Correct,17 but they have no statutory authority to18 remove anyone.19
Thank23 you, Mr. Chairman.24 If I can just add to -- and I'm25 112 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 not sure if exactly she asked for this,2 too. On the list that you're sending to3 the Chairman, Mr. Scott, I know she asked4 about the physical therapy folks, which I5 know we're concentrating on here today,6 but how about the same information on the7 doctors --8
-- and10 their zip code? I don't know if that was11 made clear. We would like that too, if12 possible. And whatever those doctors'13 specialties are, like what they14 specialize in.15
And just17 generally -- and I know Councilman Kenney18 has been asking this, but I guess what19 I'm really -- if you heard the questions20 I've asked of the previous witnesses, I21 guess I don't understand why at least22 something wasn't sent in writing to these23 people kind of explaining what the24 problem was, either beforehand, a warning25 113 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 letter, if you will, or, at the very2 least, afterwards. Because just having3 all this verbal thing -- and like4 Councilman Kenney said, I don't have any5 reason to doubt these people, but it6 would seem like it would cover you guys7 better if you had something in writing8 and saying this is why Premier Comp9 Solutions was taken off the panel,10 something to that effect.11
Yes, Councilman.12 My name is Lee Herzer, Vice-President of13 Operation for CompServices.14 I think your point is very well15 taken. I think that's something that we16 will implement into the future. However,17 I think it's important to point out that18 the contracts that these providers have19 and any providers have with CompServices20 don't guarantee nor even imply their21 participation in any panels whatsoever.22 It's a contract to provide care with23 CompServices. We have other clients24 besides the City, including SEPTA, the25 114 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 Commonwealth employees. We handle the2 claims for the 90,000 state workers and3 many other businesses throughout the4 state.5
I6 understand there's no guarantee, but I7 guess -- again, I think Councilman used8 the term just fair business practices. I9 mean, it just seems so, for lack of a10 better term, loosey-goosey the way this11 is all done, you know. They don't find12 out, then somebody gives them a call, and13 somebody is not sure if it's them or the14 City. You know, I mean, it's kind of15 very non-professional. I don't mean to16 preach here, but good grief.17
As Dr. Korevaar18 indicated, I think, earlier, the meetings19 that are held between our medical20 director, the City medical director and21 the medical directors of the six prior22 sites, I believe that Dr. Korevaar's23 opinion was that some of the providers24 were given adequate verbal notice that25 115 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 the City had issues with some of the2 things that were happening at the3 different sites.4
It seems5 to be -- I'm sorry. It seemed to be6 disputed. I think the answer to my7 questions and the other Councilmembers8 were that they were not told anything.9 Now, I don't know, but that's where I get10 back to sort of the writing idea. I11 mean, after a while -- I like the12 personal contact too, but after a while,13 it seems like almost a -- a regular14 employee, when he or she screws up, gets15 a warning letter so that they can't later16 say, I didn't know I had a problem, you17 know. It just seems like the best way to18 cover everybody in this, and then there's19 not a he said/she said thing. Well,20 here's a letter. But from what I hear21 from Premier Comp, that the only thing in22 writing was the e-mails that they sent to23 the City or to CompServices or both,24 whatever.25 116 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
That's correct.2 Our Director of Provider Relations made3 the phone call and that's how notice was4 given.5
But I6 think it was after the inquiry was made,7 correct, like why aren't we getting --8
No, I don't9 believe that to be true at all. I10 believe that a call was made to Premier11 Comp within two days from when the12 decision was made and prior to the13 delivery of the panels.14
Well,15 obviously you can't -- and I'm not16 doubting you, like I can't doubt them,17 but, you know, again, just something in18 writing.19 And are there exactly written20 guidelines, again, maybe that we could21 see too as far as like Dr. Korevaar22 talked about the repeat visits, that kind23 of thing? Is there some kind of basic24 guidelines that you're supposed to meet?25 117 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
Right. Our2 medical providers and our nurse case3 managers are supposed to follow the ACOEM4 guidelines, as Dr. Korevaar mentioned,5 that provide standards of care for6 various types of injuries based on the7 diagnosis code, what protocols should the8 doctors be following to treat injured9 workers with a specific injury.10
Yeah.15 Could we get a copy of that? Because16 that way I think we're clear on some of17 it.18
I'm just19 curious as to once an injured worker20 receives a prescription from one of the21 docs from the six sites and takes that to22 the zip-coded-required place they go, do23 they need a prescription every time they24 go?25 118 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
So why4 aren't the docs who are writing the5 prescriptions as much at fault as the6 folks who are carrying out the7 prescripted request of a medical person?8 I mean, it seems to me that if I have six9 sites and six docs or six practices that10 deal with this and every month that11 employee gets a new script to go back to12 Dr. Bonner or to Bustleton, why is the13 provider of the therapy at fault and the14 doc doesn't have any ramifications for15 writing the script up every month?16
The doctors are17 called to task on this monthly at the18 Medical Director's Meeting.19
The meetings are22 memorialized in writing. I do minutes23 and an agenda. And every month this is24 emphasized and the doctors are told that25 119 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 we expect you to adhere to the2 guidelines.3
So the docs4 that wrote the scripts that created the5 over-utilization of these particular6 companies, are they all still part of7 this network? Has any of the docs been8 removed who have written multiple scripts9 that put these folks in the position that10 they're in to be removed from the system?11
Not to13 interrupt you, but it would seem to me14 that if I'm a physical therapist or15 running a physical therapy company and I16 have a doc who is, of course, somewhat17 above me in ability and in education and18 in experience, that if I get that script,19 I should carry out that request. I20 shouldn't be penalized for a doc -- or at21 least be unilaterally penalized for a doc22 who keeps writing scripts monthly for23 folks who are now putting these people24 out of the network.25 120 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
Well, actually,2 there are physical therapy guidelines3 that state that when a person reaches a4 plateau, it is your job as the therapist5 to communicate that back to the doctor,6 and part of what we've asked of all the7 physical therapy provider sites is that8 they oversee the therapists so that that9 does occur, so that they remain within10 the physical therapy guidelines for11 numbers of visits.12
But they13 can't get reimbursed without the14 prescription. If, for example, I have15 hurt my back and I go to my --16
-- site and19 I get my prescription and I go for the20 standard set of therapy and I plateau,21 how do I get continued therapy without a22 prescription?23
You don't need24 continued therapy when you plateau. In25 121 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 fact, there's good evidence --2
-- that if you5 keep going, you become dependent and you6 get worse.7
I'm not8 arguing that. I'm not arguing the person9 shouldn't plateau. What I'm saying is is10 that how does the physical therapist11 continue providing service to a plateaued12 patient without a prescription from the13 doc at one of the six sites?14
Correct.21 So if they don't have a prescription from22 the doc at one of the six sites, how does23 the therapist get paid for continuing to24 provide service that the doc hasn't25 122 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 authorized? You're telling me the2 patient needs a prescription every month.3
But we also -- one4 of the other things that we find is that5 these providers have a higher cost per6 claim than --7
That's8 another issue. That's a separate issue.9 I'm just talking about the frequency.10 The frequency of physical therapy being11 given to a patient is based initially on12 a prescription from a doctor that needs13 to be prescribed again every month --14
So now when19 the person plateaus, why is the doc still20 issuing a prescription for continued21 physical therapy?22
Okay. The25 123 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 doc should not be. So why isn't the doc2 removed, just like these other companies3 have been removed, for providing more4 services than is authorized?5
There are some6 doctors who are on our panel by labor7 agreement, and those doctors I can't8 remove from the panel without --9
But think14 of kind of the silliness of it, is that I15 have a physical therapy company that16 loses its relationship with the City17 somewhat based on prescription18 requirements being issued by doctors at19 six approved sites that can't be removed20 for things that they do.21
We have physical22 therapy sites, including La Fortaleza,23 who will not continue to treat when24 someone has plateaued, who will pick up25 124 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 the phone and talk to the doctor, even2 the doctors that we cannot remove. And3 so --4
So you're5 telling me that a physical therapist can6 call up a doctor and tell he or she as a7 doctor that you're wrong, stop writing8 these prescriptions?9
It has happened13 to me, and I respect the therapist.14 That's why I send my patient to the15 therapist to start with. The therapist16 is the one who knows when a plateau has17 been reached. I count on the therapist18 that I send my patients to to do just19 that.20
How many21 docs are beyond reach of the six sites22 contractually, they could write a script23 a day and you still can't get rid of24 them?25 125 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
They're not in that2 six, that group of six. There are3 another four docs in this other group.4
Initially8 the testimony was there were six sites9 and six practices that dealt with this.10 Now where are the other four from?11
The other four are12 primarily -- there's three in the13 Northeast and one in South Philadelphia.14
They have to sign a21 contract with CompServices.22 COUNCILMAN KENNEY:23 Councilwoman, do you have any other24 questions, because I do think -- I25 126 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 appreciate your being here and your2 patience. It is an extremely complex and3 somewhat less than transparent -- I don't4 even like the word "transparent," but5 since it's been used so much, somewhat6 less transparent than I would like, and I7 do feel that there are folks who are8 legitimate businesses in the City who9 have had relationships with this process10 for years that are now gone, and there's11 still some other stuff there that just12 seems like it needs more explanation or13 at least more light.14
Some of the -- and15 I apologize for some of the lack of16 transparency. It has to deal with the17 medical issues that play and the patient18 care issues.19
We're not20 getting into HIPAA. That's not the21 issue. I don't need names and Social22 Security numbers. I'm just talking in23 generalities how folks move through this24 process. But I still believe that it is25 127 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 inherently unfair to eliminate a company2 that is providing services that's being3 prescribed by a physician. And, you4 know, Doctor, you've made your comment5 that any physical therapist would call up6 and challenge that physician. I don't7 know whether -- I've never seen a nurse8 challenge a physician or a physical9 therapist challenge a physician, because10 physicians have their own view of11 themselves and their abilities, but I12 guess --13
And just to say,16 that one of the things that we're also17 looking at is the fact that we have a18 provider who can provide the care at a19 lower cost to the City. And so if I have20 Provider A and Provider B, and Provider A21 can provide me the same services that22 Provider B can provide at a cheaper cost23 to the City, that's one of the things24 that we're looking at as well.25 128 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
Rates are also11 negotiated between CompServices and the12 providers.13
But it's14 still within the guidelines of what the15 City wants to spend. So, I mean, if16 there is a guideline of what the City is17 looking for themselves to spend on18 physical therapy, you really can't go too19 far outside that guideline, and when you20 contract or put a company on a panel,21 going in you know what their numbers are.22 Their numbers change during the course of23 the year?24
Well, why2 do you let that happen? Reimburse them3 for what you agreed to reimburse them4 for. I mean, if I have a contract and I5 say I'm going to provide X, Y and Z for a6 certain price and six months later I7 double the price, you're not paying me.8
No. Our contracts9 are based on and workers' comp is based10 on a state fee schedule. So our11 contracts are based on a percentage below12 the state fee schedule or a daily rate,13 so --14
Is the15 state fee schedule higher than what the16 City's fee schedule is?17
The state fee18 schedule is higher because we're19 contracting at a percentage below the20 state fee schedule.21
How do we22 get away with charging less than what the23 state fee schedule is?24
It's contracted.25 130 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
But the2 state fee schedule, I assume, is in some3 state code somewhere.4
But the Workers'6 Comp Act allows companies like7 CompServices to contract with providers8 at something less than the state fee9 schedule.10
Thank13 you, Mr. Chairman.14 I just want to spin off in just15 a slight different direction, if I could.16 Just quickly, because I know it's been a17 long hearing, but I'm looking at more18 towards the treatment or the procedure19 for the employee if he or she gets hurt.20 Can you just briefly take me through the21 process. Somebody gets hurt, where do22 they start, you know, that kind of thing,23 Mr. Scott.24
Assuming that it's25 131 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 not an emergency injury where someone's2 life is at risk, they would go to one of3 our treatment sites based on the zip code4 of their work location. They would go to5 those sites. They would see the primary6 care doctor. The primary care doctor7 would diagnose them, would prescribe8 whatever needed to be prescribed, maybe9 medication, maybe they needed some10 diagnostic work, some diagnostic imaging,11 maybe they needed some durable medical12 equipment. The primary care doctor would13 prescribe that. If they needed to see a14 specialist, the doctor would identify a15 specialist that they would need to see,16 and then that person would be referred17 through the nurse case manager at18 CompServices for an appointment with19 those providers, any specialist providers20 or follow-up care.21
Now, the22 doctor prescribes a certain treatment.23 Is that always what happens or does24 somebody else intervene to say, We think25 132 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 this is appropriate or not, if you know2 where I'm going with this?3
The nurse case4 manager, the medical director and -- the5 medical director of the CompServices and6 the medical director for Risk Management7 may all intervene in some way if there's8 a concern about the care. The system9 that we're providing here is a system for10 injury care, and so it is really11 important that the providers in this12 system focus on the work-related13 injuries. There's another system for14 handling my degenerative conditions, and15 that's a system that we don't run.16 We are -- so we're really trying to17 always tease out those conditions which18 may be a condition that a person comes to19 us with from the work-related injury. So20 we're looking at providers who are able21 to make that distinction and that22 determination and provide care for the23 work-related injury exclusively.24 There's a number of things that25 133 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 may happen. A doctor may not accept2 workers' compensation insurance, so they3 will not take a case that is referred by4 our doctor because they don't take5 workers' comp, and there are a number of6 physicians who practice in that way.7 They may be outside of our jurisdiction.8 Workers' compensation law works by state,9 and so those doctors in the State of10 Pennsylvania work under a different set11 of rules than those doctors in New Jersey12 and Delaware and Maryland and New York.13 So the rules that the doctor may work14 under also play a role in it.15 So those things may be -- it's16 a fairly complex thing. In most cases --17
In most cases, it20 rolls fairly straightforwardly, because21 the doctors are in our system, they know22 the specialists. We have a number of23 specialists who are on the panel in our24 system and so we use those providers for25 134 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 the specialized care.2
I mean --3 and you know there's one case that you4 and I talked about, but just generally, I5 know you hear sometimes that people say6 or City employees say, Well, I got this7 recommendation from the doctor I saw, and8 somebody else is saying, whether it's9 CompServices or Dr. Korevaar or somebody,10 is saying, you know, No, that's not the11 way to go. So I think that's the sort of12 frustration sometimes.13
We, over the14 years, have had problems sometimes15 finding specialists. You may recall a16 number of years ago many specialists left17 Philadelphia County because of the18 malpractice awards, and we had to really19 work hard to fill the gaps on our panels.20 I get questions from21 CompServices frequently about whether22 somebody can go off panel to somebody who23 does a very specialized kind of surgery,24 for example, and I try very hard to25 135 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 identify a person within Philadelphia to2 whom this patient can be referred if we3 don't have such a person on the panel.4 We do try to stay within Pennsylvania,5 and the reason for that is because if you6 leave Pennsylvania, then if the provider7 does not hold a Pennsylvania license,8 they may balance-bill for the total9 charges, and we do not want any of our10 injured employees to be balance-billed,11 because under Pennsylvania law, they12 should not be. So we do try very hard to13 stay within Philadelphia. It happens14 pretty frequently that we need to look15 around to find a specialized doctor, and16 we do our best. It's not always as17 simple as it may seem.18
No; I19 understand. But at some point, the20 person, the employee, needs some21 treatment and they want to make sure that22 they're getting, I guess, what they're23 supposed to and what the doctor that24 examined them is saying they should get.25 136 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 I guess that's the concern. And I2 understand cost and all. We're well3 aware of that. So I get you, but I think4 in some cases we've heard it can be kind5 of frustrating. It seems to take a6 little bit of a long time, and it has to7 go touch a lot of hands sometimes.8
Well, it9 actually comes usually pretty directly10 electronically to me. Even if I'm not11 down here, I'm on my e-mail more than I12 should be, and I take it with me on13 vacation. So we do try very hard. Barry14 sends me requests as soon as he gets15 them. We try very hard not to have a16 time lag. Sometimes we can't control the17 time lag. Sometimes doctors aren't18 willing to see somebody for a couple19 weeks, and there's nothing that we can do20 about that.21
Just22 lastly, Doctor, just so I'm clear, you're23 not a City employee; you're a contractor24 with Risk Management?25 137 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
Just one other4 thing. One other thing that happens is,5 we also will be mainly trying to do --6 frequently trying to do conservative7 treatments. Our first option is not8 always going to be a surgical option, and9 so we will treat someone conservatively10 perhaps for a time, and then the11 conservative treatment is not successful12 and we need to then go to a surgical13 option. And so that does delay the care,14 and someone sometimes is prolonged in a15 medical condition because of that.16
But when17 you say "we," I mean, if a doctor that18 examined the person is saying maybe the19 surgery is needed, who is the "we" that20 might decide not to, or to go the21 conservative way, as to use your words?22
If one of our23 treating doctors says that this is a24 recommendation, then we move forward with25 138 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 that, and it may require going off panel2 in order to do that. Really the delay3 happens because that specialist may not4 have an opening, or if a recommendation5 is made to leave Pennsylvania, then that6 may result in a couple days' delay while7 we try to find a specialist in8 Pennsylvania who can do the work, because9 we don't want the work to leave10 Pennsylvania, if possible.11
Okay.12 All right. Thank you.13 Thank you, Mr. Chair.14
Just15 quickly, CompServices indicated that16 although they won't send City referrals17 to these folks who have been removed from18 the panel, but there are other19 contractual situations they have with20 SEPTA, state employees, whatever. Do21 these folks still continue to get22 referrals from those other than the City?23
Yes. Premier Comp24 Solutions is still on a number of our25 139 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 panels.2 And, Linda, you would probably3 know more than I would as to how many4 they're on.5 And I believe some of the6 providers that were here today are also7 on SEPTA panels.8
So what9 would be the difference between an10 injured SEPTA employee and an injured11 City employee that would allow12 CompServices to make a referral that13 precludes them from referring the City14 employee? Is there a different fee15 schedule? Is there a different set of16 standards? I mean, if he can send them17 one public employee, he can't send them18 another doesn't seem that consistent.19 Not that I want you to stop sending them20 the other employees. I just don't know21 what happened with the City employee that22 makes them different from a SEPTA bus23 driver or a state employee.24
Again, I don't25 140 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 think we adequately described the process2 by which we use to create the panels.3 Barry touched on some of the metrics that4 we use to measure the medical care5 delivered. You know, CompServices as a6 company will process about $100 million7 worth of medical on an annual basis. The8 City represents maybe 18 percent of that.9 So we're pulling -- I have a10 lot of medical data to pull, get11 statistics, find out the average cost per12 claim and average number of visits per13 claim, et cetera. The follow-up ratio14 that Dr. Bonner mentioned, we keep all15 those statistics, and they're shared on a16 regular basis, and it's usually every17 fiscal year or every other fiscal year18 we'll meet with the City to discuss19 whether or not there's any changes20 necessary to the panels, and it's --21
I22 understand. Just in generality, why23 would an agency -- why would you be able24 to send an employee from a25 141 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 quasi-governmental agency like SEPTA2 that's in the same financial binds as the3 City as opposed to being able to send the4 City employee? I mean, if these5 providers are capable of handling a6 PennDOT worker or a SEPTA worker or a7 DRPA worker -- I don't know if you do8 them or not, but my point is, what is so9 special about the City that they've lost10 the opportunity to do them?11
The honest answer12 is that it's client dependent. I mean,13 the Commonwealth may have different needs14 than the City has. SEPTA has different15 needs than the City has. And that16 meeting that occurs to make up the panels17 goes differently depending upon the18 client.19
But in20 fairness -- I know we're talking about21 people and their health and everything22 else, but in fairness, it all comes down23 to the cost of providing that, and you24 would think that an agency like SEPTA,25 142 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 which is in as strict financial straits2 as any other governmental agency in the3 Commonwealth, it seems that if these4 folks are able to take those referrals,5 what makes the City workers so different?6
We have7 different kinds of injuries and people8 have different job descriptions, and9 so --10
I mean, the11 injuries are different in that -- I mean,12 obviously, thankfully, SEPTA bus drivers13 don't get shot. That one I got.14
And the job that19 they need to go back to is a very -- has20 very different physical requirements, and21 so some therapy sites are better equipped22 to handle certain kinds of injuries and23 to return people to certain job24 requirements than others.25 143 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
I mean, I2 just -- I mean, this is certainly one3 hearing. We may have another. We may4 have more discussion, and certainly no5 one here sitting at this panel is an6 expert on this issue, but there seems to7 be a lot of inconsistency in what8 decisions are made and how they're made,9 and that's the concern that this10 Committee has, is that -- I mean, one of11 the things, Doctor, that you said earlier12 was that no physical therapy company13 should have a 25 or 30 percent dependence14 on an entity like the City of15 Philadelphia for their --16
I think I said17 they shouldn't depend on any single18 employer.19
Basically20 the same thing. I mean, but when I look21 at NovaCare with nine centers, I mean, I22 don't know their business model or their23 business information, I'm wondering what24 the percentage -- with nine locations, it25 144 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251 would seem that you would have a higher2 percentage of City work coming through3 their doors as opposed to anyone that's4 been removed thus far.5
I don't8 think they would tell you, but my point9 is that with nine locations, I mean,10 volume would indicate that --11
Well, we're12 hoping that the volume coming in the door13 is likely to stay the same, but what we14 are looking for is the number of15 follow-up visits to drop. And so that16 really is the concern. It's not about17 who comes in the door. It's about18 whether they stay for 15 years, and that19 really is the concern.20
And it's21 also 15 years' worth of prescriptions; is22 it not?23
I totally agree24 with you.25 145 11/17/10 - LEGISLATIVE OVERSIGHT - RES. 1007251
Well, then2 I would feel better if we were3 jettisoning some docs as opposed to4 jettisoning some -- or in addition to5 jettisoning the therapists, jettisoning6 the docs that write the scripts that send7 them there.8
All right.11 Good.12 Any other questions?13 (No response.)14
Thank you15 very much for your testimony and your16 attendance today. We will probably17 revisit this at some future date and18 we'll have recommendations that hopefully19 are forthcoming.20
Thank you for your21 questions, sir.22 (Committee on Legislative23 Oversight adjourned at 1:30 p.m.)24 - - -25 146 CERTIFICATE2 I HEREBY CERTIFY that the3 proceedings, evidence and objections are4 contained fully and accurately in the5 stenographic notes taken by me upon the6 foregoing matter on November 17, 2010, and7 that this is a true and correct transcript of8 same.9 10 11 12 13 --------------------14 MICHELE L. MURPHY15 RPR-Notary Public16 17 18 19 (The foregoing certification of this20 transcript does not apply to any reproduction21 of the same by any means, unless under the22 direct control and/or supervision of the23 certifying reporter.)24 25