Neglecting compliance while expanding your med spa can lead to costly consequences. In this episode, hosts Brad and Michael reveal the risks of prioritizing growth over compliance. Discover the challenges of expanding a practice to new states and state-specific requirements. Tune in for strategies to keep your practice compliant and understand why this is crucial for your business’s long-term success.
Listen to the full episode using the player below, or by visiting one of the links below. If you have any questions or would like to learn more, email us at info@byrdadatto.com.
Transcript
*The below transcript has been edited for readability.
Intro: Welcome to Legal 123s with ByrdAdatto. Legal issues simplified through real client stories and real world experiences, creating simplicity in 3, 2, 1.
Brad: Welcome back to Legal 123s with ByrdAdatto. I’m your host, Brad Adatto, with my co-host, Michael Byrd.
Michael: Thanks, Brad. As a business and health care law firm, we meet a lot of interesting people and learn their amazing stories. This season we’re talking about businesses who decide to double down. They’re going to scale their business. Our theme this season is Growing a Business.
Brad: Right Michael. And for those who don’t know, growing a business is just one of the several seasons of business. What are the other seasons?
Michael: Great question, Brad. We have the building season, so starting a business; we have the operating season. so this is that phase where you’re running a business. We’re in the growing season right now, and then we will finish the year off with the buying and selling season. [00:01:00]
Brad: Awesome. Well, Michael, I think we need to go deep into our cortex to really form a connection with our audience. So get ready.
Michael: Okay.
Brad: What is your go-to fast food place between Chick-fil-A or Raising Canes?
Michael: Well, I think the lead story here is you just tried to squeeze the word cortex into your vocabulary, Mr. Fancy. Okay.
Brad: I did, I did. It’s a good $50 word.
Michael: Alright, well, that gave me a few seconds to think about this answer because this is tricky, because by far Chick-fil-A is the answer. But I feel like, like I know personally, I prefer Raising Canes. But Raising Canes always feels more like a treat Chick-fil-A is the default. And don’t get me wrong, Chick-fil-A is awesome, but it’s the default. We can’t arrive at anything as a consensus on our family, so we just kind [00:02:00] of settle on Chick-fil-A and know, it is just the one thing that everyone likes and everyone can do, even if they’re not in the mood, especially when other things are on the table. Raising Canes feels like it’s more of a, you know, “let’s get a treat.” My kids love the toast and the sauce and it’s a bigger to-do.
Brad: Absolutely.
Michael: What about you?
Brad: Yeah, I’m pretty indifferent. I actually like them both. I know that in my family, very similar to your story, it appears that Raising Canes has the edge when it comes to requesting that kind of fast food. Especially if we have a bunch of people coming over, they’re like, oh, just go get a big pan of Raising Canes, so that seems to be the easy out.
Michael: You know, interestingly, I have a very vivid memory of Raising Canes because the day that we’re recording this is the anniversary of us moving into our house many, many years ago, [00:03:00] and it was a long journey. We were supposed to move in a month prior to when we did, and one of the things we didn’t plan for was food. And someone I know, who I usually make fun of, but today I won’t…you and your family brought Raising Canes and a huge thing of lemonade over, and it was perfect for where we were and we wolfed it down.
Brad: Yeah. I’m so sorry. I didn’t mean to do that. I went to the wrong house. It was really awkward.
Michael: Oh, yeah. I answered, you’re like, “oh, wait here.” Okay. Well, what’s up with all this fast food talk?
Brad: Yeah. So I read an article on the founder of Raising Canes, a guy named Todd Graves. His story’s pretty amazing. So he was attending LSU in the 1990s, and Todd had this great idea about starting a fast food restaurant that only served fried chicken fingers. His professor gave him a low grade and said, I don’t think this is going to work, but Todd believed in it. He disagreed. [00:04:00] So he actually started like working these odd jobs. He was a boilermaker in a Louisiana refinery. He went all the way up to Alaska and started doing commercial fishing for Sams just to save up enough money so that he could open his first Raising Canes in Baton Rouge, Louisiana in 1996.
Michael: I hate to say it. I probably would’ve given him a bad grade as well, but shows you what I know. Well, that’s a pretty amazing story.
Brad: Yeah. And so, for those who don’t know, as of May 2024, there are nearly 700 Raising Cane restaurants in the United States. These restaurants are located in 38 states, 512 cities. The state with the most Raising Canes, Michael, is located in Texas with 177 restaurants. And Todd, with his “bad business plan” and no money to start it is now worth over $8 billion.
Michael: Wow. You made me feel really stupid for agreeing with a professor. [00:05:00] That’s pretty impressive. Okay, well, I assume that since you mentioned this story, you’re trying to build us up because we’re in the scaling season and you’ve got a great story.
Brad: Yeah, correct, and imagine all the issues Todd faced while growing an idea from one store to this brand that is now known worldwide.
Michael: So are we going to tell a story of a singular product like chicken fingers or fried chicken, or do you have another Todd Graves story for today?
Brad: No, but this is a story about scaling quickly.
Michael: Okay. Well, let’s jump in.
Brad: All right, Michael, today’s story starts in Thibodaux, Louisiana, famously known for being the birthplace of one Be-Be Adatto.
Michael: As many stories start in Thibodaux, I guess. And no offense to your mom, but I don’t think many people know where Thibodaux is located, or have even heard that term before. From what you told me, I recall it’s what, an hour or so outside of [00:06:00] New Orleans? Do they speak English or Cajun in Thibodaux?
Brad: Yeah, they don’t have no Cajun accent. they’re just more from like the Bayou area.
Michael: Oh, Cynthia I apologize for bringing that out of Brad. Can we just reset and scratch that part and go back to the story?
Brad: All right. All right. Today’s story, we start with Dr. Thibodaux, I’m sorry, Dr. Tiger, who actually is from Thibodaux. And Dr. Tiger went to LSU undergrad where he met Mr. Mike while taking some business school classes.
Michael: Okay. Well, I’ll just ask one question, Brad. Is all this Louisiana stuff going to be helpful to the rest of the country?
Brad: Yeah, obviously.
Michael: All right. Good. Well, they have their own laws there, so I just want to make sure. Well audience, we’ll just bear that in mind and if we need to point anything out, we will. [00:07:00] I bet Brad’s smart enough to bring something. So for those that are not following where Brad got his names from today, I’m assuming it has to do with LSU’s mascot, a tiger and they call him Mike. Is that right, Brad?
Brad: That’s right. Yeah.
Michael: Okay. And so I’m guessing you’re going there because the founder at Canes went there.
Brad: Yeah, yeah, that’s correct. Multiple gold stars for you, Michael. Now, so after graduating from LSU, Mr. Mike started a medical business in Louisiana and was growing very rapidly. His business initially started out as managing medical offices, but he quickly switched to actually owning them too. And as such, Mr. Mike brought several of the – so he ended up buying several of these medical practices he was managing, but he kept initial physicians there on as the supervising physicians.
Michael: Brad, I’m assuming that this story does not have a CPOM component ,or Corporate Practice of Medicine, as it’s more formally known since we’re in Louisiana, [00:08:00] and I believe Louisiana is a non-CPOM state.
Brad: That’s correct. So we’re not going to focus on CPOM. Okay. Originally, when Mr. Mike bought these clinics, they were mostly family and internal medicine practices. Now, Mr. Mike started seeing several elective aesthetic practices starting to open up, and he decided that that was where the growth area could be. So he started opening up new locations, which only focused on cash-based services, and he called this new practice, The Purple and Gold Med Spa.
Michael: Okay. Audience, when you hear the term elective services or aesthetic cosmetic treatments these are generally non-surgical services. So just some sampling of these services might be laser tightening of the skin, laser hair removal, Botox injections, dermal fillers, and then you have IV infusions, [00:09:00] and as we said last week, I believe, weight loss treatments. So purple and gold, Brad, LSU colors, am I on the right track? And then are these some of the treatments that they were dealing with?
Brad: Yes, that’s correct, on the purple and gold, and treatments. So the Purple and Gold Med Spa initially only had IV infusions, and then they set up near local colleges in Louisiana and quickly started adding other treatments. They had an idea that if they could set these Purple and Gold Med Spas up in college towns and in neighboring states too, they could start opening up like in Mississippi and Alabama. And Mr. Mike was aggressively opening up these new locations as he really didn’t want anyone else to really steal his idea.
Michael: Did I miss something? What happened to Dr. Tiger? We’ve been talking about Mr. Mike this whole time.
Brad: Pretty good timing of the question. As Mr. Mike expanded the Purple and Gold Med Spa into other service lines and states, [00:10:00] these initial physicians that were running the original family and internal medicine practices, they really didn’t have the skillset to understand all these different treatments being offered, much less oversee all these new locations.
Michael: Is this where Dr. Tiger rejoins the story?
Brad: Correct. Dr. Tiger had an ENT practice in Thibodaux and was an entrepreneur really trapped in a doctor’s body?
Michael: Well, we said that about ourselves, although we say lawyer’s body, but maybe sometimes we say we’re trapped in a doctor’s body as well.
Brad: We could be. As an entrepreneur, Dr. Tiger had devoted time to several other businesses, including a medical scheduling software company, which is how Mr. Mike and Dr. Tiger rekindled their relationship from their old LSU days. Mr. Mike was looking for a better way to schedule patients and found out that Dr. Tiger, again, his old classmate had one. As they discussed this opportunity to work with Dr. Tiger’s software, Mr. Mike pitched to [00:11:00] Dr. Tiger, “Hey, Dr. Tiger. You should be our Chief Medical Officer for the Purple and Gold Med Spa.”
Michael: Okay. Is this where we were brought in, Brad?
Brad: Actually, no. Dr. Tiger actually had an excellent corporate attorney named Mrs. Golden, and she was working with him in all these other investments, including the software company. Mrs. Golden helped negotiate the Chief Medical Officer agreement which was important, Dr. Tiger was, it gave him control over all medical decision making and allowing him to review and implement medical processes.
Michael: I want to pause for a minute and talk. You used the term Chief Medical Director agreement, and this can be a little misleading because as we’ve talked about in prior episodes, medical director agreements is a generic term. It can have a ton of meanings. And so, it really becomes important to understand what the role is. A lot of times these Chief Medical Director agreements in context to a med spa [00:12:00] is almost just like a brand awareness, almost like a doctor influencer person that is the name behind the brand, but sometimes they’re actually involved in setting clinical policies in place, and then sometimes they’re even actually involved in the chain of care. So, I have some follow up questions for you, Brad.
Brad: Okay, I’m ready.
Michael: Why, Mrs. Golden, as a name and was Dr. Tiger licensed in Mississippi and Alabama as well?
Brad: To answer your first question, the character named Mrs. Golden comes from the dance team at LSU. They used to be called the Golden Girls of LSU. And as it relates to the second, Dr. Tiger was already licensed in Louisiana, Mississippi, and Alabama. And he was actually in the process of obtaining licenses in states in which the Purple and Gold Med Spa was expanding.
Michael: Yeah. And that’s pretty normal when you have a friendly doc to fill that role of [00:13:00] getting licenses because generally speaking, you’re going to have to have a licensed physician in each state that you do business. And if you have someone that’s going back to that chief role, a lot of times that doctor will, as part of whatever else they’re doing, get licenses in each of the states where the business is open.
Brad: Yeah, that friendly physician is a good point. Good points. The more locations and states that Dr. Tiger started overseeing, the more nervous Dr. Tiger started feeling. As the Purple and Gold Med Spa was aggressively pushing for more locations, Dr. Tiger was still trying to understand their current model, and Mr. Mike just kept pushing, saying, we need to move rapid, we need rapid expansion. Dr. Tiger really started thinking that Mr. Mike was really just laser focused on the business side, but not so much on the medical side. And Mrs. Golden, she recognized that her focus on working with Dr. Tiger kind of had shifted and she started getting [00:14:00] uncomfortable with the compliance concerns that she had and Dr. Tiger had with the way the model was set up with the Purple and Gold Med Spa expansion.
Michael: I see the opening, Brad, you’re teeing it up. This is where we were brought in.
Brad: Yes. And believe it or not, Mrs. Golden and our team had worked together years ago, and she reached out to see if we could assist her and Dr. Tiger just with some of their compliance concerns.
Michael: Okay. Give us some examples. What were some of the compliance concerns?
Brad: What is considered a medical service? Who can perform initial consult for medical service? What are collaborative practice requirements between a physician and a NP or a PA? What is appropriate delegation and supervision for an RN and LPNs?
Michael: So all extremely normal questions that, especially for a non-health care attorney, they’re pretty standard basic for us, like the core things. And I’m guessing that they wanted these answers for each state. [00:15:00]
Brad: Yeah. Actually no. Originally they just wanted us to assist with developing an overall best practice guide which Dr. Tiger was going to go further develop as the Chief Medical Officer into actually the policies and procedures for all the Purple and Gold Med Spas.
Michael: So you said the word originally. Is that important? Did we actually end up doing something different?
Brad: Well, actually, like without a lot of our new clients, we like the system by first understanding their current model. And so we started off with a practice assessment whiteboard, really outlining the current model as they understood it, and we understood it.
Michael: Well, how did that go?
Brad: It went great, actually, we outlined the model, detailed some compliance aspects of the model, and for Dr. Tiger and Mrs. Golden, they loved it. And they said they want to get back to Mr. Mike and discuss next steps.
Michael: Okay, well, let’s go. What were they? What were the next steps?
Brad: So Dr. Tiger and Mrs. Golden were going through the notes of the compliance concerns raised during that whiteboard, and with Dr. Tiger [00:16:00] it was just really trying to help focus Mr. Mike on the medical side. And in doing so, he felt like they needed to slow down the expansion and really retool some of these compliance concerns that were raised in that whiteboard.
Michael: So, what happened?
Brad: Nothing. Mr. Mike and his team rejected every compliance concern that Dr. Tiger raised and said that no one was doing it that way that we were recommending, that Mr. Mike had spoken to “a bunch of attorneys’ and what we recommended was not needed.
Michael: The bunch of attorneys defense. The nameless, faceless many that say the opposite. Okay, well, what did – I’m assuming it’s your fault, Brad. I mean, what did you recommend that was so edgy that this nameless crew of a bunch of attorneys had not?
Brad: That they would need to hire more physicians to supervise the number of NPs and PAs that they were dealing with. They needed actually some local physicians to help with a couple different [00:17:00] procedures they were trying to implement. They needed a better, proper medical personnel to actually clear the patients before they started providing medical procedures, and that they couldn’t just use a standing order to skip several key steps.
Michael: Well, I really want to make fun of you, but I can’t because that’s seems pretty in line. So I’m just going to say, let’s go to commercial rather than hone in on you having some good points. Let’s take a break, and then on the other side, we’ll come back and let’s get into it.
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Brad: Welcome back to Legal 123s with ByrdAdatto. I’m your host Brad Adatto, with my co-host, Michael Byrd. Now Michael, this season, our theme is growing a business and we’re talking about business that want to scale. And today we had a story that a lot was happening.
Michael: Yeah and it’s going to be challenging. The setting is in Louisiana, and so it’s not my comfort zone.
Brad: Because of the Cajun accent?
Michael: Yes, exactly, Brad. I hope I don’t get a Cajun accent trying to reframe this. Okay, so let’s go back. It all started at LSU, right? Kind of the same place as Mr. Chicken that we started with, Todd Graves. So we have some college buddies. We have Dr. Tiger who becomes relevant a little later in the story, but they’re buddies, he’s buddies with Mr. Mike. Mr. Mike decides to [00:19:00] own some medical practices and evolves and then expands into other areas and opens up a medical spa, Purple and Gold Med Spa.
Brad: The Purple and Gold Med Spa.
Michael: The Purple and Gold Med Spa, and reconnects with Mr. Michael on the way. I mean, excuse me, Dr. Tiger. Dr. Tiger had his own business. They get reconnected, decides he needs a Chief Medical Officer, they get going. Dr. Tiger starts getting a little nervous because Mr. Mike is very focused on the business side, it seems, and growing really fast and not so worried about the medical side. Now the medical was all just IV, hydration. Am I right?
Brad: It was.
Michael: It was. Okay, and then there’s a bunch of attorneys who were telling Mr. Mike that it was all good and [00:20:00] didn’t agree with your advice that there were some compliance concerns.
Brad: Yeah. And just to add on to that if I didn’t do a good job it started off with IV, but then they quickly started doing all the other treatments that you typically see at a med spa, including Botox and fillers and lasers.
Michael: And they were expanding into multiple states?
Brad: Yeah.
Michael: Okay, and so did I catch the story right, Brad?
Brad: Good job, Michael. And as you were summarizing, there’s this large multiple state business that they were scaling, but they weren’t really focused on the compliance which is why they brought in a CMO. How do you respond when someone notes that? Well, everyone else is doing it that way and they’re super big because they were so it must be okay.
Michael: You know, it’s so tricky because number one, in some cases, that’s just people’s defensiveness. This guy seemed clearly not to care about it, and so he just hid behind the nameless, faceless mini. [00:21:00] But there’s also another side to the coin, which is, this is a really non-compliant industry, and there actually are a lot of other people that are doing it this way. And so you have kind of a place you can go high. We’ve talked about this in other episodes, and you objectively, your risk is probably lower if everyone else is doing it. I use the whole highway analogy. You’re driving a car, if you’re going 80 in a school zone, you’re going to get caught. If you’re driving 80 in the flow of traffic on a highway, and the speed limit is 55, odds are much lower. The problem is, is that well in this story, your client, ByrdAdatto’s client was the doctor, his license was on the line, so he was taking the heaviest risk. And you know, there’s not like the random radar gun that’s going to get you pulled over. It’s going to come from something that goes wrong, right? It’s going to be a patient or an employee [00:22:00] that turns you in or a competitor. Yeah. So Brad, maybe you can address one of the issues raised. What are the collaborative practice requirements between a physician and a PA and nurse practitioner?
Brad: Yeah and taking out the rule of thumb that if some nurse practitioner appears independent or autonomous, this doesn’t really apply, but generally a physician may delegate certain medical procedures such as like initial medical con consultation to a PA or NP or nurse practitioner, so long as there’s some type of written supervisory agreement between the PA and NP in that same supervising physician. This written supervising agreement must include like certain elements about what they can and cannot do. So what procedures can they do, what drugs can they prescribe? And this is also based on understanding what does that PA, nurse practitioners background from what their education and clinic training and certifications that [00:23:00] they have, and what other activities they train in before that. And that agreement may include, like I said the ability, which is important with Botox and fillers prescribing drugs.
Michael: So, yeah. Let’s kind of – in terms of the actual required level of supervision, generally speaking, the supervising physician for PAs and NPS is not required to be on site at all times. But that usually you hear this term like readily available by phone or some other form of communication. And again, this is for states where the PA and NP don’t have independence or even a higher degree of autonomy.
Brad: Right. Good point again. In addition, the supervising physician will have a limit to the number of PAs and NPs they can actually supervise. So I’ll give an example, like in Alabama, which they were, the supervising physician may not collaborate with or supervise more than nine full-time equivalent PAs and NPs, while we jump over to Florida, [00:24:00] a supervising physician may not supervise more than 10 PAs at one time. Now Michael, follow up question that we often receive is then is, well, does this mean that the supervising physician can oversee nine PAs in Alabama and then 10 PAs in Florida?
Michael: Yeah. I mean, it’s tricky because you think, well, I’m compliant in this state, and then I’m compliant in this state. The problem is it goes back to that whole absentee physician element, which is a medical board’s number one focus is going to be on patient safety. And the purpose of limiting it is so that the doctor can be engaged and not absentee and so they’re not stretched too thin. Well, if you have 19 instead of nine, when you come under investigation, that’s going to be a problem. And so that’s certainly, if you’re under investigation in a state and those facts come into the equation, it’s going to be problematic, [00:25:00] and so yeah, that’s your answer.
Brad: Yeah. Another good point. Wait, wait, Cynthia, strike all that. Michael, he’s getting way too many compliments throughout this one, but your point, I don’t know if it’s good or not, is if a medical board finds out that you’re non-compliant in one state, it’s going to lead to investigations in another state. Absolutely. Which is really going to open up that whole Pandora box of issues as the supervising physician. Now Michael, I know that we have talked about this in other shows, but for some reason, again, for some reason I can’t figure it out. There are a lot of people keep pushing back on us and saying, really, look, if someone’s a cash paying patient and it’s elective, do we really have to go through the whole medical clearance of a patient, sometimes called the initial medical consultation or the initial good faith exam. I mean, do we really have to do that?
Michael: Yes, if it’s the practice of medicine, Brad. And here’s the trick. So you [00:26:00] hear the cash-base, so this is just retail. so you don’t need to do it. And you mention that the other is just the perception that it’s not medical. So classic thing that we hear about all the time is IV hydration. And they think, well, it’s just an IV, nurses can do, it happens all the time. You know, this is crazy. I bet there is a bunch of attorneys out there that are not health care attorneys that would echo that sentiment. But the key comes down to this; it’s a core function, core principle of compliance. If the treatment is the practice of medicine, then that practice of medicine, you have to be cleared. The doctor or someone with the scope of practice has to evaluate the patient, look at their history, examine the patient, and determine that the treatment is appropriate. We use the term good faith exam. That’s actually the term in California, and it’s just kind of a term of art in most other states. [00:27:00] But the principle is the same, which is you have to have a treatment plan that’s issued by someone that has the ability to exercise independent judgment. Now, kind of a sister concept that you hear about is standing orders. And that’s tricky because you’ll see that in the hospital system all the time. The idea of with standing orders is, well, here I’m the doctor, I’m going to sign off just this blanket statement or order that you can go and issue IVs to whoever as needed, and that somehow satisfies. And in the context of what we’re talking about, which is a private practice scenario, it doesn’t work. There are some benefits if used correctly to written protocols or SOPs or even standing orders that serve that function. But if you’re trying to get around the need for a good faith exam, it doesn’t work.
Brad: Yeah. And audience members, [00:28:00] I think Michael said this, and I want to make sure you’re catching on this; the term good faith exam really is coming from the state of California, but it’s other states kind of talk about it. So someone might say, well, in my state we don’t have anything called the good faith exam. It’s not. I mean, that’s just a term of art we’re using, right? It’s really making sure that that person is a good candidate for those particular services.
Michael: Well, let’s jump back in. Tell me what happened next in the story.
Brad: Sure. So we had several calls with Mr. Mike, Dr. Tiger and Mrs. Golden trying to work through these compliance issues. Each time we thought we made some progress where Mr. Mike agreed to make certain changes to the process, we’d later learned that nothing was happening, and basically it was a lot of empty promises.
Michael: Okay, well, so what did Dr. Tiger do, Brad?
Brad: Dr. Tiger had successful ENT practices. He had other medical and non-medical businesses that he had ownership in besides [00:29:00] the Purple and Gold Med Spa. As such, he really just said, “I’m going to terminate this agreement with you guys because you’re not concerned about the medical piece. You’re moving way too fast and way too loose the way Mr. Mike really had this vision for the Purple and Gold Med Spa.”
Michael: Well, do you know what ended up happening to the Purple and Gold Med Spa?
Brad: I did later learn that after Dr. Tiger had left the Purple and Gold Med Spa, there were several locations where they started receiving notices, one from the state of Alabama for the improper supervision and the lack of that medical consultation or good faith exam. The good news was that these patients were not treated while Dr. Tiger was the Chief Medical Officer. The bad news for Mr. Mike was a lot of these local supervising physicians who either were not part of that rollup or just had heard about it, they started obviously getting very nervous, and they said, I’m out. And they all started terminating their relationship. And I did [00:30:00] hear through Dr. Tiger that Mr. Mike had to close a lot of those stores because they weren’t doing things properly. Michael, final thoughts?
Michael: Well, scaling is hard. And I can have a little bit of empathy for Mr. Mike. If you think about, I mean, even Chick-fil-A or Raising Canes, I’m sure they had growing pains at some point. And we all think of them as iconic, successful scaled businesses. And the problem is, is that in health care there’s compliance. And so for a non-doctor like Mr. Mike, I can understand he probably had a million headaches he was trying to solve and trying to grow his business and just couldn’t wrap his brain around adding compliance as an element. And what we saw, how that turned out, it’s just so important to understand when you are in a business that’s practicing medicine, compliances, you [00:31:00] can’t lose sight of that foundational concern or it’ll cost your business.
Brad: Yeah. Awesome. Well, Michael, next Wednesday we have a real treat for our audience. We are going to have a live podcast with a former CIA analyst, David McCloskey. And we’re going to discuss improving ways of how to communicate and give you some skills how to make decisions both either the work or in the home life. Thanks again for joining us today. And remember, if you like this episode, please subscribe, make sure to give us a five star rating and share with your friends.
Michael: You can also sign up for the ByrdAdatto newsletter by going to our website at byrdadatto.com.
Outro: ByrdAdatto is providing this podcast as a public service. This podcast is for educational purposes only. This podcast does not constitute legal advice, nor does it establish an attorney-client relationship. Reference to any specific product or entity does not constitute an endorsement or recommendation by ByrdAdatto. The views expressed by guests are their own, and their [00:32:00] appearance on the program does not imply an endorsement of them or any entity they represent. Please consult with an attorney on your legal issues.
