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:

I have a Safeco PIP case that Concentra called for similar reduced

payment. Safeco did not pay anything. I called after 60 days, and after

sending an unanswered demand letter. I was told that there was a new

adjuster involved and they would look into it. I saw the patient for six

visits (she is from WA) and sent high-quality, detailed chart copies

with HCFA bills totalling $825.00. D.O.I. was 2/04, last visit was

11/04. I was paid $184.00 on 10/04. Have sent two demand letters

referencing ORS 742.524(1)(a). Both ignored. It has been my, and I am

sure my collegues experience that the insurance companies pretty much

pay what they feel is the minimum necessary. I have lost THOUSANDS to

non-payment by insurance companies during the past 14 years. I just

wrote off a couple thousand yesterday from expired PIP cases that I

never received payment for. You have to accept what scraps you can get

and move on. Letter writing and attorney involvement is a waste of time.

There is not enough money involved, and insurance companies know that

they can get away with cheating us, so they do.

Glenn

Glenn F. Gumaer, B.S., D.C.

Chiropractic Physician

Northside Chiropractic Clinic

1240 N. Riverside Avenue

Medford, OR 97501

541-770-1330

www.seekhealth.com

wrote:

> A doctor just faxed me a Safeco PIP bill review from Concentra

> Preferred Systems, Inc. The doctor indicates that all of his/her

> billings were within the workers comp fee schedule. Nonetheless, this

> Concentra outfit (which I assume is a third-party vendor of Safeco's

> and which is presumably trying to sell its services to other Oregon

> Auto Insurance companies) lists this doctor's treatment as follows:

> *Date of Product/Service *07/15/2004 to 02/03/2005; *Provider's List

> Price* $3,561.00; *Adjusted Price *$2400.00. There is no listed or

> described justification for the reductions, other than the vague

> representation " This bill will be processed by the payor subject to

> Compensability, Auto Statutes, and Utilization Review. " Whatever the

> heck that means. Now this was a fairly significant impact with fairly

> significant injuries. Seven months of care and the bill is only

> $3,561.00! No offense intended, but I've seen $3,500+ bills after a

> month or so of chiropractic care. The point is that this is clearly

> not a case of overutilization nor overcharging. I find it curious

> that this supposed scientific and objective bill reduction system

> " adjusted " the doctor's bills to exactly $2,400.00. *Here's the

> rub*. An insurance carrier cannot force a bill reduction down your

> throat and claim there is an enforceable contract because you accepted

> the money and that neither you nor your patient can go after the

> carrier for the difference. Such a " contract " would be voidable and

> unenforceable because it lacks " consideration. " In other words, (and

> generally speaking) if I am obligated by a contract to pay you $500, I

> cannot modify that contract by telling you I'm willing to pay you and

> discharge my financial obligations to you as long as you agree to

> accept $300.00. An offer to give less than one has already agreed to

> give in a bargained for exchange (/quid pro quo/) is insufficient

> consideration to support a modification of a contract. In other

> words, you could take my $300.00 and then sue me the next day for the

> balance, regardless of the fact that I told you that payment was

> contingent on you agreeing to accept less. Concentra (and Safeco)

> attempt to get around this " consideration " problem by claiming that

> they will " (i) Waive rights to conduct an on-site audit of billed

> charges; and (ii) Release payment within 0-0 working days of receipt

> of signed agreement from the provider representative. " Now, assuming

> Safeco or Concentra had a right under the statutes or the contract to

> conduct an on-site audit of your files (they do not), or to delay

> payment of the billed charges (the bills in this case are already over

> 60 days old), there could arguably be an enforceable agreement between

> you, Concentra, and Safeco. I would allege that this constitutes

> unfair business practices, unfair claim settlement practices, and

> possibly misrepresentation or fraud in the inducement. Is it a

> coincidence that there is also a notorious workers comp ppo/mmo/hmo

> outfit operating in the workers comp arena with a similar name?? The

> listed area code for these jokers is (630). Is this something the

> Board could look at? This appears to me to be something the

> Department of Insurance or the Department of Justice ought to (could)

> look at, but my observations of those agencies over the past 15 years

> suggests to me that there would be no interest whatsoever in looking

> into anything like this. Best, G. , Gatti, Gatti, et. al.

>

>

> OregonDCs rules:

> 1. Keep correspondence professional; the purpose of the listserve is

> to foster communication and collegiality. No personal attacks on

> listserve members will be tolerated.

> 2. Always sign your e-mails with your first and last name.

> 3. The listserve is not secure; your e-mail could end up anywhere.

> However, it is against the rules of the listserve to copy, print,

> forward, or otherwise distribute correspondence written by another

> member without his or her consent, unless all personal identifiers

> have been removed.

>

>

> *

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Danno:

That message was a reply from me to at Gatti & Gatti. In

part, to vent, and in part to prod him into a response. I have written

letters and made phone calls, etc, and still do not get paid by some

carriers. When you are talking about only a few hundred dollars at a

time, there is nothing anyone can do about it. Are you doing something

that gets cheating outfits like Safeco, Progressive, Country Companies,

Farmers, et. al. to pay for all your services?

Glenn

Glenn F. Gumaer, B.S., D.C.

Chiropractic Physician

Northside Chiropractic Clinic

1240 N. Riverside Avenue

Medford, OR 97501

541-770-1330

www.seekhealth.com

D Beebe, D.C. wrote:

>:

>

>I am curious... why do you believe that you need to accept scraps?

>

>Danno

> Re: Beware of Concentra

>

>

>

>

>>:

>>

>>I have a Safeco PIP case that Concentra called for similar reduced

>>payment. Safeco did not pay anything. I called after 60 days, and after

>>sending an unanswered demand letter. I was told that there was a new

>>adjuster involved and they would look into it. I saw the patient for six

>>visits (she is from WA) and sent high-quality, detailed chart copies

>>with HCFA bills totalling $825.00. D.O.I. was 2/04, last visit was

>>11/04. I was paid $184.00 on 10/04. Have sent two demand letters

>>referencing ORS 742.524(1)(a). Both ignored. It has been my, and I am

>>sure my collegues experience that the insurance companies pretty much

>>pay what they feel is the minimum necessary. I have lost THOUSANDS to

>>non-payment by insurance companies during the past 14 years. I just

>>wrote off a couple thousand yesterday from expired PIP cases that I

>>never received payment for. You have to accept what scraps you can get

>>and move on. Letter writing and attorney involvement is a waste of time.

>>There is not enough money involved, and insurance companies know that

>>they can get away with cheating us, so they do.

>>

>>Glenn

>>Glenn F. Gumaer, B.S., D.C.

>>Chiropractic Physician

>>Northside Chiropractic Clinic

>>1240 N. Riverside Avenue

>>Medford, OR 97501

>>541-770-1330

>>www.seekhealth.com

>> wrote:

>>

>>

>>

>>>A doctor just faxed me a Safeco PIP bill review from Concentra

>>>Preferred Systems, Inc. The doctor indicates that all of his/her

>>>billings were within the workers comp fee schedule. Nonetheless, this

>>>Concentra outfit (which I assume is a third-party vendor of Safeco's

>>>and which is presumably trying to sell its services to other Oregon

>>>Auto Insurance companies) lists this doctor's treatment as follows:

>>>*Date of Product/Service *07/15/2004 to 02/03/2005; *Provider's List

>>>Price* $3,561.00; *Adjusted Price *$2400.00. There is no listed or

>>>described justification for the reductions, other than the vague

>>>representation " This bill will be processed by the payor subject to

>>>Compensability, Auto Statutes, and Utilization Review. " Whatever the

>>>heck that means. Now this was a fairly significant impact with fairly

>>>significant injuries. Seven months of care and the bill is only

>>>$3,561.00! No offense intended, but I've seen $3,500+ bills after a

>>>month or so of chiropractic care. The point is that this is clearly

>>>not a case of overutilization nor overcharging. I find it curious

>>>that this supposed scientific and objective bill reduction system

>>> " adjusted " the doctor's bills to exactly $2,400.00. *Here's the

>>>rub*. An insurance carrier cannot force a bill reduction down your

>>>throat and claim there is an enforceable contract because you accepted

>>>the money and that neither you nor your patient can go after the

>>>carrier for the difference. Such a " contract " would be voidable and

>>>unenforceable because it lacks " consideration. " In other words, (and

>>>generally speaking) if I am obligated by a contract to pay you $500, I

>>>cannot modify that contract by telling you I'm willing to pay you and

>>>discharge my financial obligations to you as long as you agree to

>>>accept $300.00. An offer to give less than one has already agreed to

>>>give in a bargained for exchange (/quid pro quo/) is insufficient

>>>consideration to support a modification of a contract. In other

>>>words, you could take my $300.00 and then sue me the next day for the

>>>balance, regardless of the fact that I told you that payment was

>>>contingent on you agreeing to accept less. Concentra (and Safeco)

>>>attempt to get around this " consideration " problem by claiming that

>>>they will " (i) Waive rights to conduct an on-site audit of billed

>>>charges; and (ii) Release payment within 0-0 working days of receipt

>>>of signed agreement from the provider representative. " Now, assuming

>>>Safeco or Concentra had a right under the statutes or the contract to

>>>conduct an on-site audit of your files (they do not), or to delay

>>>payment of the billed charges (the bills in this case are already over

>>>60 days old), there could arguably be an enforceable agreement between

>>>you, Concentra, and Safeco. I would allege that this constitutes

>>>unfair business practices, unfair claim settlement practices, and

>>>possibly misrepresentation or fraud in the inducement. Is it a

>>>coincidence that there is also a notorious workers comp ppo/mmo/hmo

>>>outfit operating in the workers comp arena with a similar name?? The

>>>listed area code for these jokers is (630). Is this something the

>>>Board could look at? This appears to me to be something the

>>>Department of Insurance or the Department of Justice ought to (could)

>>>look at, but my observations of those agencies over the past 15 years

>>>suggests to me that there would be no interest whatsoever in looking

>>>into anything like this. Best, G. , Gatti, Gatti, et. al.

>>>

>>>

>>>OregonDCs rules:

>>>1. Keep correspondence professional; the purpose of the listserve is

>>>to foster communication and collegiality. No personal attacks on

>>>listserve members will be tolerated.

>>>2. Always sign your e-mails with your first and last name.

>>>3. The listserve is not secure; your e-mail could end up anywhere.

>>>However, it is against the rules of the listserve to copy, print,

>>>forward, or otherwise distribute correspondence written by another

>>>member without his or her consent, unless all personal identifiers

>>>have been removed.

>>>

>>>

>>>*

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Danno:

Thank you for your response. My use of the term scraps was perhaps

unfortunate. It was used to get a reaction, and it is not my perception

of reality. However, there are frustrations with collections. PIP will

not pay even you for massage, or myfascial release/joint mobilization,

or neuromuscular re-education if you adjust the patient on the same

visit. They do not pay for computerized range of motion measurements, or

computerized muscle strength tests, even when they are the only

procedure performed on that day. (Actually, I am about 50/50 on that

one, but only after sending a letter.) There are only a very few

procedures that you can get paid for: E & M (but only if modified -25, and

with no other procedures); 98940-41 (98942 will raise red flags, even if

the adjusted levels are documented, there aren't enough diagnosis codes

to justify 5 areas.); 97010 ($7.49 is all you'll get); 97032, 97035

(each of limited quantity), 97110, 99211-13. What other general

practitioner is as so limited as we are? Heck, even physical therapists

have no trouble billing and getting paid for much more than what we

charge. Medicare even pays them for diagnostic procedures, while they

have zero training in diagnosis! But I digress...

D Beebe, D.C. wrote:

>We have a 92% collection rate for 2004 and have improved to 94% this year .

>My fee is my fee is my fee.

>

>By law you have to write off the amount in PIP that is over the payment

>schedule. If the insurance company will not pay as per ORS have your staff

>call and go to a supervisor, then his/her superviser then have your patient

>and yourself write a complaint to the insurance commisioner. I have the

>complaint form in my office and have the patient sit down with a staff

>person and fill it out in the office.

>You will get action, I assure you. Second you must keep a staff person on

>top of the adjusters. Once they know you are for real they are less

>aggressive.

>

>More my concern is why you have the belief that you do, ie accepting scraps,

>what you believe speaks so loudly to me I cannot hear what you say.

>

>Do you need help with collection policies?

>

>Danno

>

> Re: Beware of Concentra

>>>

>>>

>>>

>>>

>>>

>>>

>>>>:

>>>>

>>>>I have a Safeco PIP case that Concentra called for similar reduced

>>>>payment. Safeco did not pay anything. I called after 60 days, and after

>>>>sending an unanswered demand letter. I was told that there was a new

>>>>adjuster involved and they would look into it. I saw the patient for six

>>>>visits (she is from WA) and sent high-quality, detailed chart copies

>>>>with HCFA bills totalling $825.00. D.O.I. was 2/04, last visit was

>>>>11/04. I was paid $184.00 on 10/04. Have sent two demand letters

>>>>referencing ORS 742.524(1)(a). Both ignored. It has been my, and I am

>>>>sure my collegues experience that the insurance companies pretty much

>>>>pay what they feel is the minimum necessary. I have lost THOUSANDS to

>>>>non-payment by insurance companies during the past 14 years. I just

>>>>wrote off a couple thousand yesterday from expired PIP cases that I

>>>>never received payment for. You have to accept what scraps you can get

>>>>and move on. Letter writing and attorney involvement is a waste of time.

>>>>There is not enough money involved, and insurance companies know that

>>>>they can get away with cheating us, so they do.

>>>>

>>>>Glenn

>>>>Glenn F. Gumaer, B.S., D.C.

>>>>Chiropractic Physician

>>>>Northside Chiropractic Clinic

>>>>1240 N. Riverside Avenue

>>>>Medford, OR 97501

>>>>541-770-1330

>>>>www.seekhealth.com

>>>> wrote:

>>>>

>>>>

>>>>

>>>>

>>>>

>>>>>A doctor just faxed me a Safeco PIP bill review from Concentra

>>>>>Preferred Systems, Inc. The doctor indicates that all of his/her

>>>>>billings were within the workers comp fee schedule. Nonetheless, this

>>>>>Concentra outfit (which I assume is a third-party vendor of Safeco's

>>>>>and which is presumably trying to sell its services to other Oregon

>>>>>Auto Insurance companies) lists this doctor's treatment as follows:

>>>>>*Date of Product/Service *07/15/2004 to 02/03/2005; *Provider's List

>>>>>Price* $3,561.00; *Adjusted Price *$2400.00. There is no listed or

>>>>>described justification for the reductions, other than the vague

>>>>>representation " This bill will be processed by the payor subject to

>>>>>Compensability, Auto Statutes, and Utilization Review. " Whatever the

>>>>>heck that means. Now this was a fairly significant impact with fairly

>>>>>significant injuries. Seven months of care and the bill is only

>>>>>$3,561.00! No offense intended, but I've seen $3,500+ bills after a

>>>>>month or so of chiropractic care. The point is that this is clearly

>>>>>not a case of overutilization nor overcharging. I find it curious

>>>>>that this supposed scientific and objective bill reduction system

>>>>> " adjusted " the doctor's bills to exactly $2,400.00. *Here's the

>>>>>rub*. An insurance carrier cannot force a bill reduction down your

>>>>>throat and claim there is an enforceable contract because you accepted

>>>>>the money and that neither you nor your patient can go after the

>>>>>carrier for the difference. Such a " contract " would be voidable and

>>>>>unenforceable because it lacks " consideration. " In other words, (and

>>>>>generally speaking) if I am obligated by a contract to pay you $500, I

>>>>>cannot modify that contract by telling you I'm willing to pay you and

>>>>>discharge my financial obligations to you as long as you agree to

>>>>>accept $300.00. An offer to give less than one has already agreed to

>>>>>give in a bargained for exchange (/quid pro quo/) is insufficient

>>>>>consideration to support a modification of a contract. In other

>>>>>words, you could take my $300.00 and then sue me the next day for the

>>>>>balance, regardless of the fact that I told you that payment was

>>>>>contingent on you agreeing to accept less. Concentra (and Safeco)

>>>>>attempt to get around this " consideration " problem by claiming that

>>>>>they will " (i) Waive rights to conduct an on-site audit of billed

>>>>>charges; and (ii) Release payment within 0-0 working days of receipt

>>>>>of signed agreement from the provider representative. " Now, assuming

>>>>>Safeco or Concentra had a right under the statutes or the contract to

>>>>>conduct an on-site audit of your files (they do not), or to delay

>>>>>payment of the billed charges (the bills in this case are already over

>>>>>60 days old), there could arguably be an enforceable agreement between

>>>>>you, Concentra, and Safeco. I would allege that this constitutes

>>>>>unfair business practices, unfair claim settlement practices, and

>>>>>possibly misrepresentation or fraud in the inducement. Is it a

>>>>>coincidence that there is also a notorious workers comp ppo/mmo/hmo

>>>>>outfit operating in the workers comp arena with a similar name?? The

>>>>>listed area code for these jokers is (630). Is this something the

>>>>>Board could look at? This appears to me to be something the

>>>>>Department of Insurance or the Department of Justice ought to (could)

>>>>>look at, but my observations of those agencies over the past 15 years

>>>>>suggests to me that there would be no interest whatsoever in looking

>>>>>into anything like this. Best, G. , Gatti, Gatti, et. al.

>>>>>

>>>>>

>>>>>OregonDCs rules:

>>>>>1. Keep correspondence professional; the purpose of the listserve is

>>>>>to foster communication and collegiality. No personal attacks on

>>>>>listserve members will be tolerated.

>>>>>2. Always sign your e-mails with your first and last name.

>>>>>3. The listserve is not secure; your e-mail could end up anywhere.

>>>>>However, it is against the rules of the listserve to copy, print,

>>>>>forward, or otherwise distribute correspondence written by another

>>>>>member without his or her consent, unless all personal identifiers

>>>>>have been removed.

>>>>>

>>>>>

>>>>>*

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Once again use the modifier -59 with the with the 97140 you WILL get

re-imbursed so the HCFA should look like 97140-59 along w/ cmt codes for

that day! -59 describes complete and seperate procedure.

>

> Danno:

>

> Thank you for your response. My use of the term scraps was perhaps

> unfortunate. It was used to get a reaction, and it is not my perception

> of reality. However, there are frustrations with collections. PIP will

> not pay even you for massage, or myfascial release/joint mobilization,

> or neuromuscular re-education if you adjust the patient on the same

> visit. They do not pay for computerized range of motion measurements, or

> computerized muscle strength tests, even when they are the only

> procedure performed on that day. (Actually, I am about 50/50 on that

> one, but only after sending a letter.) There are only a very few

> procedures that you can get paid for: E & M (but only if modified -25, and

> with no other procedures); 98940-41 (98942 will raise red flags, even

> if the adjusted levels are documented, there aren't enough diagnosis

> codes to justify 5 areas.); 97010 ($7.49 is all you'll get); 97032,

> 97035 (each of limited quantity), 97110, 99211-13. What other general

> practitioner is as so limited as we are? Heck, even physical therapists

> have no trouble billing and getting paid for much more than what we

> charge. Medicare even pays them for diagnostic procedures, while they

> have zero training in diagnosis! But I digress...

>

> D Beebe, D.C. wrote:

>

>>We have a 92% collection rate for 2004 and have improved to 94% this

>> year . My fee is my fee is my fee.

>>

>>By law you have to write off the amount in PIP that is over the payment

>> schedule. If the insurance company will not pay as per ORS have your

>> staff call and go to a supervisor, then his/her superviser then have

>> your patient and yourself write a complaint to the insurance

>> commisioner. I have the complaint form in my office and have the

>> patient sit down with a staff person and fill it out in the office.

>>You will get action, I assure you. Second you must keep a staff person

>> on top of the adjusters. Once they know you are for real they are less

>> aggressive.

>>

>>More my concern is why you have the belief that you do, ie accepting

>> scraps, what you believe speaks so loudly to me I cannot hear what you

>> say.

>>

>>Do you need help with collection policies?

>>

>>Danno

>>

>> Re: Beware of Concentra

>>>>

>>>>

>>>>

>>>>

>>>>

>>>>

>>>>>:

>>>>>

>>>>>I have a Safeco PIP case that Concentra called for similar reduced

>>>>> payment. Safeco did not pay anything. I called after 60 days, and

>>>>> after sending an unanswered demand letter. I was told that there was

>>>>> a new adjuster involved and they would look into it. I saw the

>>>>> patient for six visits (she is from WA) and sent high-quality,

>>>>> detailed chart copies with HCFA bills totalling $825.00. D.O.I. was

>>>>> 2/04, last visit was 11/04. I was paid $184.00 on 10/04. Have sent

>>>>> two demand letters referencing ORS 742.524(1)(a). Both ignored. It

>>>>> has been my, and I am sure my collegues experience that the

>>>>> insurance companies pretty much pay what they feel is the minimum

>>>>> necessary. I have lost THOUSANDS to non-payment by insurance

>>>>> companies during the past 14 years. I just wrote off a couple

>>>>> thousand yesterday from expired PIP cases that I never received

>>>>> payment for. You have to accept what scraps you can get and move on.

>>>>> Letter writing and attorney involvement is a waste of time. There is

>>>>> not enough money involved, and insurance companies know that they

>>>>> can get away with cheating us, so they do.

>>>>>

>>>>>Glenn

>>>>>Glenn F. Gumaer, B.S., D.C.

>>>>>Chiropractic Physician

>>>>>Northside Chiropractic Clinic

>>>>>1240 N. Riverside Avenue

>>>>>Medford, OR 97501

>>>>>541-770-1330

>>>>>www.seekhealth.com

>>>>> wrote:

>>>>>

>>>>>

>>>>>

>>>>>

>>>>>

>>>>>>A doctor just faxed me a Safeco PIP bill review from Concentra

>>>>>> Preferred Systems, Inc. The doctor indicates that all of his/her

>>>>>> billings were within the workers comp fee schedule. Nonetheless,

>>>>>> this Concentra outfit (which I assume is a third-party vendor of

>>>>>> Safeco's and which is presumably trying to sell its services to

>>>>>> other Oregon Auto Insurance companies) lists this doctor's

>>>>>> treatment as follows: *Date of Product/Service *07/15/2004 to

>>>>>> 02/03/2005; *Provider's List Price* $3,561.00; *Adjusted Price

>>>>>> *$2400.00. There is no listed or described justification for the

>>>>>> reductions, other than the vague representation " This bill will be

>>>>>> processed by the payor subject to Compensability, Auto Statutes,

>>>>>> and Utilization Review. " Whatever the heck that means. Now this

>>>>>> was a fairly significant impact with fairly significant injuries.

>>>>>> Seven months of care and the bill is only $3,561.00! No offense

>>>>>> intended, but I've seen $3,500+ bills after a month or so of

>>>>>> chiropractic care. The point is that this is clearly not a case of

>>>>>> overutilization nor overcharging. I find it curious that this

>>>>>> supposed scientific and objective bill reduction system " adjusted "

>>>>>> the doctor's bills to exactly $2,400.00. *Here's the rub*. An

>>>>>> insurance carrier cannot force a bill reduction down your throat

>>>>>> and claim there is an enforceable contract because you accepted the

>>>>>> money and that neither you nor your patient can go after the

>>>>>> carrier for the difference. Such a " contract " would be voidable

>>>>>> and unenforceable because it lacks " consideration. " In other

>>>>>> words, (and generally speaking) if I am obligated by a contract to

>>>>>> pay you $500, I cannot modify that contract by telling you I'm

>>>>>> willing to pay you and discharge my financial obligations to you as

>>>>>> long as you agree to accept $300.00. An offer to give less than

>>>>>> one has already agreed to give in a bargained for exchange (/quid

>>>>>> pro quo/) is insufficient consideration to support a modification

>>>>>> of a contract. In other words, you could take my $300.00 and then

>>>>>> sue me the next day for the balance, regardless of the fact that I

>>>>>> told you that payment was contingent on you agreeing to accept

>>>>>> less. Concentra (and Safeco) attempt to get around this

>>>>>> " consideration " problem by claiming that they will " (i) Waive

>>>>>> rights to conduct an on-site audit of billed charges; and (ii)

>>>>>> Release payment within 0-0 working days of receipt of signed

>>>>>> agreement from the provider representative. " Now, assuming Safeco

>>>>>> or Concentra had a right under the statutes or the contract to

>>>>>> conduct an on-site audit of your files (they do not), or to delay

>>>>>> payment of the billed charges (the bills in this case are already

>>>>>> over 60 days old), there could arguably be an enforceable agreement

>>>>>> between you, Concentra, and Safeco. I would allege that this

>>>>>> constitutes unfair business practices, unfair claim settlement

>>>>>> practices, and possibly misrepresentation or fraud in the

>>>>>> inducement. Is it a coincidence that there is also a notorious

>>>>>> workers comp ppo/mmo/hmo outfit operating in the workers comp arena

>>>>>> with a similar name?? The listed area code for these jokers is

>>>>>> (630). Is this something the Board could look at? This appears to

>>>>>> me to be something the

>>>>>>Department of Insurance or the Department of Justice ought to

>>>>>> (could) look at, but my observations of those agencies over the

>>>>>> past 15 years suggests to me that there would be no interest

>>>>>> whatsoever in looking into anything like this. Best, G.

>>>>>> , Gatti, Gatti, et. al.

>>>>>>

>>>>>>

>>>>>>OregonDCs rules:

>>>>>>1. Keep correspondence professional; the purpose of the listserve

>>>>>> is to foster communication and collegiality. No personal attacks on

>>>>>> listserve members will be tolerated.

>>>>>>2. Always sign your e-mails with your first and last name.

>>>>>>3. The listserve is not secure; your e-mail could end up anywhere.

>>>>>> However, it is against the rules of the listserve to copy, print,

>>>>>> forward, or otherwise distribute correspondence written by another

>>>>>> member without his or her consent, unless all personal identifiers

>>>>>> have been removed.

>>>>>>

>>>>>>

>>>>>>*

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