00:00:04:08 – 00:01:14:00
Jay Shorr
Welcome to Shorr Solutions: The Podcast. I’m your host, Jay Shorr. I’m the CEO and founder of Shorr Solutions, a national and award-winning consulting firm, assisting aesthetic and surgical practices with their operational, administrative and financial success. I have an amazing team of practice management experts and clients across the U.S. and as an industry expert with firsthand experience owning a multi-million-dollar cosmetic dermatology and plastic surgery practice. Listen in as I lend you my expertise and best tips to successfully manage and grow your aesthetic practice. I will also be bringing in guests along the way, so get ready to be equipped to operate your aesthetic practice strategically and profitably. Welcome to Shorr Solutions: The Podcast.
This episode of Shorr Solutions: The Podcast was originally recorded as a webinar. However, We thought the content was so important we wanted to make sure you, our loyal podcast listeners, heard it as well. Thanks for listening and we hope you enjoy.
00:01:14:02 – 00:03:39:09
Jay Shorr
Well hello everybody, and welcome to Shorr Solutions: The Podcast. My name is Jay Shorr. I am the founder and CEO of Shorr Solutions, a national practice management consulting company specializing in the operational, administrative and financial guidance of your aesthetic, cosmetic, surgical and med spa practice. Today I have the pleasure of having two guests on this webinar and those of you who have had my join my webinars and podcasts. This webinar will be converted to a podcast, but I have two attorneys. Don’t say oh no and don’t run. These are the good guys. These are the good guy attorneys. They’re on our side. They’re not the ones that come afterwards. They protect us from us in spite of us. I have Brad Adatto and Brad is a partner co-founder of Byrd Adatto law firm based out of the Dallas metropolitan area. And I also have Alex Thiersch. Alex is the president founder of AMSpa. Everybody knows AMSpa, but also a partner of Byrd Adatto. And today we’re going to be having about navigating the landscape and navigating the landscape of, you know, our midsize and our our practices. It is such a wide and diverse thing of what we have to do, what we should do. So it’s navigating med spa compliance, what we need to know. It’s only an hour. The listen up, ladies and gentlemen. You are getting an hour of free legal advice. Now, I know that the free legal advice that I get from Brad. Because I call Brad all the time. I get free legal advice, which is one word. What would that word be? If anybody knows. It’s “depends”. And I’m asking, well, is it because of my age? I need the pens? Or is he shared with me It depends? So I always make the joke. Oh, boy, I’m going to call Brad and I know what answer I’m going to get. So let’s get started. When we talk about navigating med spies and what you need to know before we begin, let’s introduce ourselves. We’re going to ask questions. Call in ask questions live rather than in chat. Stay till the end for questions and answers, because we’re going to give it to all of you. And the recording will be available when the webinar ends. I will share with you that I have no formal disclosures about this. This is not monetized in any way, and our guests are attorneys and they have no formal disclosures about what’s going to be discussed in this. So, Brad, take it away. If you can give a 30 second of who you are. I appreciate it. And then we’ll go right to Alex.
00:03:39:11 – 00:04:16:00
Brad Adatto
Hey, everybody. Jay, thanks for the invite. Glad to be here with you guys. But as, Jay was saying, I am a lawyer with the one of the founders of ByrdAdatto and we are a law firm based in Dallas and Chicago. We have, we’re really what we’re known for is being business attorneys that represent health care practices. The vast majority of our practices that we work with happen to be in the aesthetic market. So plastic surgeons, dermatologists, med spa, wellness clinic. So it’s an area that we’re very familiar with. And like all business attorneys, we we understand how a business works. But as Jay was alluding to, you have to fund a lot of health care laws on top of that. And so that’s what we do every day at our shop.
00:04:16:01 – 00:05:12:11
Alex Thiersch
Yeah. Well, I mean, really it’s really tough to introduce myself after Brad and you because you guys are both just such luminaries. And we’ve we and we’ve done we’ve all known each other for a very long time. So this will be fun. But I appreciate the intro. Appreciate the invite. Alex Thiersch. I call myself a recovering attorney because although I still am a lawyer, I still am licensed. I spend, the overwhelming majority of my time, in fact, all of my time doing, running AMSpa the American Med Spa Association and we’re, you know, I, I founded AMSpa because of the fact that we wanted to make sure that folks were compliant. So it’s really what we do our, our, our job as an association is to make sure that everyone is armed with the information that they need so they can operate safely and compliantly. We want to elevate the industry, and make everybody, everybody’s safer and better. So that’s, that’s that’s what we do. But I am I am still, unfortunately, a lawyer. And I it’s just it’s really tough to shed that skin once you get going in that in that direction.
00:05:12:12 – 00:06:28:20
Jay Shorr
Well, I like to say the good kind of lawyers, because I remember when I owned, my practice. And I will make a disclosure. Disclaimer. I am not a physician. I say that because I’ll be speaking about my former practice, which I was a partner with here in South Florida. Very large practice. And many of you know my story. I’m not going to get into it today. And then I went into the business side of medicine, realizing about all the doctors and practitioners that needed the help and guidance. So one thing I want to ask is when you ask yourself, are all practitioners licensed and certified according to state regulations? And when I say state, I’m going to say state, I’m going to include commonwealths because we have Massachusetts, we have Pennsylvania, we have Virginia, we have Kentucky. For the purpose of today’s discussion, I’m not going to change my verbiage. Going to Commonwealth every time I mention state and want to use all the 50 states within, they could do us, you know, in the 50 states that we have here. So, Brad are all practitioners licensed and certified, meaning doctors, nurses, PAs, nurse practitioners, estheticians, scrub techs? Many are and many are not. So how do we how do we navigate around this?
00:06:28:22 – 00:07:57:17
Brad Adatto
Yeah. It’s a it’s a great question, Jay. And it’s almost like a trick question. And the trick of it is a lot of times when it comes to individuals, you may get a license from a particular state. So going back to it, you’re a nurse practitioner. You’re licensed by that nursing board. That’s who you answer to. That’s how you get your license. The certification though is a separate piece. So my scope of practice as a nurse practitioner, I can do a host of things. As events practitioner, I can help do ABC and a lot of that is dependent on what does my state say? Do I have to answer to a doctor? Do I have to be supervised by a doctor? And then to the second part of the question, the certification certifications are kind of tricky situation because most boards don’t recognize a certification in the sense of like, I trained on a laser, or I trained how to get Botox, or I trained at this. You may have a piece of paper that said you took a Botox course or laser course, which is important because that’s a skill that you need to do to actually touch that patient. But understand where I think we often see the compliance concern would be someone is certified on something, but it’s outside the scope of their authority. So to your point, Jay, earlier, yeah, there are individuals out there. They’re unlicensed, meaning there’s no nursing board or medical board or that had allowed them to touch that patient, but they get certified by some course in Vegas. But they learn how to fire a laser. Just because you were certified does not always mean in that particular state you can actually render that service. So hopefully that’s kind of helps. And I know Alex probably has some hot sports opinion on that one too, that I.
00:07:57:18 – 00:08:00:19
Brad Adatto
Then I have a. Follow up question to that. So go ahead Alex.
00:08:00:21 – 00:09:10:07
Alex Thiersch
No, I mean, I think, you know, we always get a little bit nervous when people start talking about how they are certified because really, a certification can be, you know, we could issue a certification after this webinar if we want to, we can issue a certification for pretty much anything. And and that doesn’t necessarily mean anything when you start talking to the states, the medical boards and things like that. The, the what if you’re a license holder, typically that is going to mean almost always that’s going to mean in all 50 states that the state has passed some sort of a law that allows you to be licensed as whatever they are defining your as a license. So if you’re a nurse practitioner, you’re a licensed MD, things like that. Normally and think in most of the most of the license holders in aesthetics and in medicine, that’s that’s pretty self-evident. Where it gets a little tricky is when you get into things like aestheticians who are doing medical treatments, when you get into medical assistance, who are, you know, unlicensed, but they’re also doing, doing medical, medical treatment. So it’s, it’s it’s tricky. But at the same time, I think the main thing is, is, is the licenses are really what you want to focus on when it comes to the state, because that’s that’s what the state actually recognizes. This was the license, of that state.
00:09:10:09 – 00:10:19:03
Jay Shorr
All right. So I would do a follow up question, because in the state of Florida, where I am a nurse or an esthetician, a nurse, R.N., LPN, nurse, regardless of what anybody says is not allowed to inject or fire a laser. All right. Now, an esthetician may fire a laser if they have an electrology license, but only for hair removal. And the craziest thing is a podiatrist can do laser hair removal, but only from the knee down. Go figure. I didn’t make these laws. These are according to their boards. Now, the question that I have for a follow up is that in Florida you can’t. But I was led to believe, for example, in Illinois, that under the direction of an MD, D.O., a medical assistant who is neither licensed or certified under the direction of the doctor, may perform specific services that other states you’re not allowed to do. Else, since you’re from that Chicago area. Can you comment on that?
00:10:19:05 – 00:12:10:19
Alex Thiersch
Yeah. And there’s it’s actually also a trick question, in many ways. But, that’s honestly how most states, not all states, but most states operate by saying it’s up to the physician, whoever that supervising delegating person is, whether it’s a physician or if you’re if you’re in a state that allows it, a PA or an MP, it’s up to them to determine who they can delegate to, who is qualified and experienced enough to perform that particular treatment. Now, I say it’s a trick question because, the medical boards and the investigators who are going to be enforcing these laws don’t always necessarily see it that way. So you’re absolutely right. Jay I in in Illinois, I could delegate certain treatments under the law, under the letter of the law to someone who is an unlicensed, quote, uncertified individual, and they could perform that treatment. And if I deemed them to be qualified, then that would be kind of on on me. However, a lot of that is, is not really what, what what what is what is found under the standard of care, which is kind of a separate issue. So the medical boards oftentimes are going to say, well, you know, maybe that’s allowed, but really under the standard of care as a physician, you shouldn’t be delegating, an injectable treatment, for example, to a lawyer who has no training. Right. But you shouldn’t be doing that. And, and and so it’s it’s not necessarily cut and dry to say, well, yeah, in the state of Illinois and Texas is the same way as I can attest to. It’s not really enough to say, well, yeah, you can do it because, really what it comes down to is are you able to justify and defend that decision in the event that there is an injury, some sort of a bad outcome, side effect, whatever that is, or if you’re investigate it by the by the medical board, you’re going to need to defend the fact that you delegated that treatment to somebody who was not trained and not licensed.
00:12:10:21 – 00:12:36:07
Jay Shorr
All right. So let’s talk about that. Because in order to do that, the doctor would then have to have had a delegation agreement. Right. Are they going to be creating this delegation agreement like posthaste after the incident? Like who would ever know that if you backdate that? I’m not acknowledging that that should be done. However, who’s going to hang for it? The person who allowed that person to do it. Correct?
00:12:36:11 – 00:14:38:06
Brad Adatto
Yeah. And I want to jump in here on that to to add some some more. I agree with what Alex said. Also, and going back to Florida versus Illinois a lot of times. So in the state of Florida, what the way the medical board tells a physician, hey, physician, if you believe someone can do something, you can delegate to them. So going back to your statement, Jay, I’m going to delegate to this, RN to this injection or this laser. And the nursing board would say, no, no, no, no, you can’t do that. That’s not within your scope. Now you have a conflict. This happens often with the boards where as a physician, I’m allowed to delegate it to that. And if I want to now the RN has to figure out how do I feel about my license being jeopardized by being delegated to. Which is to Alex’s point, everybody can read the rules. I mean, anybody can look them up on the internet. That’s important element. The next most important element is then how are they enforced and how are they viewed from an enforcement perspective? Because that’s what we as lawyers care about, because that goes back to the risk associated with that delegation. I’m delegating to this medical assistant in Illinois. How do they feel about that particular procedure? And to your point, Jay, the doc, generally speaking, or physician assistant, sometimes a nurse practitioner, their license are the ones that are most in jeopardy. We were delegating to a non physician. And then one more add on to that is when it comes to delegation, there’s a couple of states when someone goes, hey, I read that a doctor can delegate this laser treatment. And it’s okay. I’m like, yeah, that’s actually correct. He can delegate to unlicensed person. That’s a delegation. The second part of that rule is supervision, and the doctor must read the rest of the sentence. Be in the room with the laser check when they fire it. Well, yeah, he can delegate when the doc’s still standing there so they forget to read the second part of that, which is delegation versus and supervision if there’s an and there for a reason. And so sometimes people hear that you can do something, but they don’t realize, that those two have to be read in conjunction with each other.
00:14:38:11 – 00:15:14:09
Jay Shorr
Very interesting. It’s wonder how one question will lead to several supports, the several supports, or naturally, the, business and professional regulations, the governing body that has the licensure and naturally, the board of cosmetology. And here in Florida, which will govern the estheticians and the Board of nursing, they say that you can’t. Right. So although the doctor said it was okay, now they’re going to be in the potential situation to have their licenses revoked by their licensing bodies. However, medical assistants don’t have a license. So now what?
00:15:14:11 – 00:16:41:07
Alex Thiersch
Yeah, it’s you know, what’s interesting about that is that, when a situation like that happens and it can absolutely happen, really the license holder is going to be the one at risk. And we see this sometimes when non, non, licensed folks business people are owning through MSOs or whatever, whatever structure they have when they’re owning businesses. When it comes to the medical board investigating, they’re going to go after the folks that they have jurisdiction over, which is those license holders. So if you’re a medical assistant, you don’t have a license. Your license is not at risk. It doesn’t mean that that the med spa itself or the practice itself, the doctor itself, the supervising physician, whoever that might be, isn’t at risk. And we should always say that if the practice or whatever happens is egregious enough. Typically most attorney general have have have jurisdiction as well. And they can, open up. And we have seen this open up criminal investigations. And that doesn’t necessarily matter whether you’re licensed or not, but it’s it’s really a good point. And I think the bigger picture that we deal with as an association all the time is that when you get these conflicts between these boards and it happens more than you would think. And it’s not just that it’s conflicts between the boards, it’s conflicts between individual board members on how they interpret things. It’s conflicts between understanding of what a particular treatment is and who should be able to do it. It really is complex and we need to do a much better job as an industry of educating the board so that they understand how we do it and understand what the actual reality is and if necessary, make make changes.
00:16:41:09 – 00:17:45:00
Brad Adatto
And I want to add something to what he just said real quick, which is going back to just because you can doesn’t mean you should. And and so going back to states like Texas, where a physician can delegate to anyone they want to do a particular procedure. If if you’ve never seen that person touch a patient, you don’t really know if they have the skill set. Just because you can delegate to them doesn’t mean you should. And again, from our perspectives as lawyers, we’re thinking about if you go in front of the medical board or nursing board, we want to put you in the most defensible position. So now you get to go in front of a licensing board and explain to the board why you’re allowing someone to inject something right next to someone’s eye. And they’ve never had any formal anatomy training. Do you feel comfortable with that? And I actually know plastic surgeons like I’ve seen this person inject. They’re better than I am. And I know they’re not licensed, but they’ve been doing for 20 years. They’re amazing. Great. So long as you feel comfortable with that. Again, not against those who don’t have those same licenses. It’s just understanding. To your point, Jay and Alex, the physician ultimately has a responsibility who they’re delegating to and who they’re supervising.
00:17:45:02 – 00:18:26:00
Jay Shorr
Well, just because you can doesn’t mean you should. It sounds like God rest their souls. It sounds like something my mom and dad used to say to me as a little boy, you know, but that still resonates. So now, Brad, I’m going to leave this to you because you brought up, an issue a couple minutes ago about the doctor being in the room. Now, there are adages about direct and indirect supervision, where direct supervision doesn’t necessarily mean you have to be in the room. Some say that you have to be in the facility, and some say you have to be within an earshot of contact-ability. Do you want to expand on that just briefly?
00:18:26:04 – 00:20:21:18
Brad Adatto
Yeah, absolutely. I always break it down to three elements that when it comes to supervision. So the first one is you’re in the room with them. And that’s typically it’s such a complex procedure. The doctor has to be standing there normally as you can imagine that’s for invasive surgeries or invasive procedures are very even though it’s noninvasive, very restrictive. So a lot of times they’re in the room. The second category is what you were kind of referencing is immediately available. Generally speaking, depend on that state. That might mean that they’re in the same office building, not the same suite even, but at that same kind of practice. And then you have the third element, which is kind of general supervision, which is they do typically you’ll see in a state called appropriate supervision. And when you kind of dive deeper into that means they’re they’re available. Availability is really interesting because some states available is within 25 miles or a certain amount of, minutes or, you know, immediately available means you get them on the call immediately. So all of those are different elements when it comes to the supervision. So in the room onsite or available. And I always tell people, look, if you’re the doctor, and you’re, you’re going to go with immediately available, you know, actually no matter which version you take, you said great. Processes and protocols in place. So it’s very clear that how, the patient should be treated and if, an adverse event happens, how do they react to that within the next steps they’re supposed to do? Because when we again, going back to the defensible position, something bad happened. But that person knew exactly what to do because they had been trained on it. And the policy said, these are the next few steps that you’re supposed to do. So again, that goes back to no matter what type of supervision that you’re required to do, definitely have great written out protocols that, of course, the supervising physician should be aware of. And I know, Alex, you have some also thoughts on when someone’s not available. How how should a med spa or a practice respond?
00:20:21:20 – 00:20:40:18
Jay Shorr
There’s a lot of those. A lot of doctors, even the NPS. What the good, the good, the GFE good faith exams are not on site when you know these corporate facilities, for example, they allow some of these people to perform services. And the direct supervisor, whether it’s the NP/PA or doctor, aren’t there.
00:20:40:19 – 00:22:08:05
Alex Thiersch
And that’s not necessarily, against the, against the law. Or as Brad said, you know, even if you can’t do it, that that’s not necessarily inappropriate. There’s, there’s, there’s it really depends on the type of treatment and who’s performing the treatments, what you want to focus on. So an advanced procedure, obviously you are going to want to have more supervision than a less advanced procedure. So it’s not necessarily incorrect to not have the physician on site provided you have the protocols, as Brad was saying, in place, and proper delegation procedures, all of those things in place where you can deal with, you can deal with bad outcomes or side effects as they happen that the other thing that that that Brad was mentioning that I think is important is that particularly in aesthetics and, and med spa, oftentimes there will be times when the supervising physician or NP/PA if the, if that’s the case is not available for whatever reason, they are traveling, they’re overseas, they’re in, you know, Africa on a safari or whatever it might be, or you just can’t reach them. In those cases, it’s very important through your protocols to have some sort of a backup. You’ve got to be able to reach somebody. And it’s especially if you’re in an RN, or an esthetician, laser tech, one of those who doesn’t have prescriptive authority, you can’t actually make diagnoses. It’s going to be really difficult for you to do anything, if you can’t get a hold of that of the, of the supervising physician. So that’s it’s crucial to think about these, these things before you start restart, just operating with impunity.
00:22:08:07 – 00:24:06:03
Jay Shorr
And one of the problems that I have with a lot of my clients, I get to them and the first question I ask is, who is your medical director? All right. And they’ll tell. They’ll give me the name of a medical director. And as we all know, the big boys and girls in this industry. But they’ll give me a name of somebody in the person who who’s Google them, and they’re like, psychiatrist or like an orthopedist or an internal medicine. And the indications and adverse reactions, they’re not even astute enough to know how to treat, you know, I think the practitioner or themselves are more stooped in how to treat it. However, when there is a counter indication or an adverse reaction that needs to be treated by an advanced level practitioner, they have nowhere to go because their medical director isn’t. So, Alex, I’ll, at this question, I’ll direct to you because I know AMPSpa promotes provides different all different types of training. And then how much training do aesthetic practitioners need to perform treatments? Because I don’t want to build be a Danny Downer. However, one of the problems I have are there are so many monetized weekend courses that are out there that teach people how to operate a laser and toxins and, and, and fillers. And honestly, when I interview these people, you know, for jobs at other places or for clients, and they told me they got their certification, here we go. You know, I’m not going to name the place. And I ask them, what is the name of the laser that you use? I don’t know, all right. They don’t even know the name of it. What’s the fluids? You know, is it an erbium? Is it? Yeah. I don’t know. So that’s kind of dangerous. So as an attorney and in charge of AMSPA, how much training do aesthetic practitioners need to perform a treatment? And I didn’t ask Brad because I know if you want to get the answer, it depends.
00:24:06:05 – 00:25:04:17
Alex Thiersch
Well, it does depend. But you know, I’m glad you asked that question because it’s something that that whenever Brad and I do presentations together and we do them frequently, it’s, it’s it’s always it’s always something that folks want. The bright line answer. Right. They want to know I’ve got x number of hours. I’ve, I’ve done these number of courses. Therefore I am competent and I’m court certified. I can go ahead and do these treatments. The truth of the matter is it’s just not that simple. Unlike a lot of other verticals in medicine where there are board certifications, right? So you can have a board certification and orthopedics or cardiology or whatever it might be that doesn’t exist. So there’s no there’s nothing prohibiting a physician, like you said, whether it’s a, psychologist, psychiatrist or a, a heart doctor to become an aesthetic physician. Now, the question is, if you’re going to do that, how much training do you need? And there’s not an answer for that. I wish there was just a really good answer.
00:25:04:19 – 00:25:19:09
Jay Shorr
I’m gonna interrupt you for a second, I think because those doctors aren’t that you just mentioned aren’t aesthetic physicians. They are boarded and they’re professional board certification. They’re just being used because it’s MDDO.
00:25:19:09 – 00:27:33:11
Alex Thiersch
That’s right. It’s that’s exactly right. Because there is no board certification in aesthetics. Right. A doctor, just like a lawyer, can really practice in any field that they want, provided they are trained and experienced and they believe through their training and experience, they can they can meet the standard of care for those particular treatments. So when we get questions about how much training do we need, I always kind of chuckle because it’s there’s no answer. And I always say, as you want to get as much training as possible. And the the real answer is and this is this tends to work for physicians especially is the real answer is you want enough training where you can prove to a medical board if you’re being investigated, that you had enough training to, to to complete that treatment. And that’s not you know, that’s not a satisfactory answer to a lot of folks. And I get that. But it’s the truth because it’s it really is this, this kind of amorphous standard of care, term that we use, which is the physician has to act under the standard of care. And so for them to be able to perform a treatment, they need that to, to be able to act on the standard of care. And they need enough, enough training and experience to be able to do that. And that’s not something that is defined. It just needs to be. But it is something that you need to be able to prove. So if you’re investigated all those courses that you took, all the hours that you practice, all of those things, you need to be able to show to the board. So this is this is why I am able to perform this treatment. Number one, this is also why I’m able to delegate that treatment to somebody else who can do it. And I’m, capable of supervising and handling any complications that come up. It’s Brad. We always laugh about this because it really is. It’s a tough, tough question to provide guidance on because there really isn’t an answer. I think, a good way to do this. So for those of you who are before physicians or providers, just go back to what your specialty is like, what your actual board certification is. If I was to ask you a question in that certification, I’d say, you know, how do you know that you can perform a physical exam for, a heart check? You know, you have an obligation. You have an opportunity because you’re part of that particular board. You know the answer that’s kind of have to look at it from aesthetics, even though there’s not really a board for for aesthetics. And that that’s something that I think would be very helpful if we could develop that at some point.
00:27:33:13 – 00:28:05:02
Jay Shorr
Well, you know, I just want to say you have to be careful because the AACS would probably tell you that’s not true. However, there isn’t an abm’s recognized board because the the board of the laser board laser that the American Board of Cosmetic Surgery, although people recognize them as boards, they are not recognized by the American Board of Medical Specialties. And in certain states, you’re not even allowed to mention them as being board certified. Go ahead.
00:28:05:02 – 00:29:56:04
Brad Adatto
Yeah. And I’m going to add to to Alex’s point to, point and to your question earlier, I can give you examples. So a lot of time people are like, well, can you give me an example of how that’s work? So client in New York who’s a dermatologist, he has, many different practices. And when he’s training a nurse practitioner to come into his practice to inject, he doesn’t care how much experience she has. She must shadow him for at least six months before he feels comfortable that that person knows what they’re doing. So even no matter how much training even there, he’s during the injection because it’s a very precise way. And then he watches her or him do the injections. So again, this doctor is like now at least six months. And if I don’t trust them, they’re not working for me. So that’s that’s just shows you like his perspective about what he likes to have in his. So again, going back to the doctor mentality and I’m not picking on anyone else. This is a doctor story out of Chicago. And Alex knows his story pretty well too is we had a spine doc reach out to us. He was you know, he was slowing down on the surgeries and said, I’ve been reading all about this, these cash based businesses, med spa. I’m very interested in it. But I don’t know much about that field. And I said, great. I’m glad you’re asking us these questions now, but you can. As to Alex’s point, you can 100% owned the Med Spa because he wanted to get into the cash world, but he didn’t know how to do it. But one of his good friends was a dermatologist, so that even though the doctor owned 100% of it, he had a dermatologist come in and be the supervising physician. And over the next few years. So this is years ago now, this doctor did get started up and shadow the dermatologist and took courses so that when he finally start being the supervising physician, we all felt comfortable including here. It’s his license. Not mine, not Alex’s, not anyone else’s, that he felt comfortable, that he had enough training to be in a defensible position in front of that board. So that’s again, to Alex’s point. That was his reasoning as to why he felt good about it.
00:29:56:10 – 00:30:12:10
Jay Shorr
Beautiful. You just brought up another subset question from a subset question. All right. Is there a difference between a supervising physician because you just brought up something and a medical director?
00:30:12:12 – 00:30:14:17
Alex Thiersch
00:30:13:00 – 00:30:14:17
Brad Adatto
Do you want the “it depends”.
00:30:14:18 – 00:30:16:17
Alex Thiersch
00:30:16:19 – 00:30:22:02
Jay Shorr
I know one I know one can be the other. Yes. All right.
00:30:22:03 – 00:31:22:04
Brad Adatto
And so in some situations, the terms are: So, a medical director sometimes in certain states is a requirement. So if you have like a laser hair removal here in Texas, you must have a, quote, medical director or what is that job of the medical director? Sometimes the job of that medical director is to do be the supervising physician of that. Some of my larger clients, they may have a chief medical officer who has a medical director agreement, but because they’re so big, that doctor cannot be the supervising physician for every single location. And so they start finding other doctors to act as supervising physicians in the Alabama location and different doctor for the Florida location again, so that just start to really start getting to the details. But medical director doesn’t always mean that they’re supervising physician, of that individual, who’s doing the injections. But ultimately, the medical director would be the one responsible, making sure that all medical services being performed there or at the same level, that should be, to meet whatever the consistency with the state laws.
00:31:22:06 – 00:32:50:18
Jay Shorr
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00:32:50:20 – 00:33:23:22
Jay Shorr
Alex, let me jump to something else that just came out of this. Why is it that in certain states, a doctor can have unlimited amount, of spas or practice, they can be a medical director, but in that same state, if you’re a dermatologist or a plastic surgeon, you’re limited to the amount that you can supervise. Why is that? I would think that should. You’re just the opposite, that your best medical director of aesthetic Cosmetics would be a derm or plastics or facial. Oculoplastics.
00:33:24:00 – 00:36:06:10
Alex Thiersch
The realistic answer is that because, the the lobbyists haven’t quite got that figured out yet and the legislature hasn’t been convinced enough to make that, that, that, that change. I think, your point is a good one, though. I would hesitate, though, to say that, even in those states where it’s, quote unquote allowed, technically speaking, if you’re a supervising physician supervising, you know, 50 locations, I think there’s some risk there, right? There’s some risk there. And it’s I don’t care how good a doctor you are, it’s just not physically possible to be able to do that. But the the truth is, is that the the laws in these individual states that operate like that just haven’t caught up with the practice yet. You know, love moves very, very slow. Slowly. We the way the laws are written now, they’re designed for things like dermatology, and things like, you know, traditional areas of medicine and aesthetics, other than plastic surgery and dermatology really is not a traditional area of medicine. And then it’s relatively new. Right? So we’re still trying to get those laws to catch up and to actually address the way that that the business and the and the medical practices work that’s going to take some time is something that we are working on all the time. And it’s it’s really, really tough and sometimes frustrating, not only from a question like the one that us, but also from the other side. When you have a perfectly capable physician who is trained in aesthetics, is doing everything right, but you have a medical board or a nursing board who comes in, doesn’t necessarily know how it operates, and can’t figure out why. It is that a general practice physician who you are a E.R. doctor is now a medical director for a med spa, supervising a bunch of people doing aesthetics. In their mind, it doesn’t make sense. And so it becomes an issue. So there’s a lot of work to do. But I will say the most important thing is most physicians, I think. Brad, I would love to hear your thought on this. Most physicians, when you break it down for them and ask them, look, are you able to supervise these particular, procedures in this amount with, you know, whether it’s 50 locations or two locations, most physicians in their training can break it down to, okay, what training do I have? Am I able to supervise? Am I able to handle complications? Am I able to prescribe things to help with complications? And if there if there’s just too, too much and or they don’t have enough knowledge, they’re going to say no. And so that’s kind of where it comes down to because the oftentimes the board and the laws are not going to comport with how it’s actually working.
00:36:06:12 – 00:37:47:03
Jay Shorr
All right. So let’s jump to the next equipment. Medical equipment. You know, we go to all of these conferences. And when you walk onto the exhibit floor, I’m telling you, you don’t know one box from another. They all look alike. They’re FDA approved. They’ve gone through the 510K approval. And now I lecture internationally, whether it’s in Europe or Canada and South America. And then I see a whole bunch of other machines that are not FDA approved. I’m not even talking about off label. All right. So does your med spa and the med spa’s comply with state and federal regulations. They should be FDA approved and all equipment should be properly maintained. And procedures have to follow both the state and the federal regulations so that there’s no violations from the FDA. I guess one of my major questions would be, how do you ensure that the people are knowledgeable?
00:37:47:05 – 00:39:52:23
Brad Adatto
Yeah. To that point on that, I’ll address that one first and then the secondary part second. Yeah, that’s the hard part, because not one of the things you said earlier when we’re starting, this is every single state is different in certain states. When you do have lasers and depending on the type of laser there is a registration process. It’s a it’s just a kind of kind of it is compliant. And I do know where people get reported, to that to a lot of times it’s the person the reporting to is, is competitor or their angry patient or whatever it is saying this, this place is not certified to have that laser. They have not filed the proper paperwork. That doesn’t change the fact that the doctor knows how to properly use it. The individual knows it properly. It’s a paperwork compliance. And to your point, Jay, you know it would be beneficial to the laser companies to make sure that that are that sale process. They tell them that I know that, and spa has a lot of paperwork out there. I know we’ve lectured on that. We’ve talked about it, but it is word of mouth, unfortunately, Jay, more than anything else. But to your point about the type of equipment, I think the the we should have said I should, I should at the very beginning that no matter what you want to say, you’re in the practice of medicine. You can call it a medi spa, a med spa, wellness clinic. I’ve seen all the different names, and because you’re in the practice of medicine, no matter what you say as I go. Oh, this person’s waiving their rights. That I’m using a machine that’s not FDA approved or I’m. They’re paying me cash, and therefore, it’s okay. All I’ve heard, all those kind of exceptions. No, no. That’s correct. And you were saying this and I think this is where you’re going with this when you are having equipment in your medical practice, your med spa, it must be FDA certified to, to be utilized. And I know there’s a lot of machines out there that people are selling. And they actually were saying they’re not FDA approved. And therefore it’s okay because you’re using it for off label. That’s not how it works. Or you’re importing something from Korea that’s used all the time in Korea. You’ve trained on it in Korea, and therefore you want to use your practice again, that’s a that’s a federal issue. It’s more than just even a state issue. And so the you can’t even start going to the off label, until you make sure it’s FDA approved to some capacity.
00:39:53:00 – 00:40:27:13
Jay Shorr
How would a client know that they go to a conference, they’re fed a bill of goods. You see it all the time. I happen to think that the ones that we see domestically, they’re legit. You know, even if I don’t like their laser, they’re legit, right? But I go Canadian, I go South America, and there are good machines. They’re just not FDA. How would somebody know that if I’m buying it? Let’s say, hey, here’s an example. I’m buying it from Doctor Alex. How do I know if it’s FDA approved or not? And then I’m liable. How do you find this out?
00:40:27:15 – 00:40:31:06
Alex Thiersch
Yeah, it’s coming from Doctor Alex. It’s good. Trust me.
00:40:31:08 – 00:41:27:10
Brad Adatto
Well, and to your point, Jay, I think number one is, you know, obviously they should listen to this podcast and then they’ll get the information they need. They know they had to stop and hit the pause button. When they are going to international conferences, the vast majority and, and I’ll let you speak to and spell. But I know a lot of these different organizations they vet who’s showing up and who’s selling product at their place because they don’t want their, their clients to their, their attendees to have issues, that there’s a laser being sold there, but no one can use it, ever in the United States. So why is that laser here? So I know that that’s part of their process. But, and then to the compliance question, unfortunately, that that’s going to be one of those if I’m buying it from Doctor Alex, I should go to the process to make sure is that equipment certified doesn’t meet the rules of being FDA approved. So that it is it hopefully there they hit the pause button before they make that purchase because these these purchases tend to be very expensive, very expensive.
00:41:27:12 – 00:42:37:07
Jay Shorr
And we see a lot of second hand equipment on the market. I, we all know all the name brands, but there’s some that, you know, I don’t even know that. So, let’s get now on. So how do you manage? This is a big thing today. How do we manage the patient expectations and maintain treatments during the adversity? During drug shortages, for example, the FDA is current shortage answers appetite and semaglutide. All right. With these big weight loss, there has been a lot of conjecture whether compounding pharmacies are allowed or whether they’re not allowed. I’ve seen some conjecture from some attorneys that said it is on the shortage list. I’ve heard somebody said that they’re not. I have two clients that received a cease and desist from a law firm saying that they need it in writing, that they’re going to stop marketing it. All right. It’s no longer on the shortage list. I’ve done investigations myself. I see the list on the shortage list. And then, of course, you call another law firm that’s not on the shortage list. I know it depends. I’m looking for an answer for the people listening.
00:42:37:09 – 00:44:50:20
Brad Adatto
It doesn’t depend. This is this is the weird area of the FDA law. So on the FDA law, there is a shortage lists. And so when a drug is moved over to that list, it sits there and to a time in which the FDA thinks, hey, based on all the, the, the actual the producers of this particular drug. So let’s use Eli Lilly, they’re producing this drug that hits the shortage list. This allows pharmacies to compound their they’re all the ingredients. They say to do A, B and C and D. And by doing that they can now compound it legally eventually based on production. It goes from the shortage which list to the available es. So when that happened, a lot of people like, oh, it’s no longer on the shortage list and therefore I have to stop using it. Eli Lilly started sending out I mean, we had a ton of clients getting a letter saying you can’t do this anymore, blah, blah, blah. Well, they jumped the gun because it’s actually still on the shortage list. Technically, because available means that the FDA’s paying attention to see can they get enough of these drugs produce to then eventually move it to the resolve list? And once it hits the resolve list, that triggers a whole bunch of stuff I won’t bore your audience with today, but that’s the three steps. So right now it’s on the available list that does not change what compounding can do, and it does not change. As a practitioner, what I could do where most practitioners got in trouble was they were marketing that they had that particular drug at the practice and they don’t. So that’s on the on the medical rules. That’s false, deceptive, misleading to say, I’m going to give you this drug, you’re actually getting a compound version of that drug. I do know investigations that have gone on where if the doctor didn’t disclose that was a compound. So again, if you’re out there using it, you must disclose that to the patient. Explain to the patient what is compounding. What does it mean. And you definitely want a written consent that they understand that they’re getting a compound and drug and not the actual drug. And then that means on your marketing material, don’t have them up there. In a lot of my clients now that says weight loss drugs or compounded weight loss drugs, you can sit there and describe to them what it does. But again, be very, very careful. But how you’re promoting it for the marketing right now, everything else is just white noise when it comes to the shortage list.
00:44:50:22 – 00:46:39:20
Jay Shorr
All right. Well, jump to another topic. I know that I’ve been on some panels with you, Alex. And I teach this at the university. HIPAA. You know, back when this portability act first came out, people have said no, HIPAA is only if you take insurance, because that’s why it’s called health insurance portability guy. All right. I’d like you to really give the reality of violation of protected health information for anybody. And the fine is that a massive this is not a state regulation. This is a federal regulation. So ensuring that there’s documented protocols for patient consent and confidentiality. We speak about that for a second for clear procedures for obtaining , the consent, keeping the health information confidential and remembering HIPAA standards and you know, when we talk about the consent for a second, I hear this all over the place. If you have a consent, do you have to consent to each and every treatment, or does there a master consent example? You join a Botox club or a Dysport club? I want to visit the club. I want to be fair to all them and I sign the consent. I’m aware of the contract indications and then I come back for the next treatment. The next treatment. All right. And I don’t sign the consent because it’s the same procedure. And then the nurse practitioner says, you know, you could use a filler in your nasal labial fold. Now you’ve already done a different procedure, not under the same consent. Can you elaborate on that.
00:46:39:22 – 00:49:50:17
Alex Thiersch
Yeah. So there’s I mean there’s there’s two things there. One is the, the HIPAA question and the patient confidentiality and the consents are there’s obviously part of HIPAA that come with consent, but there’s also consent to treatment. So taking your your later question first, you’re absolutely right. When patients need to be able and are required to consent to the treatments that they’re getting most of the time, that doesn’t mean a general consent is going to cover everything. I would not be comfortable with that. Particularly given all the different drugs, particularly given that your condition can change when you come back. So when your consent to a particular procedure, what that means, kind of in layman’s terms, is that you’re being given all the information to be able to make an informed decision about whether or not you want this particular treatment. Now, if you come back and they say, well, we’re going to do something else or there’s a, there’s there’s something, or potentially there’s been a change in your health history. We always use the example where you’ve become pregnant or you’ve, you had a stroke or whatever it is. Things have changed now. And, and so those disclosures need to be made over again. There needs to be another consent where you’re consenting based upon all of those new things. Again, it’s not necessarily that you have to do it every time, but it’s good practice because more than anything, and Brad can attest to this is, you know, if it’s not written, if it’s not recorded in the medical chart, it’s like it didn’t happen. So the reason that these consents are kind of use, like when you go to the doctor now oftentimes you’re saying the same thing over and over and over again. You’re like, man, I’ve already signed this thing a million times. Well, in many ways they’re covering their ass saying, well, yes, you signed it this, this particular time. And then when it comes to when it comes to HIPAA, it’s again, hip is all about patient confidentiality and making sure that the patient’s medical records, the patient’s information are protected. You’re absolutely right. There is an argument to be made that cash based practices and aesthetics aren’t necessarily covered and subject to the federal HIPAA law. However, that is basically a bit of a red herring, I think, because what we’re seeing is, number one, all of the states have their own patient privacy laws that tend to be as strict, if not stricter than HIPAA itself. And, we’re starting to see every now and then, when this issue comes up, we’re seeing we’re seeing judges or we’re seeing enforcement actions cite to HIPAA as being the standard of care, meaning that if you’re not adhering to to HIPAA on a federal level, you’re not really taking the type of care that needs to be done. I’m not sure about the, the actual penalties and provisions. Hopefully Brad knows everything. He has everything memorized. So I would ask him about that. But but I know they can be extreme. I know that getting any kind of a hit, the part of the problem of getting a HIPAA violation, if it’s actually HIPAA on the federal side, it’s not just the the the fines, it’s the obligations that you’re now required to take as far as disclosing and reaching out to folks and making sure that you’re publishing what happened. And it can be really, really, really time consuming and costly and it can be debilitating to a practice. Brad, that I yeah.
00:49:51:12 – 00:52:39:07
Brad Adatto
Good job Alex. Thank you. Thumbs up. And I want to add some stuff. That’s what Alex said which I think is really important to what your question Jay which is a lot of times when a patient comes in before the practitioner touches that patient, there’s a general consent. The general consent is that you agree to come in. And if they have to do for their, their, their, their examination, they might have to touch your skin to see how it responds. You want that general consent. That’s consent. Where to your point Jay is after that it’s an informed consent, which is okay. Now that we know you’re a good candidate for this service, you know, the laser, the Botox, whatever, we need to make sure that you understand. What are you about to have done? So if I only came in and I was cleared for that under informed consent for that laser. But the next time I come in, I want an IV in. The next time I want to come in, I want to have, Botox each one of those. There should be a good informed consent in which I was cleared properly by the physician or a Pas, and that I understood what I was getting into. Now, if I come in and they say, Brad, you give me a great, candidate, we gotta remove that tattoo that says, I love Alex on your arm because I know you don’t like it anymore. It’s going to take, it’s going to take six times for us to get it off. Now they’ve put that together. So I’m going to come in for six different times. I understand that’s they’re going to keep firing the laser to it goes away. And every single time I come in before they fire that laser, they should ask, is there any material change in your health? That’s the question they asked. And nothing else is change. We can continue through this treatment plan that we have to fire that laser. I come in, that goes. Any material change, you help? No, but I got really burned. I was out, you know, when the Florida with Jay on his boat and we had too many cocktails. I forgot to put sunblock on. I don’t think you’re a good candidate today for this. Let’s pause. I’m going to get you back with the nurse practitioner to make sure, when can we start this laser process again? Because I don’t want to. I don’t want to fire a laser on burned skin again. That’s. Those are material. And he had material to the point of how it affects that particular procedure. So, you know, I have a head cold. Might not be enough to say, oh, no, you’re fine. We can keep going. Material to what? That it is. And to Alex’s last point, yes, I totally agree. HIPAA does exist on the federal laws, but every single state already has their own baby. We call baby HIPAA a state version of that. Many of them have higher fines and higher issues that you have to abide by. And then that standard is really being set by different courts. Some states have allowed it, like Arizona, no. One state where plants attorneys sued the doctors and saying this is the standard that you have to follow, and you didn’t even come close to it. And so the judge was allowing that in as the standard for that breach, saying that you you, the practice, even though you don’t have to follow verbatim, you should have at least had some of it. And so that’s, that’s the HIPAA and understanding how it’s applied.
00:52:39:09 – 00:54:04:20
Jay Shorr
Yeah, I don’t even want to get into reviews and HIPAA because we speak about that for hours. You know, and yeah Jeff. All right. Yes on that. But it becomes a nightmare about violation of HIPAA or sometimes, violations of terms of service. I don’t necessarily agree that it’s not fair for the doctor to respond when a patient actually calls you out, but that is the law, right? Let’s talk about professional liability, aka malpractice insurance. You know, we have to confirm that med spa and medical practice carry the adequate amounts of malpractice professional liability. Because here in Florida, the minimum would be 100 300 and it could be 250-750 if you have an O.R.. And here in Florida, you do not even have to have malpractice insurance. Professional liability. You can either post for that personal financial responsibility, an irrevocable letter of credit, or have a policy. Now, if you post personal financial responsibility and you’re called to task and you can’t pay up, you lose your license. All right. So and they also have different like if you were hit for three malpractice claims by a court, you know, on the national practitioner’s databank, you could also lose your license. Let’s talk about malpractice insurance and who it covers, whether it covers the PA the NP, the institution in your practice, or whether they should have their own policies. Let’s start with you, Alex.
00:54:04:22 – 00:56:15:03
Alex Thiersch
So it depends. However, what I will say is that, first of all, you should definitely have malpractice insurance. I don’t I don’t recommend not carrying insurance. Not carrying adequate insurance. So there’s different types of insurance that cover different things. This isn’t exactly my expertise, but what we have been finding is that there are insurance companies that provide a medical malpractice policy for everything that happens under the roof of that medical spa. So all the treatments that are happening, provided you’re disclosing what all those treatments are, you’re meeting all the conditions that should cover what happens under that, that the roof of that medical spa. However, a lot of physicians have their own, individual policies, and that’s that’s not a bad idea because, you know, the more insurance the better. Is, is was what many people say, when it comes to other types of practitioners, like nurse practitioners, particularly in PAs typically, they are going to be if there is a policy, they are going to be covered under that, a policy of the medical spa. The problem is, is that unless you get your own policy, right, you get you secure your own insurance policy, you’re relying on other people to make sure that everything has been all the I’s have been dotted, the t’s have been crossed, the bills have been paid, everything is being disclosed properly. So it’s not necessarily a bad idea to have your own policy. But but the main thing when it comes to insurance is in this area is you’ve got to make sure that you are completely forthright with the carrier on everything that you’re doing, making sure that you understand it. Because where we see folks get into trouble in this industry is that insurance is they think they have insurance. But when it comes to a lawsuit or a particular claim, it turns out they don’t, because for whatever reason, that carrier says, well, we’re not going to cover weight loss. We’re not going to cover IVs, or you didn’t tell us about this, and that’s where you get in trouble, because this is a very it’s a it’s a unique area for the insurance carriers, too. They’re still learning the ropes in this. So you’ve got to be careful and you’ve got to be totally forthright. And just make sure that you’re disclosing everything. You’re not hiding anything at all and you’re completely transparent. Now you’re behaving.
00:56:15:05 – 00:57:01:03
Jay Shorr
Yeah, that’s a great point, that when you have a policy, it has to list what the coverages are on the declaration pages so that you don’t think I thought he said she said. And then that person is gone. I’m going to ask one more question before we wrap it up, because I’ve got dozens more questions. We just don’t have another enough time. But that will be for part two. All right. So how much freedom do independent practice nurse practitioners or possess have? This is another one of these things that, you know, in certain states, they’re going to have and be able to open up their own. In California, they’re allowed to open their own in this state. They’re, indeed medical directors and delegation agreements. What are we going with this?
00:57:01:05 – 00:57:02:14
Alex Thiersch
Brad loves this question.
00:57:02:14 – 00:58:54:17
Brad Adatto
So this is a hot topic, as you can imagine. Jay. And it’s because basically there’s three ways that a nurse practitioner can get independence. I’ll focus on them first because that’s where the trend is going. And so generally speaking, it’s by the fact that you have a license. So you’re in Nevada and you get licensed there. You’re you’re independent. Autonomous means that you can do a host of things, under your particular license. The next level is what’s happening in Illinois and Florida and New York and now California, where after practicing under the proper supervision of delegation for a certain time frame, you can then get your independence. And the third one, which is not as relevant is is because the area meet certain criteria. Normally it’s out in the boonies and the because of the way it’s been delegated, you can practice there without as somewhat independent, but that’s that that’s a three that we typically look at it, which the fascinating part is we saw this happen in Illinois when I was at Florida. I’m having the same conversations in California. In New York is a lot of people see, oh, they passed the law and therefore I can go become independent. It’s like, no, no, no, no, that’s what the statute says. Now we have to wait to see how the nursing board say you get independence. And that’s the most relevant piece. So in Illinois we had a bunch of nurse practitioner were jumping the gun because it said that they passed the law. The governor signed it, but the nursing board finally said, no, no, no, you have to do this many hours, this many accredits and then apply and then you get your independent. So it’s not by fiat. Like again, going to Nevada I’ll have to do is get a license that I’m independent. There’s a whole process that you have to go through. You know, it’s like, you know, you can’t skip it. You can’t. You have to go through that route. And there’s arguments in New York, in California as to when does that start or stop? So it’s it’s it’s gray is, Mississippi mud.
00:58:54:19 – 00:59:50:14
Alex Thiersch
Yeah. It’s very tricky. Jay. And what I would recommend for everybody, if you’re an NP or a PA, one of these states, you’ve got to move with caution in this because we get questions all the time on this. The truth. It’s not just that the rules have to be set, which is true. But then how are those rules going to interact with other things like medical advertising? There are some states that say independent MPs shouldn’t be calling themselves medical directors or shouldn’t be operating a medical spa, because it’s the term medical as opposed to nursing. And we’re not sure how this is all going to play out. So it’s kind of in real time, starting to shape up, and it’s going to take a little bit of time to unwind this. So as excited as all the NPs and some of the PAs to get out there and be independent, it’s there is some risk there. And until we get it, until we understand what it’s going to be, until the boards understand how they’re going to enforce it and how the penalties are going to happen and what they’re going to investigate. It’s there is some risk there. And I would proceed with caution.
00:59:50:16 – 01:01:00:10
Jay Shorr
All right, ladies and gentlemen, we have reached the hour. My how time flies when you’re having so much fun. So let’s share how they can get in touch with us. I do have one note. To announce that yesterday, Shorr Solutions, my practice management company, received notification from Informa, who has the AMWC, VCS, The Aesthetic Show that we were nominated and voted as the best practice management company of 2024. This is my fourth time out of six years winning that. So thank you to all of you out there that have voted. Thanks for the confidence, Alex and Brad, that we work together with all of these things. It can’t be done without every one of you. So if we can throw that slide up, you can contact me. That would be Jay Shorr at Shorr Solutions. Plural. Because we have more than one solution. All right. Our website is www.shorrsolutions.com. And all of our social media handles are at Shorr Solutions. Brad.
01:01:00:12 – 01:01:17:08
Brad Adatto
Yeah, and for us the easiest way to get Ahold of us is at info@byrdadatto.com If you reference the fact that you saw this video or listen to the podcast, my team will send up a consult gratis, so that we can kind of help answer any questions that you had left that we can address today.
01:01:17:10 – 01:01:18:22
Jay Shorr
And lastly, Alex.
01:01:19:00 – 01:01:40:18
Alex Thiersch
Yeah. And for me, info@AmericanMedSpa.org. the main spot is AmericanMedSpa.org. that is the AMSPA website. And Instagram is where we spend most of our time when it comes to socials. You’ll see it there, but our social hands are there as well. Info@AmericanMedSpa.org will work. But yeah, that’s. And you know, you reach out to Jay, he’ll get a hold of me too.
01:01:40:20 – 01:01:56:06
Jay Shorr
Okay, so ladies and gentlemen, thank you for spending the hour with me, with my colleagues, Alex Thiersch from AMSpa and Brad Adatto from Byrd Adatto. Have a safe holiday season. Good luck and God bless.
01:01:56:08 – 01:03:29:08
Jay Shorr
So that wraps up today’s episode of Shorr Solutions: The podcast. If we mentioned any website links, you can find them in our show notes to work directly with me and our award-winning team of consultants to increase efficiency, increase revenue and decrease costs in your aesthetic practice, schedule a free consult with us today. We will help you establish and refine your aesthetic practice’s protocols for maximum efficiency and productivity, decrease your expenses and increase your profitability with an expert financial analysis of your business. Attract more patients, convert calls to consults, convert consults to treatments and keep patients coming back for more. With our sales training, coaching and complimentary access to our conversion cascade online course. Recruit, hire and train new team members and manage any staff turnover with our human resource expertise plus more, head over to our show notes and click on the link to schedule a free 30-minute consult with us today. And if you enjoyed today’s episode, don’t forget to spread the word and share this episode with your friends, colleagues and the rest of your team. Remember to also follow us on social media @ShorrSolutions and sign up for our e-newsletter. You’ll learn about our latest tips, blog posts, services, videos, webinars and more. Links to our social media channels, and to sign up for our e-newsletter are in our show notes. So see you next time and remember to leave us a review and subscribe or more valuable content.
