Nov
4

The Public Option in Workers Comp

Thanks to the good folks at Workers Comp Insider, I learned of an intriguing study conducted by Conning and Company that concludes (in part) that private work comp insurers don’t perform as well as public ones.
Here are a couple of excerpts from the article in Insurance Journal:
25 public and quasi-public workers’ compensation insurance plans perform better financially than the private market in a number of performance categories and at least as well when it comes to the bottom line.
– public workers’ compensation providers tend to have higher losses than the workers’ compensation insurance industry as a whole, they more than offset those losses with lower expenses, higher investment returns, bigger dividends to employers and better injury prevention efforts.
– through more stable reserves and superior investment income, state funds have managed to achieve operating income on a par with that of the workers’ compensation industry as a whole.
– Spurred by their mission that includes improving safety and their state’s economy, state funds blunt the impact of bigger losses through concerted loss prevention efforts. As Jablonowski put it, “They are able to convert the marginal and poor risk into something better.”
The public providers offer employers significantly higher dividends, which provide an incentive for businesses to adopt safety measures. These dividends can also create a competitive advantage and build customer loyalty, according to the study.
Congratulations to the good, hard-working, effective folks at SCIF in California, Texas Mutual, NYSIF in NY, the North Dakota state fund, Beacon Mutual in Rhode Island, and the rest of the state funds. While all is not perfect, and as Peter Rousmaniere has pointed out, often quite a distance from perfect, some of the findings of the Conning study are illuminating.
I’m also thinking the study should be carefully reviewed by Federal legislators, as the conclusions may help inform the discussion about the public option in health reform. I’d point to them to this quote:
“When you look at the entire insurance world, there are obviously insurance companies in the private world that do a great job of loss prevention control,”[the study’s author said] “But the unique thing about funds is that they all do it. Twenty-five of them and they all do it. So it’s not a random sample; it’s a sample that suggests that this group puts an emphasis on loss prevention control.”
That’s exactly, precisely what we need to do with health care – prevent preventable claims that lead to high costs and lousy outcomes.
What does this mean for you?
Once again, the health insurance world can certainly learn something from workers’ comp.


Nov
3

UPDATE – Ethics in workers comp managed care

For the update, see UPDATE below.
Also, if you would like a copy of Todd’s marketing presentation, email me at infoAThealthstrategyassocDOTcom. The presentation is not copyrighted, marked confidential or proprietary, or otherwise protected from distribution.
Original post
The world of work comp managed care is highly competitive, with vendors willing to push pretty hard to win business or hold on to customers. That’s the way the market is, and as long as these practices don’t cross the line, may the better competitor win.
But sometimes that line is crossed.
A work comp PBM took my copyrighted work and without my permission, used it in a marketing presentation. They also copied my Survey of Prescription Benefit Management in Workers’ Comp and distributed it without my permission.
Not only that, but the PBM mischaracterized the work in such a way that it appeared I endorsed their approach and business model, if not them specifically.
I’ve repeatedly asked the PBM to retract their statements and have yet to receive confirmation that they did so. Rather than continue to spend money on attorneys, I’ve decided to publicly disavow any connection between myself, my firm Health Strategy Associates, LLC, and the WC PBM consortium I work with, CompPharma, LLC, and the PBM in question – one WorkComp Rx, Inc, and WCRx’ President, Greg Todd. Todd is also affiliated with Integrated Prescription Solutions.
Here are a couple specifics.
The introductory slide in a WorkComp Rx marketing presentation (entitled HSA Comparitive (sic) Summary ) states the: “findings [of my firm’s Annual Survey of PBM in WC] support WCRx’s performance Is The Best-In-Class”. No, it most definitely did not.
Another slide showed WCRx’s inability to comprehend the survey. The slide reads “Typical PBM Pharmacy network size is 55-58,000 pharmacies of which “penetration rate” is approximately 65% which totals 38,000 participating pharmacies”, showing his firm didn’t understand the definition of ‘network penetration’, which is not how many pharmacies participate but what percentage of scripts are processed thru the retail network. This led to this wildly inaccurate conclusion:

WCRx’s pharmacy network includes 99.7% of all US pharmacies (64,000+) and a 100% “participation or penetration” rate. That is more than 30,000 additional pharmacies with 100% participation than any competitor.

Yet another slide stated that the Survey found that Third Party Bills “…amounted to 40% – 50% of all W/C pharmacy bills.” Nowhere in the Survey do those words appear.
There are plenty more examples of misinterpretations, fabrications, and distortions, but you get my drift. It could be that Todd et al just don’t understand the work comp business, as his company’s website reads in part:
“Workers’ compensation is mandatory medical insurance that is paid for by employers and is required by law in every state.”
There are two errors here – WC is not mandatory in every state (i.e. Texas) and is not ‘medical insurance’.
UPDATE – IPS changed its website yesterday; the new description of work comp reads as follows:
“Workers’ compensation is a form of insurance that provides compensation medical care [sic] for employees who are injured in the course of employment, in exchange for mandatory relinquishment of the employee’s right to sue his or her employer for the tort of negligence.”
end of UPDATE
It also states that work comp medical spend is broken up thusly:
Hospitals & Physicians: $18.4 billion
Physical Medicine: $8.8 billion
Pharmacy: $6.0 billion
Diagnostic Services: $3.2 billion
DME/Home Healthcare: $3.2 billion
Cost Containment (UR): $1.8 billion
Perhaps Todd et al made these data up themselves, or have a source I’ve never heard of, or used data from one state to extrapolate to the rest of the country (no source is cited); I don’t know where else they could come up with these statistics, certainly not from NCCI or WCRI or NASI or DoL BLS reports.
When I learned of the misuse of the Survey’s findings and unauthorized duplication of the Survey itself, I immediately contacted my attorney, who sent a firm but polite letter to the PBM’s president, Greg Todd, a man heretofore unknown to me. The letter asked Mr Todd to stop using my material, inform all those he or his employees or agents had shared my material with that this was unauthorized, and tell them that I had not and did not endorse his company or approach.
Mr Todd sent a letter back telling me that I was fortunate to have his company spreading the word about me and my firm. But before he sent that letter, he called me and asked if this was about CompPharma, the consortium of workers’ comp PBMs I work with and am a part owner of. I said no, it was not; he replied that he knew other CompPharma members were using my work, whereupon I told Todd if they were it was with my permission. He then offered to join CompPharma and inquired about the fee.
He could not seem to understand that this was not about a fee. This was about his company doing something it should not have done, misusing my work and using my reputation and credibility to help him sell his stuff.
A follow up letter to Mr Todd went unanswered. As it appears that Todd is not going to respond to my request that he retract his statements and stop using my materials, I have no choice but to get the message out myself.
I am not today, have never been, and will never be affiliated with, work with, endorse or recommend WorkComp Rx, Integrated Prescription Solutions, or any other firm associated with Greg Todd. Any use by Mr Todd or anyone at either of those firms of any work product of Health Strategy Associates, LLC, CompPharma, LLC, or myself is done without my knowledge or permission.


Nov
2

States can deliver low work comp premiums and high benefits

A few states deliver high levels of benefits to injured workers at low premium rates, and a few deliver low benefits at high premium rates. Peter Rousmaniere’s assessment of each state’s work comp system not only tells us which states fall into which categories, but provides insights into the ‘why’ as well.
For example, NJ NY and Montana have the highest work comp insurance costs, but very low benefits. And Massachusetts is at the opposite end of the spectrum, with low premiums and high wage replacement benefits for injured workers. (Mass doesn’t treat providers nearly as well, as the Mass fee schedule is among the lowest in the country, while medical costs are not)
Peter delves into the whys, and among his findings are:
five states deliver both low premiums and high wage replacement benefits (IA AZ VA NV MA)
– five states are the polar opposite, with high premiums and low benefits (AK CA NJ NY MT)

and then there’s the majority of states which fall in between costly/poor benefits and cheap insurance/good benefits.
Peter also notes that there is a wide disparity among states in median duration of disability, ranging from 4 days in the best states to 12 in NY.
While some states seem stuck in a dysfunctional morass, making little progress, California’s recent success in dramatically reducing premiums and costs should encourage all state legislators to get cracking. Reform can be done, even in a state as large and diverse as California. Montana, which is tiny by comparison and much more homogeneous, should find reform a much less difficult task.
What does this mean for you?
Find out how your key states are ranked, and you may well find where you’ve got problems in your comp program.


Oct
30

Who’s the crook?

Few things I’ve encountered in my twenty-five-plus years in the insurance business are as outrageous as the prosecution of Sandy Blunt, the former head of the North Dakota work comp fund.
I’ve posted on this case several times; what originally caught my attention was the announcement that Bryan Klipfel, a former State Trooper had been named the head of the ND work comp fund.
According to a local paper in ND, when asked about his qualifications, Klipfel said “I’m going to work with Bruce (Furness) for a couple of weeks, and I’ll just have to learn some of that information as time goes on…My strong points are that I have leadership ability, and I understand human resources, how to deal with people. And I think that’s the big part (of the job) right now.”
That got me thinking – “He’s going to learn on the job? While getting mentoring for a ‘couple of weeks”? In a business that is incredibly complex? At a time when investments and reserving practices are critically important? And his qualifications are his understanding of human resources and leadership ability?” – with the result that I dug deep into the story, only to find out what can only be characterized as a witch hunt, conducted for unknown reasons by a prosecutor’s office that went way beyond what could be construed appropriate behavior.
The deeper I dug, the stinkier it got. Blunt was convicted of felony charges, which could only be brought because the prosecutor ‘rolled up’ several smaller charges related to gifts for workers (trinkets, food for parties, etc) and his authorization of sick leave. In fact there aren’t any charges that Blunt took money himself.
At the time, I thought ‘Ok, so Blunt made a few bad decisions and/or didn’t follow all the rules by the book. But a felony conviction for a sick leave authorization and some inexpensive ‘gifts’?’ Seemed wildly excessive – at any other big organization – public or private – this wouldn’t merit anything more than a reproachful email from the corporate compliance officer/legal counsel.
Turns out it was way more than ‘wildly excessive’; the Blunt conviction was the result of egregious prosecutorial misconduct.
The prosecutor didn’t give Blunt’s attorney exculpatory evidence – evidence that would have proven that the sick leave charge was insignificant – it wasn’t even a concern to state auditors who had gone thru the state fund’s books with a fine-toothed comb. More importantly, the prosecutor didn’t give the memo from the state auditor pertaining to this issue to Blunt’s attorney.
Anyone who’s watched even a little TV knows that prosecutors MUST give all evidence to the defense. Anyone except Cynthia Freland, the assistant state’s attorney who tried the case.

I have no idea what in the hell is going on up in North Dakota, but I do know this. Sandy Blunt is a decent, honest, very capable guy who has been absolutely screwed, apparently in no small part by a prosecutor who broke the law.

Blunt is currently appealing the case before the state supreme court, primarily on the basis of the prosecutor’s ‘roll-up’ of charges. His contention appears to be because one of the charges was thrown out, the jury should have been allowed to consider each of the other charges independently, which not coincidentally may well have resulted in acquittal as the remaining alleged offenses may not have met the standard for a felony conviction.
If there’s any justice in this country, Blunt will be acquitted and Freland fired and investigated for possible commission of a crime. Regardless, Blunt’s reputation will be forever tarnished with his professional life ruined due to some bizarre personal vendetta on the part of an at-least incompetent and possibly criminal state prosecutor.
Disclosure – I’ve come to know Sandy pretty well. I called him to hear his side of the story earlier this year. He is a very smart, humble, positive gentleman who is a consummate professional. Sandy and I have worked together on a couple projects, and I have been very impressed. Sandy’s performance at the ND Fund speaks for itself – and I can – and will – put my personal reputation on the line for him.
It’s a no-brainer.


Oct
30

Syracuse University – the new home of UCR

We now know who will replace Ingenix as the nation’s provider of usual, customary and reasonable (UCR) data; we also know when (by the end of 2010). As to the how, that’s a bit less certain.
Syracuse University will be the home of a non-profit data house’ to be called FAIR Health (Fair and Independent Research Health); Cornell, Upstate Medical Center, SUNY Buffalo, and the University of Rochester will also contribute (got to spread the largesse around). (full disclosure – Syracuse is my alma mater)
The new entity will be funded at least in part by the $100 million NY Attorney General Andrew Cuomo has gotten in settlements from Ingenix’ UCR database customers. In addition to Cuomo’s successes, Ingenix’ parent company, UnitedHealth Group paid $350 million earlier this year to settle a class action suit, and other legal action is continuing which Cuomo expects to add to the $100 million total. The cash will be used to develop the database and set up a mechanism to deliver data to payers and consumers via a website. This last is a great idea – providing health care consumers and providers with access to UCR data should help promote transparency and enable price comparisons by consumers and price competition by providers.
FAIR will be headed up by SU Professor Deborah Freund, an expert in health economics, Distinguished Professor of public administration and economics in SU’s Maxwell School and Senior Research Associate at Maxwell’s Center for Policy Research. Dr Freund has a wealth of experience on the academic side of health policy and economics and has published on a wide range of topics in those fields.
I’ll see if I can stop in for a chat when I’m back up on the Hill in January for another alumni meeting.
The timetable seems…aggressive – there’s a lot to do to avoid some of the problems that plagued Ingenix’ MDR and PHCS databases; non-existent quality control on source data and inadequate volume of data in some areas are just two of the problems that led to the settlements. While Freund et al at FAIR may want very much to provide comprehensive, clean data that covers all procedures delivered by all providers, they don’t control the quality, accuracy, and consistency of the data collected by health insurance companies and other payers. And after the Ingenix debacle, they sure want to be absolutely positively comfortable with their data before they release it to the public.
My guess is the website and initial data will be up and running by the end of next year, but it won’t be comprehensive. Even if FAIR is able to come up with standards and a rigorous QA process, it will take more time for payers to develop and implement processes to ensure the data they provide FAIR meets those standards.
And you can bet your last hundred million that no payer is going to send data they aren’t absolutely sure is up to snuff.
What does this mean for you?
Good news, as the new UCR provider will help reduce payers’ exposure.
Health plans have a new vendor to work with – on the vendor’s terms.
Over the longer term, there’s another ‘outcome’ – Health data quality is about to go under the microscope, and the view may be pretty ugly. Healthplans and other payers may well have to upgrade their technology, training, and staffing to meet FAIR’s demands
Background
For those who don’t follow these things on a daily basis (hard to believe I know), some background. Years ago, the health insurance industry’s lobbying and service arm (HIAA) aggregated and compiled physician charge data as a service to its members. HIAA collected the data and fed it back to members, who then used the data to determine how much they should pay providers in specific areas for specific services (services defined by CPT codes). HIAA was taken over/disappeared about a decade ago, and Ingenix took over the aggregation and distribution of the data, which has become known as “UCR” for “Usual, Customary, and Reasonable”.
For about ten years, all was fine, at least as far as most insurers were concerned. Sure, physicians complained at times and consumers railed about the low reimbursement paid by companies citing their UCR, but the complaints didn’t really make any difference until Cuomo got involved. The problem arose when a few folks in New York complained about the amount they still owed providers after their insurers had paid their portion – according to Ingenix’ UCR. After a lengthy investigation, Cuomo found reason to charge UHC and other insurers, and that action ultimately resulted in this settlement.


Oct
29

It feels like the party’s just about over

It’s been a wild party in the comp world – and a long one too. A brutal hangover may well be next for work comp payers.
Those who remember the late nineties are getting increasingly nervous, as well we should. The longest soft market in my memory is still around, doggedly refusing to firm up – as it should have, long ago. Work comp premium rates continue to decline, especially in key states such as California (down by a whopping two-thirds in five years) and Florida (an equal drop over six years). Most other states have also seen precipitous declines, driven by successful reforms and a decline in frequency.
Yet medical severity – the comp industry’s somewhat-misleading term referring to medical cost – continues to increase in most jurisdictions.
Pause and think about that. Workers comp insurance costs have dropped by two-thirds over five years. Two-thirds. How is that possible? Does that make sense? Is there any way that’s sustainable? Don’t cite statistics and financials and actuarial reports – tell me what your gut tells you.
Mine’s really queasy.
Back in the late nineties, most comp payers thought medical inflation was tamed, as their view in the rear-view mirror indicated medical trend was in the seven to eight percent range. Not so fast, the gods of workers comp proclaimed. Inflation roared in the ensuing years, crushing many payers’ financial returns and bankrupting more than a few carriers in the process.
While NCCI reports medical inflation is under control, that’s not what I’m seeing. Facility costs are trending up, driven by declining ‘savings’ from broad, generalist PPOs. Prescription drug costs are on the increase after four years of declining trend. Ancillary costs are also heading higher, especially for those payers yet to fully embrace specialty managed care programs – and regardless of what you may think, that’s most of the payers in the industry.
Today’s WorkCompCentral reports [subscription required] Liberty Mutual, the nation’s largest writer of work comp with premium of $5.4 billion in 2008, is backing out of California and very nervous about Florida. I have reason to believe the big carrier is not leaving California, but the points made in the article regarding market conditions are spot on. Employers Direct already pulled out of the Golden State, and if it weren’t for new entrants to both Florida and California competing hard for share, the market in both states may well have firmed up by now.
Yet new carriers are entering these markets – which may be either a horrible idea or a pretty smart move. Unburdened by an existing book of comp claims incurred by writing policies that I believe are increasingly underpriced, the smart ones (if there are any) may be able to prosper as the carriers who showed up early for the party are heading towards the floor.
A more likely scenario is these johnny-come-latelies will party hard to catch up, consuming large quantities of business on an empty stomach. Kind of like freshmen at their first college party, with equally unattractive results.
Is it possible that there will be a ‘soft landing’. It is, but it is much, much more likely most carriers will feel like they fell out of a moving cab onto cold, wet, and very hard pavement…
hangover-passed-out-in-the-street1.jpg


Oct
27

How horrible is Medicare?

Depends on who you ask. If you ask group practice administrators about how Medicare compares to the private insurance industry, it is pretty darn good – in several categories, Medicare Part B is rated higher than any other large payer.
That’s partly due to the lousy performance of some of the private insurers, but administrators actually rate Medicare’s responsiveness, transparency, prompt payment, and overall administrative functions highly.
Yes, you read that correctly.
On a five-point scale, with 5 the highest rating, the much-maligned and oft-decried public plan for the aged has an overall satisfaction rating of 3.6, with Aetna at 3.1 and UnitedHealthcare bringing up the rear at 2.5.
Medicare was considered the most timely responder to inquiries, with Aetna second and UHC at the back of the pack; the same standings hold for accuracy and consistency of the payer’s responses to questions, speed of payment (Medicare 4.1, Aetna 3.5, UHC 3.1), disclosure of payment policies, and claims appeal process (Aetna was excluded from the report).
Medicare doesn’t appear on the list of questions regarding satisfaction with the contracting process, except in the ‘willingness to disclose the fee schedule’ category, where it is again rated at the top. This isn’t surprising, as CMS is not engaged in ‘2-way good-faith negotiations’ nor do practices have ‘leverage during the negotiation process’. I don’t know if responders didn’t ask about Medicare or if Medicare was ranked at all; I’ll let you know when I hear back from the Medical Group Management Association (MGMA), the organization that conducted the study.
As with any study or survey, you can find data to support any perspective.
That said, the ratings of the health plans are generally consistent with those reported by the Verden Group, an independent firm focused on helping providers deal with managed care organizations.
Aetna received top marks for clarity of communications, and was rated the most ‘provider friendly network’ by respondents to the Verden Survey in 2008.
As the public option becomes possible once more, and opponents lament the inefficiency, lousy service, and incompetence of the faceless bureaucrats that run Medicare, it is helpful to know what the people on the other end of the transaction think.
If you listen to them, on a number of fronts, Medicare’s a darn sight better than most of the private insurers they have to deal with


Oct
26

Swine flu and workers comp

While there will be differences due to jurisdictional rules, I’d be surprised if we don’t see Workers Comp cover many health care workers who get the flu.
Health care workers are getting inoculated due to their higher risk, the prevention information you mention indicates they are at risk due to their employment status, and there’s no question of their increased exposure risk.
The Federal government’s website, flu.gov, directs workers who are exposed to flu to contact their state work comp boards for questions on eligibility and coverage – that direction alone may encourage sick workers to file for comp, and if they were exposed at work and the exposure meets specific criteria, they may well have a compensable claim.
In addition, lower paid workers who do not have health insurance may – and I emphasize MAY – be more likely to claim WC for flu as they have no other coverage.
My sense is in many jurisdictions and for many claimants, swine flu would be compensable – if it can be demonstrated that the contact was ‘during the course of or arising out of employment’. And for health care workers, that shouldn’t be too difficult to prove.
Jon Coppelman wrote a good synopsis of this some months ago – here’s an excerpt from his piece:

In order for the flu to be a compensable event under comp, certain requirements must be met:
: the individual must be “in the course and scope of employment” when exposed to the virus
: the exposure must arise out of work (as opposed to being a totally random event)
: work itself must put the individual in harm’s way

My sense is in many jurisdictions and for many claimants working in health care service delivery, swine flu will be compensable – if it can be demonstrated that the contact was ‘during the course of or arising out of employment’. For health care workers, that shouldn’t be too difficult to prove.


Oct
23

Work comp drug fee schedules – what’s going to happen?

No one knows just yet, not even the regulators and legislators who are the ones tasked with coming up with a mechanism to replace AWP – which is going away in less than eighteen months.
More accurately, the First Databank/Medispan version is going to disappear; the Redbook version will still be around.
One option is to use Redbook as the standard, and there are some indications from some states that they are looking at Redbook. But Redbook has its issues – folks who know more than I about these things say it is not updated as frequently as Bluebook, and while it covers more medications, this ‘delay’ may make it problematic for PBMs who may well get into disagreements with retail pharmacies over the reimbursement level.
Beyond that ‘quick fix’, here’s how the changes may roll out. States with fee schedules set by their legislatures may well find themselves hard-pressed to meet the deadline; some, like Texas, aren’t due to meet until 2011, and others have a rather full legislative agenda with a lot more important stuff to deal with than work comp drug fee schedules. Thus, it is entirely possible that some states may not be able to address the issue before the clock runs out.
In that case, PBMs and payers will likely have to use the last version of the FDB AWP file for repricing pharma bills. That’s fine if the delay in selecting a new benchmark is a matter of days or perhaps weeks, but if it goes much beyond that we’ll see problems as prices charged by pharmacies will change while the reimbursement levels don’t. Litigation will likely ensue…
States that manage fee schedules via regulatory process are (likely) going to be a bit better off, as these processes are not dependent on the legislative process and complications thereof. Several states are already carefully evaluating alternative methodologies, and from my interaction with a number of regulators at the IAIABC conference last month, they are goign about this thoughtfully and with their eyes and ears wide open.
The real risk is if fee schedules are changed to match the Medicaid reimbursement rates.
This would be a disaster, as it was in California when physician dispensing exploded, and drug costs actually increased after the fee schedule was linked to Medi-Cal. In NY, where the State also set WC reimbursement at Medicaid, every PBM sent letters to the Chairman of the Workers Comp Board relaying their intention to exit the state if rates were not revised. Fortunately for all parties, they were successful in their efforts.
Unlike workers comp, there is no eligibility problem with medicaid – all recipients have a card. The formulary and DUR processes are well known and electronically administered. In comp, many claimants don’t know who their PBM is, and the only drugs that are approvced have to be directly related to the occupational injury or illness. These are just a couple of the distinctions, but they serve to illustrate the fundamental, and real, differences between comp and Medicaid.
Stay tuned – it is likely the big group PBMs and payers will move to another pricing benchmark, and like it or not, that will become the de facto ‘standard’.


Oct
21

A bit of sanity on Capitol Hill?

The Senate rejected the Medicare Physician Fairness Act rather resoundingly today, preventing a ‘fix’ that would have added a quarter trillion dollars to the deficit.
Senate Dems were trying to pass the bill separately from any overall reform bill, as combining the two would have pushed the total cost well over a trillion dollars over ten years – a figure that would, in all likelihood, doom the bill.
But an interesting coalition of all 40 Senate Republicans, Evan Bayh of Indiana, Russ Feingold of Wisconsin, Claire McCaskill of Missouri and Ron Wyden of Oregon – a pretty broad spectrum – voted no, killing the bill in a procedural vote.
This is good news. Not because we’re still stuck with the dysfunctional Medicare Sustainable Growth Rate mechanism, but rather because fully a dozen Dems stepped up to the plate and rejected a huge increase in government spending on an entitlement program. Lest my Republican readers get too excited, their party has yet to participate in any meaningful, helpful way in the discussion, and Minority Leader McConnell’s snarky comments today were yet another example of his inability to set aside petty, stupid, childish politics for the good of the country.
Here’s hoping that the rejection means we will actually, finally, seriously start talking about cost. This is where the GOP should show some leadership, which will require McConnell et al get a sudden injection of statesmanship. None of the bills currently before Congress – with the exception of Wyden-Bennett – reduce costs.
We should throw them all out, pass Wyden-Bennett, and get on with other matters.
Yeah, right, that’s really going to happen…