense In Depth On Work Comp Claims: Attorney Ted Ronca Tribute

We recently learned some sad news that one of our long-time contributors to Workers’ Comp Roundup, Attorney Ted Ronca, has passed away due to health complications.  Ted was a wealth of knowledge in representing employers in workers’ compensation and a frequently used legal resource for questions and clarification by our primary blog writers, Michael Stack and Rebecca Shafer.

 

We pay a tribute to him with a compilation of some of this extensive writings. Because his library of articles is so large, and the information so valuable, we have broken it into 3 parts. Employers are recommended to use this information as a reference for workers’ compensation defense best practices.

 

Part 2 of 3:

 

Deny Work Comp Claims From Disallowed Unemployment

Can a worker who files a claim for unemployment and loses because of a justifiable dismissal then file for workers comp? Yes. And it happens all the time. The danger for employers is that the existence of the unemployment claim is not automatically known to the carrier or the New York Workers Comp board, causing many comp claims that could be defeated to be allowed at great expense, ultimately, to the employer.

 

Investigating Work Comp Fraud: Concealed Working Off The Books

If an employer has, say, a hundred or more workers who are semi-skilled, sooner or later there will be a comp claim in which suspicion grows that the worker has healed but is working off the books. This is a common problem in large metropolitan areas where activity is more easily concealed.

 

Injured Worker’s Personal Problems Lead To Dangerous Workers Comp Claims

There are classes of comp claims that start as ordinary reports of injury but quickly turn into claims nightmares. Among these is the younger worker claim in which an otherwise healthy person develops an inexplicably complicated claim. An explanation that needs to be considered is “trouble at home leads to trouble at work”.

 

‘See Attached’ Is Best Way To Complete First Report of Injury

The employer’s first report of a possible accident can be a dangerous trap when dubious claims are being reported. This is due to the fact that first injury forms are not designed to capture the information necessary to make decisions which are critical in the first days following an accident report. The decisions can be triaged into categories: there has been a clearly compensable accident, there has not been a work related accident, there has been a report which requires further investigation. (The second, there has been no compensable accident, also requires further investigation to document reasons for an objection.)

 

Defense In Depth On Work Comp Claims: The Employer’s Role

“Defense in depth” is a principal from conflict theory which promotes using several defenses in coordination instead of seeing them as separate defenses to be used one at a time. Sometimes, the phrase “mutually supporting” is used. In work comp hearings, defense issues often are identified and documented but they are not processed so that the use in hearings is enhanced.

 

 

Author: Attorney Theodore Ronca was a lawyer from Aquebogue, NY. He was a frequent writer and speaker, and represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years.

Two Basic Rules To Solve Workers Compensation Problems: Attorney Ted Ronca Tribute

We recently learned some sad news that one of our long-time contributors to Workers’ Comp Roundup, Attorney Ted Ronca, has passed away due to health complications.  Ted was a wealth of knowledge in representing employers in workers’ compensation and a frequently used legal resource for questions and clarification by our primary blog writers, Michael Stack and Rebecca Shafer.

 

We pay a tribute to him with a compilation of some of this extensive writings. Because his library of articles is so large, and the information so valuable, we have broken it into 3 parts. Employers are recommended to use this information as a reference for workers’ compensation defense best practices.

 

Part 1 of 3:

 

What Your Employees Fear Most After A Work Comp Injury

Fear, silence, and uncertainty do more to drive workers’ compensation costs than is generally appreciated – and these factors are fairly simple to control through employer involvement. Attorneys in the field quickly learn that an unpaid medical bill is certain to drive a worker to a lawyer, but there are many other fears which will also do the same thing. Job security is perhaps the second greatest fear, but much else can cause dangerous anxiety. Your workers will quickly find themselves worrying about problems which don’t exist and can’t exist, but these problems will be very real unless someone communicates with them.

 

Two Basic Rules To Solve Workers Compensation Problems

Nearly all compensation problems are solved by employers if they follow two basic rules: 1. Communicate early, 2. Communicate thoroughly.

 

The Work Comp Claim Isn’t Over Until It’s Over

Yes, this article honors Yogi Berra, but not for the reason you might think. His now famous phrase, about a game (or a season) not being over until it’s over has become the archetype for a thought which is a) true, b) egregiously obvious and c) useless. But Yogi may well have the last laugh.

 

Warning For Employers: Social Security Problems & Consequences For Workers Comp

The trust funds for the Social Security disability benefits program are nearly exhausted and will be gone by 2016. What consequences are there for an employer’s workers compensation costs?

 

Pay Particular Attention To Work Comp Claims That Overlap With Other Laws

“Flexibility” when you’re involved in a claim of any kind, gives you options – and that means having several ways to deal with a problem. But flexibility can mean much more. It can also give an employer freedom of action; in addition all others involved in a claim do NOT have the same advantages that the employer has.

 

Author: Attorney Theodore Ronca was a lawyer from Aquebogue, NY. He was a frequent writer and speaker, and represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years.

 

Opportunity for Employers To Locate Medical Providers in New York

An investigation team for a major television station in New York reported that many workers were finding it increasingly difficult to find doctors willing to treat a workers’ compensation claim. Lists of doctors authorized to treat workers comp claims were found to be outdated with many or even most of the doctors on the list no longer willing to treat new patients.

 

The Board has a help line to find workers a doctor but the law itself contains an opportunity for employers. It is a common misconception that the employer can have no role in medical treatment of compensation claims. In fact, the law compels the employer to assist in providing a doctor IF requested to do so by the employee. Furthermore, Sect 13-a(3) of the NY Workers Compensation Law authorizes the employer to transfer treatment if it’s in the best interests of the worker.

 

 

Employer In Best Position to Locate Medical Care

 

Why would an employer want to get involved? Well, the employee is being helped by the employer during a frightening period in which the employee is adrift. The employer, with some small effort, is in a far better position to call the Board and obtain lists of local providers.

 

A local medical group receiving a call from the employer, will be more likely to take the patient, especially if the employer explains the situation and offers to pay directly for the initial treatment. (Employers are authorized to pay but it must be reported to the carrier. The medical provider then follows the rules for filing medical report.)

 

 

Workers Compensation Board Encourages Employer Assistance

 

The employer need not fear that the Workers Compensation Board will object or interfere. Workers who need help in finding treatment face a critical problem and the Board welcomes assistance from employers.

 

Is all this a new change in the law? Far from it. This has been in the workers compensation law since its inception in 1914. Have employers ever done this? Rarely, but it deserves to be better known.

 

 

 

Author: Attorney Theodore Ronca is a practicing lawyer from Aquebogue, NY. He is a frequent writer and speaker, and has represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years. Attorney Ronca can be reached at 631-722-2100. medsearch7@optonline.net

 

©2016 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

 

What Your Employees Fear Most After A Work Comp Injury

Fear, silence, and uncertainty do more to drive workers’ compensation costs than is generally appreciated – and these factors are fairly simple to control through employer involvement. Attorneys in the field quickly learn that an unpaid medical bill is certain to drive a worker to a lawyer, but there are many other fears which will also do the same thing. Job security is perhaps the second greatest fear, but much else can cause dangerous anxiety. Your workers will quickly find themselves worrying about problems which don’t exist and can’t exist, but these problems will be very real unless someone communicates with them.

 

 

Employer Needs to Maintain Communication

 

The employer does not have to be a counselor or advocate to control such stress, it just needs a credible reason to maintain direct communication. Other laws, OSHA, DOT, FMLA, contain provisions for employer directed medical examinations which are separate from workers’ compensation. These demonstrate the employer’s concern and can be performed days after an injury is reported.

 

If an employee’s disability extends for more than a few days, a phone call at reasonable intervals to inquire about any difficulties in obtaining proper medical care or simply in purchasing food service as an excellent way to maintain contact.

 

The employer should be aware that many workers live alone and even one week at home can be a difficult experience. Also, the employee will be communicating with a new and often mysterious group of individuals that are inevitably part of the claim process – claims examiners, medical office personnel, state boards, and lawyers. Each of these will be speaking to them in unfamiliar technical terms.

 

The employer, who has been through previous workers’ compensation claims, can serve as an interpreter. The employer can also answer many related questions, especially with regard to short-term disability if the claim should be contested.

 

 

Employee’s Spouse Is Your Greatest Ally

 

The employer will also be able to answer most of the concerns of the spouse. Disability is a family problem and the spouse is your best ally. Spouses do NOT generally favor extended disability and will do more to make a return to work effort succeed than an entire team of vocational rehab experts. Never cut off communication with such a valuable friend.

 

In short, silence is the worst enemy of an effective disability management program.

 

Author: Attorney Theodore Ronca is a practicing lawyer from Aquebogue, NY. He is a frequent writer and speaker, and has represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years. Attorney Ronca can be reached at 631-722-2100. medsearch7@optonline.net

 

©2016 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

 

Unwitnessed Accidents And NY Workers Compensation

A recent decision, Siennikov v. Professional Grade Construction Corp., restricts presumptions in favor of compensability, greatly assisting employers with unwitnessed accidents. While the decision does not change existing law it halts a gradual drift, through misinterpretation, regarding what is to be assumed in the absence of actual evidence.

 

 

Merely Filing a Work Comp Claim Does Not Mean It’s Compensable

 

Section 21 of the NY Workers’ Compensation Law, presumes that an accident which occurs at a workplace during work hours is work related, absent substantial evidence to the contrary. But in recent decades that has been incorrectly broadened to mean that every claim filed, even if unwitnessed, in presumptively correct.

 

The new decision reaffirms that old rule. The presumption applies only to accidents which are shown to have actually occurred. There is no presumption that an unwitnessed accident has actually taken place. Merely filing a compensation claim does not mean that anything is presumed to have actually occurred.

 

How should this affect the way an employer reports accidents to the Board and carrier? If an employer in filing its own report of injury (C-2) merely repeats what the employee stated it will appear that the employer has done some investigation and sees no reason to doubt the claim. If that is ever to be unraveled it will involve trials, testimony and appeals.

 

How does an employer deal with this?

 

 

Investigate Unwitnessed Accidents ASAP

 

As soon as an unwitnessed accident is reported contact the carrier by phone, email and surface mail (all three!) and inform the carrier that an unwitnessed  accident has been reported BUT CAN NOT YET BE VERIFIED. Say that an investigation will be done ASAP.

 

If an investigation verifies that an accident has occurred, so notify the carrier. This will limit unnecessary issues and focus attention on issues that can be developed.

 

If an investigation still cannot confirm, by objective evidence, that an accident has occurred send a written addendum to the carrier by email and surface mail. AND include a phone call. Make a detailed summary of what efforts were made to investigate the claim.

 

When mailing material do so by certified mail, return receipt requested, and carefully save your copy with proof of mailing.

 

Unwitnessed accident account for a large percentage of workers compensation contested claims. Early efforts by the employer will greatly improve results.

 

 

Author: Attorney Theodore Ronca is a practicing lawyer from Aquebogue, NY. He is a frequent writer and speaker, and has represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years. Attorney Ronca can be reached at 631-722-2100. medsearch7@optonline.net

 

©2016 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

 

Was Benjamin Franklin the Father of Disability Insurance?

Benjamin Franklin often had the ability to think decades, and sometimes a century, ahead of others. For instance, he founded in 1727 a business discussion group, called “The Junto” in Philadelphia to discuss business topics of common interest. We have a list of topics he proposed, one of which was “Should businesses provide insurance to employees.” (He actually referred to them as “servants”.)

 

We don’t have the minutes of that discussion but we know that nothing, at the time came of it. Why?

 

 

Franklin Over 80 Years In Advance Of First Work Comp Law

 

Franklin was thinking far ahead of the medical treatment and vocational help that was available. In fact, he was over 80 years in advance of the first workers’ compensation law (Sweden, 1810). A compensation law, in Franklin’s time, would have been unable to provide much more than primitive setting of a fracture, and not much else. Medical treatment would have included leeches and a wide variety of herbs and chemicals of no use whatsoever. Furthermore, all labor was heavy and any injury would have been total unless it healed itself pretty quickly. Franklin’s head was in the right place, but state of the art science was not.

 

Franklin was 21 when he created the junto and made the insurance proposal.

 

The fact that modern disability insurance laws did not become possible until the 1880s was due to modern surgery and sterile procedure appearing at that time which made it possible to survive serious injury. In the United States, the appearance of X-rays in the years just prior to World War I made the treatment of serious fractures far more effective, as did the appearance of modern pharmaceuticals. (Aspirin was the single greatest advance in the management of pain in history.) In the first years of workers’ compensation in the United States, fractures were about the only conditions covered.

 

 

The Modern Prometheus

 

But Franklin wasn’t through with contributions to speculative medical advances. His work on electricity in the 1750s (the kite experiment) led the scientist/philosopher Emmanuel Kant to call him “the modern Prometheus” (Prometheus stole fire from the Gods – lightning – to help mankind.) And Mary Shelley, in 1817, stated in a literary preface that her story was not fiction and might very well become reality in the near future. That was the preface to “Frankenstein”, and the title was no accident. Victor Frankenstein was also called “the modern Prometheus”.

 

Franklin also anticipated the paddles that presently are used for cardiac resuscitation.

 

 

Author: Attorney Theodore Ronca is a practicing lawyer from Aquebogue, NY. He is a frequent writer and speaker, and has represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years. Attorney Ronca can be reached at 631-722-2100. medsearch7@optonline.net

 

©2015 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

 

Employers/Carriers/TPAs/Brokers/Vendors looking for additional information FREE resources for Workers Comp cost containment best practices are invited to access Amaxx FREE Workers’ Comp Cost Containment Essentials training series

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

 

Right Way And Wrong Way To Investigate A Work Comp Claim

Should employers be involved in investigating dubious compensation claims? Yes, of course – if they do it correctly. Two examples show, rather dramatically, a right way and a wrong way. Each, in its own way, serves as an example from which an employer may learn. Both examples are completely true events which occurred in the New York City area a few years ago.

 

 

Right Way To Investigate A Claim

 

First, the right way. A small employer had a worker out of work from a work comp claim. A co-worker reported to the employer that the worker on disability was working off the books as a self-employer owner of a truck vending coffee and snacks.

 

The employer, at its own expense, engaged an investigator to trail the employee. Rather quickly, impressive motion pictures captured the employee selling from the truck. Even more dramatic was the footage showing the employee performing repairs on the truck, crawling under it with a large wrench and playfully twirling the wrench after he crawled back out.

 

The footage showed not merely an exaggerated claim but considerable IRS fraud as well. The employer forwarded the material to the carrier, and had it shown at a workers’ compensation board hearing. The worker made an excuse that he could not attend the hearing as he had to go to his cousin’s wedding. The claim, of course, was closed without further awards.

 

 

Wrong Way To Investigate A Claim

 

Now, the wrong way. A moderately large self-insured employer had an in-house workers’ compensation claims unit. The unit was told that a worker out on a work comp claim, was, in fact, working. The unit quickly engaged an investigator to follow the worker and photograph him reporting to work. The investigator reported back that he had succeeded. Would the employer approve further detailed investigation? It did. Films were sent showing conclusively that the employee was reporting daily for work.

 

 

The problem? He was reporting to his regular job with his employer. He was, in fact, working one floor below the workers’ compensation unit! And the investigator was a former claims examiner who had handled workers’ compensation claims, at a TPA, for that very employer.

 

 

Ask Questions, Look At Pictures & Reports

 

In both cases the employer had received factually correct information. In the second case, the employer had never asked the correct question – who is the employer paying this employee? Nor did the employer ask to see the first photos, showing the worker driving into its own parking lot!

 

The first employer, a rank amateur at claims and investigations, had used a little common sense and got everything right. The second used a team approach with trained professionals and provided its outside counsel with a “you can’t make this up” story for future seminars.

 

But the second employer was fortunate in that the investigation effort never got beyond the unit and served as a live training event. The unit never made a similar mistake again.

 

Please, be involved. Just ask one or two more questions.

 

 

 

Author: Attorney Theodore Ronca is a practicing lawyer from Aquebogue, NY. He is a frequent writer and speaker, and has represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years. Attorney Ronca can be reached at 631-722-2100. medsearch7@optonline.net

 

©2015 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

 

Two Basic Rules To Solve Workers Compensation Problems

Nearly all compensation problems are solved by employers if they follow two basic rules: 1. Communicate early, 2. Communicate thoroughly.

 

 

Employers Begin Reaching Out Far Too Late

 

Employers with complaints about the handling of a problem claim nearly always begin reaching out far too late. Complaining only after the litigation is finished and the results are in is far too late…and far too common.

 

The period for communication that yields the best results is immediately following a report of injury. This is the period where an employer can gather the most useful information and send it to the carrier so that it can be used most effectively. During this period (the first week after the first report) the employer will, inevitably, have questions. This is also the period in which to use the phone to get those questions answered.

 

 

Best Sign Of Poor Communication Is Blank Spaces On Forms

 

The best sign of poor communication is blank spaces on forms that the employer completes. A blank space may occur because the employer has insufficient information or thinks that the carrier or someone else will get the information if it is needed. Most assuredly, that will rarely occur. Blank spaces, at best, cause delay; at worst, they cost money. So eliminate blank spaces on forms. And call the carrier when you need help – before you stop writing.

 

Communication by the employer is not just with the carrier. Employees are usually required to file a written claim form with the compensation board and carrier. If the facts on the employee form do not match the facts on the employers report a contested claim may follow. Therefore, it is best if each party receives a copy of the other’s form and contradictions are resolved before the forms are mailed (or e-mailed) to the carrier and board.

 

 

Communicate With Treating Health Facility

 

Communication by the employer with the treating health facility is also highly desirable at the start of a claim. Most employees calling a compensation lawyer do so because the initial medical bill goes unpaid and the worker receives a demand for payment from the health facility. Usually this is triggered by the facility’s failure to communicate properly with the compensation board or the carrier. If the employer encourages employees to bring initial payment problems to its attention the number of claims with lawyers will drop dramatically.

 

In addition, a compensation claim may be involved with simultaneous claims for negligence, unemployment, private disability insurance and discrimination. The employer will usually have file of information on each, where it will do no good unless the carrier is alerted to the existence of such files.

 

Silence, in the presence of claims, is only golden for your opponents.

 

 

Author: Attorney Theodore Ronca is a practicing lawyer from Aquebogue, NY. He is a frequent writer and speaker, and has represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years. Attorney Ronca can be reached at 631-722-2100. medsearch7@optonline.net

 

©2015 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

 

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

 

Is Workers’ Compensation Destroying Social Security Disability?

Believe it or not, the title is based on actual allegations being made in DC. Members of congress have published a statement linking declining workers’ compensation costs to rising Social Security Disability Income costs (both being measured per hundred dollars of wages paid in the national workforce). The ominous conclusion is that savings in workers’ compensation costs must be transferred to the SSDI trust funds (which are now officially zero).

 

To prove the assertion, one can look at the gradual rise  in SSDI costs since 2000, vs the gradual decline in workers compensation costs. Convincing? Hardly.

 

Some additional information is needed:

 

First, the Social Security regulations have been relaxed somewhat to allow for more people to qualify for disability income. That alone could account for the rise in SSDI.

 

Second, workplaces are safer than ever. Plus, more workers’ compensation boards are using objective evidence standards to measure disability.

 

Workplace safety has been on the rise, steadily, for decades, due to an economy based less on brute force activity and more on machine assisted tasking. In addition, safety technology and medical advances have greatly reduced the frequency and length of lost time.

 

Several decades ago, workers’ compensation was operating under assumptions which can be traced to the state of the art practices in medicine prior to 1914. Tables which awarded benefits for arm and leg fractures were based on average outcomes in treatment in English factories from 1848-1888. Those tables were incorporated into US compensation laws in the early 20th century and only recently have been replaced by modern methods of evaluation.

 

So what is to be made of increases in SSDI vs the decreases in workers compensation? Declining costs of workers’ compensation, if due to enhanced safety, should not be characterized as a “race to the bottom”, as was suggested in the congressional paper. Nor should rising SSDI costs be seen as the result of cost transfer from workers’ compensation to Social Security – especially where the definitions of disability were intentionally changed to allow for more disability awards.

 

Your correspondent has handled Social Security disability claims since 1977 and workers’ compensation claims since 1975. The bulk of Social Security claims are for conditions with onset after age 50, mostly through gradual degeneration.  About 20% of all claims are for chronic mental illness. The change in standards was long advocated by state agencies bearing the bulk of responsibility for many disabled.

 

 

 

Author: Attorney Theodore Ronca is a practicing lawyer from Aquebogue, NY. He is a frequent writer and speaker, and has represented employers in the areas of workers’ compensation, Social Security disability, employee disability plans and subrogation for over 30 years. Attorney Ronca can be reached at 631-722-2100. medsearch7@optonline.net

 

©2015 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

 

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional.

 

 

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