NDIS fraud and dodgy providers – Reasonable & Necessary podcast with Dr George

Hi and welcome to Reasonable Necessary, a steadiest premier pop-car series on everything you've wanted to know that the national disability insurance can. North to you by the summer foundation. I am your host, Dr. Dr. Dr. Dr. Forest, and today we're talking about how you can protect your plan from fraud and drugs providers. I'm designed by the Security Lawyer, Peter Grangery, as well as singer staff from the National Disability Insurance Agency and from the end of the year, Tony and safeguarding commercial. Check it out. I'm person now. Welcome to the show. Thank you. Thank you for having us. That's about my living, who you are and what you're living alone. Thanks George. My name's Matt Barron, the Director, Compliance and NDIS Worker Screening at the NDIS Quality and Safeguard's Commission. So my role involves supporting compliance, policy and strategy across the full range of the commission's functions, including as they relate to fraud and other practices that may be non-compliant with obligations under the Act. Hello. Hello. Hello. Yeah, thanks George. My name is Bruce Grayden. I'm the Acting Director of the New Fraud Fusion Task Force and the Investigations within the NDIS. So that means we've got investigative capability across Australia and I currently manage that capacity. Wow, but great line-up throughout zeroes today. Now, before we go in the further, let's take a listen to an earlier conversation that I had with Peter Gregory. Just to get a few of us, some of the dodgy providers I have here that see he out talking about earlier than we. Hope you don't. Welcome to the show. Hey, George. Hey, Gunn. Grunt's a house there. Can you tell us some of the most common and concerning practices that is encountered? Yeah. So when people are talking about supports coordinators, for example, they're talking about those practices where the support coordinator makes charges, but they're unable to get a clear understanding of what the support coordinator actually did. Or practices where it appears as though the support coordinator is making regular charges without any evidence that they've actually done, any work. And as you know, the beauty about the support coordination role is that they're there to assist you to identify suitable providers, to help you connect, to help you negotiate the service agreements, and where people are reporting challenges. It's in the area of charges being made without that work being done, without those connections being made. And these are some concerns around how our health practitioners and the assistance is well, but yeah. Yeah. So one of the big areas, I think, for people is that they report engaging, how I'd health practitioners, to prepare a report, particularly for a plan review, or to enable them to implement some more sophisticated support strategies, and that the allied health practitioner will either not produce the report, or produce a report that is inadequate to their needs, and then say in order to adjust or modify, that report will need additional payment. So it's a situation where people feel compelled to keep on paying out money for more and more information. When at the outset they'd already said, "I need a report for this purpose," and we're agreeing on an amount of money to do that. A lot of us do that, and we still. Well, I think we've seen a real escalation in some dodgy practices around SDA. I think we've seen a real escalation in providers who've got no experience in specialist disability accommodation, coming in, building group homes on spec, and then entering into arrangements with some civil providers, supported independent living providers, to fill the vacancies. When you're building group homes on spec with the objective to filling vacancies, inevitably you're going to lead to people being placed into forced co-tenancies. We know historically that means that when people are in forced co-tenancies, that will inevitably move towards abuse, neglect, domestic violence. It's just the equation. I think those sorts of practices are really questionable. The other associated practice that's questionable is where the SDA provider is the landlord, but they have another arm of the company that's also the service provider. Or if it's not SDA, the landlord is the service provider. If you enter into conflict with the service provider, you can be evicted. Those practices where you don't have a separation between landlord and provider really expose people to significant risk. Long case, what do the reflections on what Peter had to say? That was the wrap. Thanks, George. Thank you, Peter, for raising some really important issues. A couple of matters came directly to mind in the examples that Peter raised. The first one was really around the importance of participants, understanding and exercising their rights as consumers, as well as NDIS participants. What I mean in terms of as consumers, everybody has the rights under consumer guarantees, under Australian consumer law, including that products are of quality and that services fit the stated purpose. It's really important that participants are aware of and exercise those rights, just as they would in engaging or purchasing any other product or service for any other purpose. The other part of that is rights as NDIS participants, so under the NDIS Code of Conduct and other obligations that the Commission regulates, participants have the right to engage supports and services that are delivered in a quality, in a safe manner with care and skill and for which support them in meeting their needs and goals under their NDIS plan. The other examples also raised for me the importance of round service agreements and ensuring that participants have service agreements in place with the providers that engage and service agreements that meet the needs and goals of participants. So it's important that in having discussions with prospective providers, participants are putting that forward in how those service agreements are designed and then executed. It's important in those agreements that they cover the supports that will be provided, what they will cost so that participants can make decisions around whether they are affordable and aligned with their NDIS plan, what you and the provider are responsible for. Peter raised the example of behaviour support plans. If you're engaging a service agreement for the development of a behaviour support plan, you might look to include matters in that agreement, ensuring that that plan meets your needs and goals, is informed by evidence, informed practice and meets the requirements of state of consent requirements and authorisation requirements of the relevant states and territories and requirements of the commission in relation to those plans. Including service agreements encourage you to ensure that the agreement states how long that plan goes for, how it may be ended or ceased and how you you might do with any disagreement under that service agreement. The examples also raised me the importance of providers ensuring that participants are aware of how they manage conflicts of interest, particularly in that scenario where a single provider is delivering specialist disability accommodation and supported independent living. It's important that providers are complying with their obligations in respect of that particular scenario and ensuring that participants do not experience any adverse consequence relating to a decision about what services they engage within that particular accommodation setting. I often say that people like the service agreement is the most important thing they need to have because even though they're a hassle, they're really helpful because you can't go say things. I did service agreements that say we need to see your plan, we need to have everything 24 hours. I'm like hang on, no, no, no, no, no. I let them eat all of those things and if you want a business, let's look at this agreement together because ultimately it's something that my plan funding, I should go to the side that turns as well, it's not also the provider. Do you want to say something? Well, you were taking the words out of my mouth a little bit there, George, because when the investigator in me, there's a couple of things in Peter's examples that are a little bit of a fire. And they're around the fact that we all have to be vigilant. So my take away from Peter's comments was, I'd really encourage participants to be two things. So I'm going to have a little bit of a conversation with their plan and really brave. And what I mean by that is you almost have to have a plan about your plan when you go into this. So you know, choose your provider wisely. Peter spoke about being sure that because providers are a little bit, their business is to provide services to participants. But they're in a competitive market, right? They will all, like a salesman, tell you why their service is best for you and there's nothing wrong with that. But the owner's, I guess, is on our participants to be a bit vigilant and do some background checks. See, George, when you were talking before, it's obvious that you've got no problem having difficult conversations. Others find that difficult. So I think going back to having a plan about your plan, I think it's important for our participants to encourage them to have an honest conversation with themselves about, are they the type of people that need somebody else in their life to turn to as a trusted ally to go to when they need to have a difficult conversation with a provider. And then this, what Peter talked about was kind of what I called "God's News". Yeah, so it's like, you know, all of them. I asked for this and I thought something that doesn't feel like it's good value and in fact, I'm feeling a bit real tough, right? Now, we've rather than answered that, I think we called that "Sharp Practices" in the sense that it's not "God", right? Because there's a difference between doing something to the dawns and being "God's News". Is that right? Yeah, look, if I could jump in there, Matt, I think. Oh, there's an argument that "Sharp Practices" for, but I'll tell you the difference. There's a difference is. And the moment we say it, because I'm putting it out there, and I'd like to know. Well, from an investigative point of view, a fraud is committed when someone forms the intent that they're going to do the wrong thing, right? When, if they are sloppy in their business practices, that might come under "Sharp Practices". But if they form an intent that they are going to charge more than what they should be getting, that's fraud. Now, intent is really difficult to prove because it's a state of mind. And therefore, can only be proved through a proven set of facts. And we might gather those facts by talking to witnesses and taking statements and having participants, a range of participants telling us that, "Well, we got charged for four hours of house and yard maintenance, but we only ever got an hour." Or, "I got charged for house and yard maintenance, but I live in a unit complex, so I don't have a yard." So, that's how we might gather the evidence to prove "Sharp Practice". When it's low level, we might treat that initially with a shot across their bare-cutter area because this is, you know, this will not be tolerated. But as often happens, it can turn into something greater. And again, this goes back to what I was saying earlier. We need our participants to have those difficult conversations to stop providers, to pull them up, right? So, that's why we have to be brave. But the problem is, like, I read that in the ad data for the services to the relevant dollars, correct payments, is that? That's a lot of money. It's an awful lot of money. And there's a lot happening in that space right now, and I'm sure we'll get to that to combat that. The other point that I'd make, George, is just to keep this in context. You know, I reckon you can categorize the people that are in the industry. There's three different categories. You've got honest people, honest providers, honest participants with no intent to do anything wrong. And that is the vast majority of people in the industry. And then right down the other end of the scale, you've got organised criminal entities that enter the scheme with one intent, and that's to rip it off. Now, they're at the tiny minority, the tiny minority, but they do a lot of damage. And then talking about sharp practice, we've got this group in the middle, if you like, who may start out doing everything perfectly. And then for reasons that we don't see, they start to slide. They might be experiencing some financial difficulties with their business. And they think they see it as a short-term solution. For whatever reason, they start charging for four hours when they should be charging for two, and it gets away in them. But yeah, it's a lot of money, George. That's a sure. I'd like to talk about that. This was people claiming hours that weren't provided at the time. One of the really simple solutions is my head is that we need to make sure that participants are fine off on invoices. It can save me that people who are agency-ready can essentially have that, well, a significant amount of their funding are rated, because they can't, they don't have to lose a claimant. Isn't that a separate issue that could be relative to the declared draft? Yes, and yes. So it is an issue, and it's an issue that we're addressing through the introduction of a new program. This new paste system is going to address just that. So whilst it hasn't been introduced yet, I think I've got to feel that the trial is starting to either has just started at starting very soon. Excellent. I'm not going to talk about it. Longer over the end. And the reason why the government announced this task force is that you're the acting director of the service. And tell us a little bit more about that. Well, I think there's been a recognition from the government that we've got to do something. And I like to what Dylan Alcott said the other day that the people that are committing fraud against this scheme are literally taking away from a new, a diverse kid from getting care or from someone with a high-level disability, having a shower. It's as simple as that. So those people that are committing fraud on the scheme, there are real people, real victims behind that. And that doesn't even factor in the families of those victims. And we see this. We see family break down. We have, I can think of, incidentally. instances of parents in tears because they thought that they had mismanaged their child's plan and they went away that they were a victim of fraud. So I think that's a real, as I said, historically, I think it's a bit dry. Everyone thinks, "It's just a fraud against the taxpayer." No, not this. These are real people at real risk. So the government has quite rightly committed quite a lot of money. What happens if you're a victim of fraud in this case? I'm thinking that people get their funding around stated. Yep. Well, what does the agency do to support people through that? It's very difficult. I have a fund in it. It's horrendously difficult. But we've got, or the agency's got dedicated staff that are focused on the participants' plans and wherever necessary, we reinstate the funds into those plans. So we won't let people go without services. It's super important. That's why this game exists. Right? So in those circumstances where we've identified fraud, we will top those plans up to make sure people get the services that they need. I don't think we've realized today suddenly we find that they're on the portal and the funding is not there. That's the provider discipline that they have. How does some of these cases end up identified? Well, you'd be surprised. George, how often we will go knocking on the door because we're investigating something and participant doesn't know that they've been defrauded. But sometimes there's lots of instances where participants go to organise an activity and there's no money in their plan. And again, this is all about being vigilant. This is why I'd love to see us change the mindset of the way we view our plans. The analogy I use sometimes is I'd like participants to think about their plan. This is called a hundred thousand. I'd like them to think about that money being in cash, sitting at their front door, behind their closed front door. Now I can't think of a human being, a human on the planet that would not keep a close eye on a hundred thousand in cash. And yet essentially that's what participants sometimes, I'm speaking generally, we're not vigilant enough for it. Now the money is there, it's behind a locked door, but that doesn't stop bad people from trying to get to it. And I'd like our participants to start thinking about their plans like that. They've got to keep an eye on it. They've got to be vigilant. They've got to speak up. So. Absolutely. That commission is up there in some quality and safety and to reiterate the industries. And people obviously who are receiving services that are similar to what Peter talked about, that ain't followed. That's not very different. What do you do? What powers do you have? Get things, get things right for people. George, as the regulator in the sector, we have a broad range of compliance and enforcement actions that are available to the commission to not only penalize address correct noncompliance, but also influence a broader uplift in quality and safeguarding across the end of the IAS market. We do receive a lot of complaints around dodgy practices, sharp practice, which goes to unethical conduct, mistreatment of participants and their plans, conduct like coercion to engage particular services, as well as not acknowledging the privacy of participants in sharing information about them with other providers and not acknowledging their authority around how funds under their plans are spent, which is obviously of concern to the commission and obviously to the NDIA. So where we do identify that practice, if a participant does make a complaint to the commission, the commission will talk to them around the issues to understand what those issues are. The commission will ask for consent and discuss options around resolution of their complaint, which may also include with participants consent, engage with the agency around matters of misuse of participant funds and/or fraud against the scheme in their plans. It will also tell participants what we did about their complaint, the action that we took and the outcome from that action. That action may include, as I mentioned, that broad range of compliance enforcement tools available to us. And that goes from education in building the capability and understanding of providers in terms of their obligations across particularly the NDIA's code of conduct, which applies to all NDIA's providers regardless of whether they're registered or unregistered through to issuing warning letters, requesting that corrective action be taken to address that non-compliance. We then have tools available to require correction of conduct, including what are called compliance notices, which attract a penalty if a provider fails to comply with that compliance notice. We have the ability to enter into enforceable undertakings with providers and individuals to address non-compliance identified. And then we have the ability to seek penalties, so whether that's through an infringement notice that the commission can issue, which attracts a monetary penalty of just over 13,000 for a body corporate, through to seeking civil penalties from a court, which can range up over the $200,000 mark in terms of maximum penalty. We also then have the ability to restrict or prohibit providers and individuals from engaging and specific activities or being involved in the provision of supports or services. Unful stop to people with disability. And that's through the making of banning orders and then decisions on the registration of providers, such as suspension and revocation of their registration. In terms of suspension and revocation, the effect of those decisions is that those providers can no longer deliver services as a registered provider, meaning they are unable to provide supports and services to participants who are managed by the NDIA, as well as deliver certain supports and services for which registration is mandatory. And that includes specialist disability accommodation, behaviour support, and any class of support that involves the use of regulated restrictive practices. So we have quite a broad range of actions which are administrative, as well as court determined decisions, which all go to addressing mitigating risk for participants out of the conduct that we're identifying. Rent the out, I'll be registering for providers who are behaving this way. So through the registration process, there's obviously a number of assessments that are undertaken, one of which is assessment against the practice standards that apply, dependent on the classes of support that a provider seek to be registered for. And in addition, a suitability assessment in terms of the provider and their key personnel, which includes a range of considerations such as whether a key personnel has been found, had adverse findings made against them, either within the context of the NDIS or elsewhere. And those activities are really important to identifying providers of concern for which we may make a decision to refuse a registration. And in the first quarter of this financial year, we've already refused 161 providers registration for a variety of reasons, including on suitability grounds. But there's a bit of some of those, I mean that's weird, that you're doing that. I'm just wondering, do you think that some of these providers are now operating as unregistered providers? Do you know? Is there a way of tracking them down? Because clearly that's, we don't want that right. We want them out of the system entirely. Yeah, yeah. So in terms of unregistered providers, what I would encourage participants to do, particularly participants who are self-managing, that they can ask their provider and their workers that they engage to be screened. And that's in terms of NDIS workers screening. That means that those people have undergone a screening process to assess whether, based on information available, including criminal history records, whether they present an unacceptable risk to the safety and wellbeing of people with disability. So that's a really important safeguard. Absolutely, really important. Yeah, and also, I always think of random people, often think of NDIS workers screening as the support record that I know that I'm, you know, as a member of a board of a disability provider, I have to be screened as well. So listen up, the free, free worker screen. Yeah. Yeah, that's, that's right. So participants, there's information on our website that participants can access around how they can verify the clearance status of workers who they engage and they can access the worker screening database to undertake their verification. For agency managed participants, all registered NDIS providers must ensure that all workers in particular roles, called risk assessed roles, which includes board members and those in control or ownership of entities, have an NDIS worker screening clearance. If any participants have concerns over the providers they engage in terms of their compliance with those obligations, they can make a complaint to the NDIS commission and will assess that accordingly. Because the commission and the NDIA work closely together. As I said earlier, a lot of our matters are pretty complex and they include a lot of them. I think we call phoenixing. That means organisations run by criminal entities who have a number of shelf companies, if you like, just set up ready to go, lying dormant and when we or the commission take action against the original business, that is shut the doors and walk away and they take all the participants that phoenix and they have into a new organisation and the offending continues. So the commission and the NDIA work very closely together to try to keep in front of that and that is what I think is important about what is now is the new fraud fusion task force. The fact that we are going to be dealing with 15 different agencies essentially with a common purpose, I think that is really exciting. Bruce, just to pick up on those points, an example where the commission and the agency will work collectively around this is where fraud is identified. We will look at the people involved, linkages to other NDIS providers. We will look at the business model and practices and identify where that practice may be replicated elsewhere. We will conduct proactive investigation and compliance monitoring activity to further mitigate risk particularly around phoenix activity reestablishment of entities as well as identifying where participant details may be shared without their consent authorization for the purposes of continuing that fraud against their plans and the scheme. The commission can take a range of preventative action so I mentioned before banning orders which can prohibit or restrict a person or an entity from engaging in particular activity. We do have the ability to make banning orders and circumstances where a person hasn't engaged in the scheme as a preventative measure to mitigate the risk of non-compliance by that individual in the NDIS market and that is a tool that we are using in accordance with in addition to our registration. Leaverset we can also use to mitigate future risk of fraud and other sharp practices. Now I think there are probably some people who are listening or watching in that. They are thinking, "Oh, this doesn't do a lot in terms of something that they're experiencing with the provider. They want to do something about it. They're afraid." Because I think it's quite scary to make a complaint about a service when you look at the service and then let service, let service, no reason to leave. What would this say to those people or are there those concerns? In terms of, as I mentioned earlier, as I mentioned, raising a complaint with the commission, I understand it can be a really difficult step to take in making a complaint to the commission. Your details will be confidential as you provide that consent to the commission, to share the details of your complaint with another party. Raising that complaint with the commission or providing that information to the NDIS fraud reporting contact line as well as email is really important because it may assist the commission and the agency in identifying a course of concerning conduct for which we may address proactively out of assessment of that information. You can also have conversations and encourage participants to have conversations if they're plan managed with their plan managers to get an understanding from plan managers around what they are doing to ensure that your funds are being spent the way that you want them to be spent. But in addition to what we mentioned earlier around keeping records and being, for example, the word "vigilant" around your plan, is really important to informing any discussion you might have with the commission, with the agency, or if you're having a conversation with your provider, with your provider to ensure that you're a, you can evidence and document the services that you have received, what you should have received, and those claims that you're concerned about in terms of whether services were provided appropriately. How was the rate for the provider about that you had to come after me? This has happened sadly, this has happened, but George, I really want to point out this is very, very rare. But in circumstances where it does happen, we engage the local law enforcement, we'll do whatever we need to do to make sure that a participant is safe. It goes back, George, to what I spoke about originally about being brave. We need participants to speak up, and we need them, but they need to do that in the knowledge that we will protect them wherever we can, and by that I mean that if they were to be harassed or in any danger whatsoever, they can report that to either us or to the local police. If it comes to us, to be honest with you, we will put measures in place to ensure that a participant is safe. Now, if it's okay, George, I want to talk about reporting things into the agency, into the NDAA, because I think it's an area that we can do better to be honest with you. I don't want to comment too broadly because I know there's a lot of work happening in this space, and perhaps that's already been put in place, but historically people would report things to the fraud reporting hotline. At some point at a later date, our investigators will go and meet with them, or go and make contact with them, and they are often shocked to hear from us, because once they've reported it, there's just a vacuum. Now, that's a bit there that we need to be better. We need to improve that. But it's a really difficult balance, George, because from an investigative point of view, it's really important that we don't telegraph our punch and let a fraudulent provider know that we're looking into their practices because as you can imagine if we said to if we got if we took receipt of a complaint and we got on the phone and said thanks a lot for this I've got a team of investigators that are looking into it you can expect some action soon that's really juicy information and it'd be hard for most people to keep a lid on that and the risk here is if if the wrong people find out that we're coming a lot of bad things can happen like the destruction of evidence so it means that we don't get what we need to convict someone and like the threats and intimidation of witnesses or participants so but I respect there needs to be a balance of what we're doing on but if there's any participants out there thinking I will I reported something and I haven't heard anything please don't assume that nothing's happening because that's not the case that's amazing for that now I do ask Peter for some of his suggestions around what to do to a sensor avoid having to do with those and who's the person who helped us out. This question of entering into agreements with providers comes up a lot and I like to think about the process of evaluating the providers as something like a due diligence so the first thing that we would normally do is go online and have a look at their website and you can get an impression of the sophistication of this provider by the website for example if they have a website that is chock full of stock photographs and they haven't even taken off the the watermarks you have to say to yourself if they can't even get the the presentation of their organization right online then how sophisticated are they going to be in meeting my needs that's one the other is how do you contact this provider if they've got a mobile number and that's the only contact point I say well that looks as well like a provider who doesn't have a significant resource base behind them so are they the sort of provider who has the sophistication that I need on that website are they saying who are the key people associated with this organization seems to me that if a provider is unwilling to identify who the key people in the organization are then you have to be questioning whether they have something to hide if you I like to check out the address of that provider and then use Google Earth or Google Maps to try and find out where they are and some of my personal favourites are providers who have addresses that looks like a warehouse in some industrial complex somewhere or or another personal favorite is the suburban house in a really richy neighborhood and it's really really huge with no real indication that this is a bona fide entity so all the you know these people may be legitimate but what I'm saying is that as you begin to unpack these superficial questions you begin to be asking questions about the level of sophistication I like to do an avn check to see what's the history of this organization how many business names have preceded the one that they're using now and who are the proprietors of that business and whether those proprietors have any demonstrated experience in the disability area or want to buy again personal favourites is have they have us have they had associations with government funding activities where there's been dodgy practice in the past like association with child care is has been has been historically one of those areas where people have got into to make a lot of money and have they chopped and changed around from one business activity to another that's not really related to disability but it looks as though this has been opportunistic and also within my networks I'll be asking privately have you come across this individual have you come across this business what history can we put together about this business so those sorts of things give us a bit of an indication of whether or not we're dealing with somebody who has some history and some confidence to deliver the services that they say they're going to deliver I think the the other one that's really nefarious is those providers who adopt names that imply they are either the equivalent of a government agency or some extension of the NDIA and doing that by the way in which they structure their name why in which they use the NDIA's colors the branding and that sort of stuff to to create the illusion that they are in some way an extension of a government activity or the agency if you've then decided that you're going to go ahead and interview this provider then be very clear about what you're going to ask them to provide don't enter into long-term service agreements until you are clear that you want to go with that provider and get them to explain to you how they are going to deliver on a service that's based around what you want not what they want to deliver this is really important many providers come and say this is a service we provide and the conversation has to shift to what will the provider do for you to provide the service that you want and then once you've done all of that make it clear that you're happy to enter into a short-term agreement until we work out whether this is the right fit and of course one of the really big indicators that this is not going to work is if the provider turns up to that interview with a service agreement already prepared so that's really the case of buyer everywhere do your research talk to other people who may or may not have heard of the service or the provider and I really feel so clear that coming on the soul and the talented people that you're experiencing because hopefully that will help lock his ought to make sure that they do what has to be done just so safe and in that finding a trusted and reliable and those provider that's really helpful as well guys yeah any additional tips for your eyes just a couple from me participants may choose to engage a registered NDIS provider which may provide a level of greater assurance because those providers have been assessed against the applicable standards and undergone those suitability assessments that I spoke about earlier and registered providers are also subject to ongoing oversight through quality audit processes the the other activity that that participants may do is around as I mentioned before having a look at the commission's compliance and enforcement register and these are published on our website which identifies compliance action the commission's taken against individuals and providers including some information around the nature of that that conduct and that is really useful information to informing participants about whether or not to engage that provider. Yeah from my point of view participants really should make an effort to be really vigilant because we can't be the solar as an ease of all things for what we need. We need to adopt the ethos that we're all in this together. Oh, independently, and this is why I wanted to do this. Top-class business. And yeah, we, as participants, we're very conscious of the importance of, of, keeping a mind of what's going on and making sure that that money goes where it should be. That's very, that's that. I know that people can confidently come to individual organisations. We're going to have fun on this and contact those valves available on the description below. And I'm really concerned at the time and for sharing the toilet work that you do those factors so much for joining us. Thanks George, it's been a pleasure. Thank you George, thank you Bruce. Great to be part of this fantastic conversation. Thank you. That's all we have time for on today's episode of Resolent Necessary. Thank you to our partner for this episode, the National Visibility Insurance Identities. To be notified, answer to episodes, then forget to hit the subscribe button and the notification bell. Thanks for listening and until next time stay well and reasonable.