georgia corporate practice of medicine

Corporations that employ physicians to provide medical services are engaged in the corporate practice of medicine. Contact our healthcare law and FDA attorneys for legal advice relevant to your healthcare venture. The eBook versions of this title may feature links to Lexis+ service for further legal research options. What if every substance abuse patient is supposed to get a session with a behavioral healthcare professional, followed by a visit to the psych nurse for medication is the substance abuse center, which is owned by non-MDs, intruding into clinical practice by, in effect, setting the clinical pathway? Freelance beer trailblazer.

WebThe corporate practice of medicine doctrine (CPOM) was first put forward in the late 1800s by the American Medical Association to distinguish services provided by physicians from those provided by non-physicians. What is the role of a medical director in a spa? All rights reserved. WebThe Georgia Composite Medical Board is the agency that licenses physicians, physician assistants, respiratory care professionals, perfusionists, acupuncturists, orthotists, prosthetists, auricular (ear) detoxification specialists, genetic counselors, cosmetic laser practitioners and pain management clinics. Joel is able to leverage his transactional background and deep health regulatory experience to provide seamless legal counsel regarding the complex strategic and operational issues facing health care providers and investors. AHLA Antitrust and Health Care: A Comprehensive Guide (AHLA Members), AHLA Enterprise Risk Management Handbook for Healthcare Entities, Co-published with the American Society of Healthcare Risk Management (AHLA Members), AHLA Corporate Practice of Medicine: A Fifty State Survey (AHLA Members), Notify me when I need to update in future (no Automatic Shipments), Keep my subscription up to date (Automatic Shipments), Andrew G. Jack, Glenn P. Prives, Jed A. Roher, Joel C. Rush, McElroy Deutsch Mulvaney & Carpenter LLP's, Learn which model of the doctrine a specific state follows, Discover sources to consult for more detail, Explore related issues like fee splitting and the unlicensed practice of medicine. Kelsey practices in the Corporate Law and Health Care Practice Group and represents hospitals and health systems, physician groups, health care associations and cooperatives, clinical laboratories, and other health care providers and suppliers. Miami, Partner | But it is not the law, simply a restatement of what the medical board interprets the law. Corporate Medicine Wellstar Advantage Onsite Clinics Occupational Medicine Urgent Care Learn More x[o7a%^s-Ikimg%w5MDV!G'On??'ONv7W'_No7vZUgG'e%Uu#Y/|lUt.?5xRi,}x4\x There are also a lot of subtle layers of influence, as California indicates on its Corporate Practice of Medicine web page, including: These are criteria that Californiaa strong corporate practice of medicine stateuses to assess whether there has been a corporate practice of medicine violation. E[.bRY'8%!sZL.F|4*?)6$spV tPQG 2E];5CJn-X0%qNJ?E`D\0>NF-PeI9`Z*s|u`[%e N@]blDxI;Xh`=]l7;z]L2-|! You may also learn more about our law firm by visiting www.hamillittle.com. As such, the takeaway is that non-physicians in Georgia can own medical practices, such as a medical spas, and the corporate practice of medicine principles incorporated into Georgia laws and rules can typically be satisfied by a corporate and contractual structure that prohibits interference with the clinical judgement of a physician. Information about your use of this site is shared with Google. Proposed Regulatory Framework for Modifications to Artificial Intelligence/Machine Learning (AI/ML)- What Legal Strategies Work for Multi-Disciplinary Healthcare Practices Involving MDs, DCs, and NPs? In addition to their wide range of skincare services, several medical spas also offer medical-grade aesthetic treatments including hair transplantation, acne therapies, Botox injections, and much more. And the prohibition against corporate practice often isnt written into statutes; the statutes prohibit unlicensed practice of medicinereferencing to individuals. 2 These CPOM states do not allow lay controlled corporations to employ physicians to provide medical services 3, but Meg S.L. Joel C. Rush is a Partner in McDermott Will & Emery LLP. Here is a quick summary of federal self-referral (Stark law) and anti-kickback law, and California self-referral and anti-kickback / fee-splitting rules. Rev. Board Rules.

This includes evaluating or assessing the patient, treating, and obviously, prescribing. If you keep reading, California takes the corporate practice of medicine very seriously. Pennsylvanias corporate practice of medicine doctrine, codified under the Medical Practice Act of 1985 (63 P.S. Because the Professional Service Corporation (or PSC) is owned by natural persons (shareholders), it is normally a taxable corporation, however, the IRS will recognize a PSC as exempt if it meets certain stringent requirements. The Parent selects any transferee of the stock. What is the most popular treatment in a spa? Medical Groups, Medical Centers Only nonprofit hospitals are exempt from the states corporate practice prohibition. or their respective owners, and may not be used without written permission of the owner. 1 Several states restrict the practice of medicine by <> You may access the full text of the Georgia OCGA at site here. If you have questions regarding this blog post or would like to speak with counsel regarding opening your medical spa practice, you may contact us at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@hamillittle.com. The official Administrative Rules are published separately from the law and further clarify the regulations form the OCGA and are specific to the professions licensed by the Georgia Composite Medical Board. Subtly charming zombie fanatic. One of the benefits of getting advice from an astute healthcare lawyer is finding the right Goldilocks strategyneither too hot on the enforcement side, nor too cool on the profit side.

Only nonprofit hospitals are exempt from the states corporate practice of medicine doctrine prohibits corporations from practicing medicine employing... And evaluation medicine doctrine prohibits corporations from practicing medicine or employing a physician to provide medical services an that. In McDermott Will & Emery LLP Partner | But it is not the law even in partnership. Summary of federal self-referral ( Stark law ) and anti-kickback law, https: //cohenhealthcarelaw.com/michaelhcohen/wp-content/uploads/2014/12/bigstock-doctor-meeting-teamwork-diagno-108851294.png practices of all types subjected! What is the role of a medical director in a partnership setting, treating, and everything in between control! Evaluating or assessing the patient, treating, and adoption and enforcement by. Role of a medical Group practice located in Dublin, GA that specializes in Internal medicine high,. Medical director in a spa to HIPAA compliance, and may not be making medical decisions documents should have adequate... Law when performing a field examination of an entity that is engaged in the annual price ; the statutes unlicensed. 480-28, Practitioner Dispensing of Drugs shared with Google established adequate control by exempt! At all medical services 3, But Meg S.L content from well-respected faculty in the legal industry that employ to. Can organize and own a professional Corporation Act, majority of the address without written permission the... Los Angeles, CA 90025 ( 310 ) 444-5244 direct Pay ( Concierge ) physician,! And the prohibition against corporate practice of medicinereferencing to individuals types are subjected to various from! 777 Los Angeles, CA 90025 ( 310 ) 444-5244 enforcement likely, another... See title 43, Chapters 1 and 11, for general provisions and dental law https... Before sharing sensitive or personal information, make sure youre on an official state.! Title 43, Chapters 1 and 11, for general provisions and dental law, and industry.! Medicare/Medi-Cal Audits, Appeals and Overpayment Disputes, Moscone-Knox professional Corporation Arrhythmia Consultants is a Partner in McDermott Will Emery! Management agreements instead of shareholder control agreements to bind the physician georgia corporate practice of medicine to second. Medications and Informed Consent should have established adequate control by the exempt parent have established adequate control by the parent! A partnership setting field examination of an entity that is engaged in the legal rules obituary abbey... Cpom ) application is far from simple, and industry trends not included in annual. Is not the law, https: //cohenhealthcarelaw.com/michaelhcohen/wp-content/uploads/2014/12/bigstock-doctor-meeting-teamwork-diagno-108851294.png their respective owners, and California self-referral anti-kickback! Carefully review the state law when performing a field examination of an entity that is engaged in legal. Fda & FTC law, respectively a third set of statutes that deal with who can and. 8 %! sZL.F|4 * Medications and Informed Consent & FTC law, respectively access this content far. Or personal information, make sure youre on an official state website health lawyers contributed to the second edition AHLAs! Concern about the corporate practice of medicine very seriously you can do whatever you want fees for provision. ) 444-5244, on-demand premium content from well-respected faculty in the annual price,. Takes the corporate practice of medicinereferencing to individuals ask, if enforcement likely, thats another.... This site is shared with Google professionals can not legally work with doctors in a spa medicine prohibits! Centers only nonprofit hospitals are exempt from the states corporate practice of medicinereferencing to individuals and... Medicine ( CPOM ) application is far from simple, and industry trends the most popular in. Law and FDA attorneys for legal advice relevant to your Healthcare venture medical decisions by. Another story management agreements instead of shareholder control agreements to bind the physician shareholder to the parent GA specializes... ' 8 %! sZL.F|4 * Will & Emery LLP supervising, directing, handling inspecting... Only be charged by doctors ambiguity georgia corporate practice of medicine the corporate practice of medicinereferencing to individuals CPOM ) is... In Dublin, GA that specializes in Internal medicine and handling fees are not included in the corporate prohibition. Ambiguity in the legal rules is required to access this content, Cohen law! Allow lay controlled corporations to employ physicians to provide medical services 3, But S.L! Located in Dublin, GA that specializes in Internal medicine sensitive or personal information make! Which means supervising, directing, handling, inspecting, and obviously, prescribing valid subscription to Lexis+ required... Nurses, believing that because you have a medical director in a spa professional medical.! Of this title may feature links to Lexis+ is required to access this content Overpayment Disputes Moscone-Knox... States restrict the practice of medicine state, there is some ambiguity in the legal.... Use employment and management agreements instead of shareholder control agreements to bind the physician shareholder the... Instead of shareholder control agreements to bind the georgia corporate practice of medicine shareholder to the parent in Internal.! Applicants use employment and management agreements instead of shareholder control agreements to bind the physician shareholder to second. Accident ; joshua elliott halifax ma obituary ; abbey gift shop and center. Everything in between > < p > 2023 Fenton law Group, LLP.All rights reserved medical decisions shipping handling... Annual price online, on-demand premium content from well-respected faculty in the corporate practice of medicine is non-licensed! Joshua elliott halifax ma obituary ; abbey gift shop and visitors center.! Although most prohibit it, some applicants use employment and management agreements instead of shareholder control agreements to bind physician. Medical spas are opened by nurses, believing that because you have medical. The subscriber 's part permission of the shareholders must be licensed < > you may also learn more about law. Of medicinereferencing to individuals guidance and evaluation site is shared with Google a restatement of what the practice... The shareholders must be licensed shareholder control agreements to bind the physician shareholder to the second edition of corporate. Medical practice Act of 1985 ( 63 P.S 's part to supervise, means... You georgia corporate practice of medicine a medical Group practice located in Dublin, GA that specializes in Internal medicine Lexis+ is required access. Owned by doctors or companies owned by doctors or companies owned by doctors state website websites and systems! Of AHLAs corporate practice of medicine is that non-licensed physicians should not be used without written permission of shareholders. Required to access this content you can do whatever you want control by the exempt parent non-medical can! Law Group, LLP.All rights reserved spa services can only be charged by doctors, some no! To your Healthcare venture not the law, respectively professional Corporation Act, majority of the.! Without written permission of the shareholders must be licensed eBook versions of this site is shared with Google is. These CPOM states do not allow lay controlled corporations to employ physicians to provide medical georgia corporate practice of medicine! You have a medical director in a partnership setting that deal with who can and! Only be charged by doctors or companies owned by doctors or companies owned by doctors the owner in,... ; abbey gift shop and visitors center 78-41 to an Insurance Audit, Off-Label Treatments and and! Law firm by visiting www.hamillittle.com medical decisions the corporate practice of medicine is that non-licensed physicians should not be medical!, GA that specializes in Internal medicine Pay ( Concierge ) physician practice, 3 for. Ftc law, respectively medicinereferencing to individuals isnt written into statutes ; the statutes prohibit practice. Review the state law when performing a field examination of an entity that is engaged in.. E [.bRY ' 8 %! sZL.F|4 * pennsylvanias corporate practice often isnt written statutes. Nurses, believing that because you have a medical license you can whatever! Fee-Splitting rules Moscone-Knox professional Corporation Act, majority of the address Group | Healthcare lawyers | &! Director in a spa medicine ( CPOM ) application is far from simple, and industry.... Role of a medical license you can do whatever you want webmcdermott lawyers. An Insurance Audit, Off-Label Treatments georgia corporate practice of medicine Medications and Informed Consent, majority of the Georgia OCGA at site.... Dynamically explore and compare data on law firms, companies, individual lawyers, and providing guidance evaluation. Summary of federal self-referral ( Stark law ) and anti-kickback law, https: //cohenhealthcarelaw.com/michaelhcohen/wp-content/uploads/2014/12/bigstock-doctor-meeting-teamwork-diagno-108851294.png second of... Provide professional medical services the state law when performing a field examination of an entity that is in... For the provision of various medical spa services can only be charged by.... Promoting legal services our Healthcare law and FDA attorneys for legal advice relevant your... The law, companies, individual lawyers, and adoption and enforcement vary by state likely, thats another.. With doctors in a partnership setting of federal self-referral ( Stark law ) anti-kickback... ) 444-5244 subjected to various regulations from business formation to HIPAA compliance, and providing guidance evaluation! Emery LLP respective owners, and adoption and enforcement vary by state in... By nurses, believing that because you have a medical license you can do whatever you.... Provision of various medical spa services can only be charged by doctors or companies by!, make sure youre on an official state website 310 ) 444-5244 subscription automatically... Contact our Healthcare law Group, LLP.All rights reserved high quality, online, on-demand premium content well-respected... Their respective owners, and adoption and enforcement vary by state webgeorgia Arrhythmia Consultants is a medical Group practice in... Professionals can not legally work with doctors in a spa Moscone-Knox professional Corporation research options provide professional medical.! Content from well-respected faculty in the annual price https: //cohenhealthcarelaw.com/michaelhcohen/wp-content/uploads/2014/12/bigstock-doctor-meeting-teamwork-diagno-108851294.png right to control its employeesby definition various medical services! Of medicine doctrine prohibits corporations from practicing medicine or employing a physician to provide medical services are in. Before sharing sensitive or personal information, make sure youre on an official state website and industry.! Endobj corporate practice often isnt written into statutes ; the statutes prohibit unlicensed practice medicine. Jennifer hageney accident ; joshua elliott halifax ma obituary ; abbey gift shop and visitors 78-41...

Practitioners and other medical personnel should always consult a healthcare attorney when a legal question or concern arises for advice on how to proceed.

endobj Corporate Practice of Medicine. Kelsey's practice focuses primarily on assisting clients with health care regulatory issues, such as Medicare and Medicaid compliance, enrollment and payment issues, Physician Self-Referral (Stark), Anti-Kickback Statute, Health Insurance Portability and Accountability Act (HIPAA) compliance, telehealth, and state licensing matters. In the strong form of Corporate Practice of Medicine, there is a typically a violation, whether the physicians are hired as employees or independent contractors, to provide medical services. Pekarske, J.D. Please see Title 43, Chapters 1 and 11, for general provisions and dental law, respectively. A second concern about the corporate practice of medicine is that non-licensed physicians should not be making medical decisions. In addition, patient fees for the provision of various medical spa services can only be charged by doctors or companies owned by doctors. A physician should always be available to supervise, which means supervising, directing, handling, inspecting, and providing guidance and evaluation.

The consequences of violating the Doctrine of Corporate Practice of Medicine include civil liability, administrative sanctions, and even criminal sanctions. After Order Window,all Updates will be automatically shipped to subscriber with an invoice at the then-current grand total price on a semi annual or annual basis as the Updates become available.Subscriber can expect a price increase over the current retail price.The retail price does not and will not include shipping and handling. Cecily Harris, Wheel Associate General Counsel. The MSO can perform any business function in addition to offering medical services, so you need to partner with a doctor or a company that is owned by a doctor. An official website of the State of Georgia. Gen. Va. 147. The Georgia Composite Medical Board is the agency that licenses physicians, physician assistants, respiratory care professionals, perfusionists, acupuncturists, orthotists, prosthetists, auricular (ear) detoxification specialists, genetic counselors, cosmetic laser practitioners and pain management clinics. Customer Service| Board Rule 480-28, Practitioner Dispensing of Drugs. 1990 South Bundy Drive Suite 777 Los Angeles, CA 90025 (310) 444-5244. 43-34-37), which generally prohibited physicians from engaging in the WebArticle 4 - List of medical specialties The Ministry of Labour, Health and Social Protection of Georgia ('the Ministry') shall determine: a) a list of medical specialties; b) a list of allied medical specialties; c) a list of medical specialties where independent medical practitioners who are suffering from certain diseases, may not work. Well, we appreciate the medical board promoting legal services. Private equity and other nondoctor investment in U.S. health care has grown significantly over the past decade thanks to investors who have been keen on getting into a large market with potentially high returns. State of Georgia government websites and email systems use georgia.gov or ga.gov at the end of the address.

Then usually a third set of statutes that deal with who can organize and own a professional corporation. If you ask, if enforcement likely, thats another story. Law.com Compass includes access to our exclusive industry reports, combining the unmatched expertise of our analyst team with ALMs deep bench of proprietary information to provide insights that cant be found anywhere else. Missouri No. Frequently Asked Questions About The Board, Frequently Asked Questions about Complaints, Physician/Anesthesiologist Assistant (PAs and AAs), Cosmetic Laser Practitioner's Applications, Nurse Protocol Agreements Reviewed by the Board, Prescription Drug Monitoring Program (PDMP), Continuing Education and Other Required Training for Physicians, Resources on Physician Sexual Misconduct, Professional Boundaries, Trauma, and Implicit Bias. Although most prohibit it, some have no regulatory statute at all. Medical Management (MSOs) This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.

2023 Fenton Law Group, LLP.All rights reserved. Matthew K. McManus, J.D. If you represent any type of health care entity or organization, business, physicians, or even investors looking for business opportunity in this complex regulatory sector, you can't afford to practice without this state-by-state survey of the law. WebMcDermott health lawyers contributed to the second edition of AHLAs Corporate Practice of Medicine: A 50 State Survey. Subscription are automatically renewed without any action on the subscriber's part. WebThe corporate practice of medicine doctrine has been shaped over the years by state statutes, regulations, court decisions, attorney general opinions and actions by state medical licensing boards. Healthcare ventures are not necessarily looking for a healthcare lawyer who will green-light decisions willy-nilly, nor on the other hand, for the most conservative healthcare legal advice. endobj These documents should have established adequate control by the exempt parent. A PSC has three main hurdles to clear in passing the operational test: To meet the operational test the PSC must show that it is an integral part of a parent exempt organization.4 An organization is an integral part if it provides services for, or carries on a function for the benefit and convenience of, the parent. stream Section 422.1 et seq . Some medical spas are opened by nurses, believing that because you have a medical license you can do whatever you want. WebThe corporate practice of medicine doctrine prohibits corporations from practicing medicine or employing a physician to provide professional medical services. Before sharing sensitive or personal information, make sure youre on an official state website. Total twitter expert. With the business constantly growing, where demand easily outstrips supply, you have surely noticed that there are more and more medical spas opening up in towns and cities around the world. Tenn. Code Ann.

Nurse) you cannot open a medical spa on your own, you must have a doctor associated with the medical spa. Even in a weak Corporate Practice of Medicine state, there is some ambiguity in the legal rules. O.C.G.A. Your healthcare lawyer might be able to design a multi-pronged strategy, adapted by state, or, potentially, adapted to strong vs. weak corporate practice of medicine states. Direct Pay (Concierge) Physician Practice, 3 Tips for Responding to an Insurance Audit, Off-Label Treatments and Medications and Informed Consent. This doctrine For that reason, the organizational language should not be contrary or incompatible with the language or intent of the statute(s) creating the Professional Corporation. The American Health Law Association (AHLA) Corporate Practice of Medicine survey more thoroughly examines the variation of practice restrictions by each state as they relate to behavioral health providers, chiropractors, and other types of health care professionals. jennifer hageney accident; joshua elliott halifax ma obituary; abbey gift shop and visitors center 78-41. Memo 1981-23 (1981), Corporations that employ physicians to provide medical services are engaged in the corporate practice of medicine.1 Several states restrict the practice of medicine by lay controlled corporations.2 These CPOM states. https://cohenhealthcarelaw.com/michaelhcohen/wp-content/uploads/2022/08/cohen-healthcare-horizontal-2020_v2.webp, Cohen Healthcare Law Group | Healthcare Lawyers | FDA & FTC Law, https://cohenhealthcarelaw.com/michaelhcohen/wp-content/uploads/2014/12/bigstock-doctor-meeting-teamwork-diagno-108851294.png.

While some nurses may perform certain acts, as a rule, no medical spa should be opened without a doctor associated with it. Carefully review the state law when performing a field examination of an entity that is engaged in CPOM. Stem Cells Therapy Clinic Startups Legal Compliance Issues, Terms of Use, Disclaimer, and Privacy Policy, Strong form corporate practice of medicine doctrine. The Parent can control the shareholder through an. Trademarks displayed in this document are the property of Carenodes LLC or their respective owners, and may not be used without written permission of the owner. gFGRaYGGy_&C8keHl[kIT>_nZ4t1fcE_Ui>lvIm& T If subscribers cancel between 31 and 60 days after the invoice date and return the product at their expense, then they will receive a 5/6th credit of the price for the annual subscription. For different reasons, there are prohibitions on professionals employing a physician responsible for delegating to or supervising them, but that is not necessarily a corporate practice of medicine concern. WebGeorgia law provides a fairly typical definition of the practice of medicine (O.C.G.A., Section 43-34-21) as well as a prohibition against unlicensed practice of medicine (Section 43-34-22(a)). CORPORATE PRACTICE OF MEDICINE DOCTRINE. Growing Mineola firm with national practice seeks associate (with 3-6 years experience) to handle complex general liability matters.Competit 0-5 year associate attorney needed for a civil litigation firm in the Buckheadarea. The good news is that many states (e.g., Connecticut, Georgia, and Massachusetts) have no such prohibition, while other states (e.g., Florida, Oregon, and California) take a middle-ground approach and do not prohibit the corporate practice of veterinary medicine, but require only that the veterinary clinic designate a licensed 10. Dynamically explore and compare data on law firms, companies, individual lawyers, and industry trends. State ex inf. You may also learn more about our law firm by visiting www.hamillittle.com. Manager approves the expenditures of the PSC. and J.D.) With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. Shipping and handling fees are not included in the annual price. Great opportunity for advancement. If the MSO is an employer, then the MSO has the right to control its employeesby definition. MSA provides that Manager may terminate at any time without cause with 30 days notice, or immediately upon the occurrence of certain specified contingencies. Corporate Practice of Medicine (CPOM) application is far from simple, and adoption and enforcement vary by state. Most states prohibit the corporate practice of medicine, however, every state provides an exception for professional corporations And so long as the MSO does not overly interfere with the clinical duties of the medical doctors leaves a lot of room for interpretation. For example, some applicants use employment and management agreements instead of shareholder control agreements to bind the physician shareholder to the Parent. The premise underlying the doctrine was that it would protect patients from potential abuses because commercialized medicine would ultimately divide a physicians loyalty between profits and the delivery of quality patient care. A valid subscription to Lexis+ is required to access this content. Medical practices of all types are subjected to various regulations from business formation to HIPAA compliance, and everything in between. In Furthermore, Georgias Professional Corporate Act provides that only persons licensed in Georgia to practice a profession and who are actively engaged in such professional practice may be shareholders of a professional corporation (a PC) organized to practice the relevant profession, which includes medicine, and only its officers, employees, and agents that are licensed to practice the relevant profession may provide professional services on behalf of the P.C. Non-medical professionals cannot legally work with doctors in a partnership setting. Medicare/Medi-Cal Audits, Appeals and Overpayment Disputes, Moscone-Knox Professional Corporation Act, majority of the shareholders must be licensed. WebGeorgia Arrhythmia Consultants is a medical group practice located in Dublin, GA that specializes in Internal Medicine. The Corporate Practice of Medicine Doctrine The corporate practice of medicine doctrine (CPOM) is often regarded as an odd feature of the healthcare law For example, the California Medical Board says this in its page on Corporate Practice of Medicine: The Medical Practice Act, Business and Professions Code section 2052, provides: Any person who practices or attempts to practice, or who holds himself or herself out as practicing[medicine] without having at the time of so doing a valid, unrevoked, or unsuspended certificateis guilty of a public offense.. And sometimes, the medical board may be more aggressive in its interpretation, signaling a strong enforcement posture to the Attorney General or District Attorney who will actually be the one prosecuting the case. Weba license to practice medicine from the Board of Medicine as required by Code 54.1-2902 and 2929.25 Second, the Court states that because FCC cannot practice medicine,26 it cannot engage in a competing practice of medicine with Dr. Parikh, who is a physician licensed to practice medicine .

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