Episode Transcript
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SPEAKER_00 (00:00):
Thank you.
SPEAKER_03 (00:27):
I want to begin by
thanking you for listening to
today's podcast.
The topic for today'sconversation is incredibly
timely, Medicare Advantage,Navigating in Certain Times.
Before we dive into today'sconversation, let's do a quick
round of introduction of today'sspeakers.
Christine, let's start with you.
SPEAKER_01 (00:47):
Great.
Thanks, Alan.
Hi, everyone.
My name is Christine Worthen.
I'm a healthcare regulatoryattorney.
with Epstein Becker Green in theWashington DC office.
My practice spans a few areas.
I represent providers, payers,digital health companies, and
investors.
(01:07):
as they navigate regulatory andbusiness challenges in the
continuously evolving healthcaredelivery and reimbursement
landscape.
I have a lot of experience withMedicare reimbursement, Medicare
Advantage, participation in CMSInnovation Center models,
managed Medicaid, managed carecontract negotiations, and
value-based payment arrangementsacross the spectrum, commercial,
(01:30):
self-insured, MedicareAdvantage.
and help folks with theregulatory, operational, and
financial considerations as theymaneuver through the changing
payment environment and variousforms of risk-based payment
models.
I also help with pricetransparency, revenue cycle
issues, payment integrity,value-based enterprise models,
(01:52):
risk adjustment, and providercompensation arrangements.
Great to be here.
SPEAKER_03 (02:00):
Thank you,
Christine.
SPEAKER_02 (02:02):
Joe, could you
introduce yourself?
Sure.
Thanks, Alan.
Hi, everyone.
My name is Joe Mangrum.
I am a partner at ECG ManagementConsultants.
ECG is a national consultingfirm.
We do a lot of the same types ofwork that other consulting firms
do, but what sets us apart is weonly operate in the healthcare
(02:24):
industry.
So anybody who is on anengagement from the consultant
level up to the partner level asextensive and vast experience in
healthcare.
And at the firm, I lead ourpayer practice.
So my clients are all healthplans, different sizes and
structures all across thecountry.
(02:46):
And like Christine, my team andI do a lot of different
initiatives, help with a lot ofdifferent issues for payers.
financial turnaround, strategy,process improvement, regulatory
issues.
But I would say the vastmajority of my work has been in
(03:06):
the government programs, MAspace.
So, you know, happy to be onthis podcast today.
As Alan said, a very timelytopic.
And what I hope to do here isprovide what I call a payer
perspective.
So maybe how health plans arethinking about the issues with
(03:27):
NMA and the upcoming changes andjust the forecast of what we're
going to be looking at for thenext few years.
So very happy to be here andlooking forward to the dialogue.
Thank you.
SPEAKER_03 (03:39):
Joe and Christine,
really appreciate those
introductions.
And let me provide a quickintroduction of myself.
I am Dr.
Alan Lassiter.
I'm a principal in ECG's PayerStrategy and Contracting
Division.
I provide strategic guidance tohealthcare systems, hospitals,
physician organizations,academic medical centers, and
private equity firms.
(03:59):
My practice focuses onvalue-based payment
arrangements, Medicare Advantageplans, CMS innovation models,
and Medicaid.
I've been privileged to leadboth provider and payer
organizations and use thoseinsights from those roles to
help organizations successfullynavigate the intricacies, and
they are intricacies, ofprovider-payer relationships.
(04:20):
And I will serve as moderatorfor today's conversation.
As we begin, let me provide somelevel setting for those
listening in.
As most of you know, MedicareAdvantage is one of the most
popular insurance programs forthe Medicare eligible
population.
In 2025, MA plans are projectedto cover a record setting 35.7
million people.
(04:41):
This represents 55% of allMedicare beneficiaries.
However, in spite of itspopularity, Medicare Advantage
is facing significant headwinds,and we read about those in the
news almost on a daily basis.
And those headwinds are fromboth payer and provider
organizations.
As but one example, a recentsurvey of CFOs by HFCA found
(05:03):
that 16% of healthcare systemsare planning to stop accepting
one or more MA plans in theConversely, several insurers
themselves, including such heavyhitters as Aetna, Humana,
WellCare, Cigna, and Blue CrossBlue Shield have made the
decision to exit targetedMedicare Advantage markets.
And of course, these decisionsare all going to have a
(05:25):
significant impact on patients.
those we are called to serve.
And as has already been teed upin today's conversations, we
will be discussing the currentstate of Medicare Advantage, the
complex issues confronting bothpayers and providers, and
strategies for successfullynavigating uncertain times.
Christine, I'd like to startwith you.
(05:46):
Let me begin with this question.
I'm really curious.
What are the biggest challengesproviders who participate in
inmate plans facing right now?
And how are their strategiesevolving in response?
SPEAKER_01 (06:00):
Great.
Thanks.
Happy to answer that.
I think, unsurprisingly, thebiggest challenges that the
providers are facing at presentis payment delays as well as
payment cuts.
In terms of strategy andadaptive strategies, providers
(06:20):
have been doing things, startingwith the basics, looking at the
contract language regarding thepayment terms and paying special
care to address things likeretrospective audits, prepayment
audits, and generally tighten upthe language with regard to both
informal and formal disputeresolution.
(06:41):
They're also paying moreattention to data or healthcare
providers can have variouscapabilities from very basic to
very advanced and understandingnow that really diving in and
looking at trends is extremelyimportant.
(07:02):
Some of the trends that we'vebeen looking at for clients and
helping them get their armsaround are trends in the two
midnight rule.
issues with prior authorization,and then payment audits, as well
as DRG downgrades.
And we have been looking at thefinal rule that was just issued
(07:23):
last week and have some moreclarity on that very issue with
regard to prior auths.
Also looking at the use of AI inutilization management.
whether and to what extenthumans are actually looking at
the medical record when issuingdenials.
The final rule that was justissued did not go as far as to
(07:44):
provide additional clarity onthe AI issue, but nevertheless,
that is something that's onproviders' mind and is something
that they're looking at andbuilding out trend
identification in that regard.
And then also looking at Otherthings in the contract have had
providers unbeknownst to them,their payment appendices exclude
(08:06):
things like dish payments and ofcourse addressing that.
And then making sure yourdispute resolution language is
clear so that you know exactlywhat you're doing and where
you're going, trying to get somesort of informal dispute
resolution process in placebefore you proceed to whatever
binding venue, be it arbitrationor court.
(08:29):
And then they're also looking atthe impacts of things, upticks
in medical records requests, andthen trends there, and then
trying to address that in thelanguage as well.
And again, looking at KPIs,conferring with the plans, and
(08:49):
generally just being moreproactive in their approach to
ensuring sustainablereimbursement.
SPEAKER_03 (08:58):
Thank you,
Christine.
Really, really insightful.
Joe, let's take that samequestion from the payer
perspective and let me justrephrase it or not rephrase it,
but let me articulate one moretime.
What are the biggest challengesMedicare Advantage plans are
facing right now and how arethey adapting their strategies
in response?
SPEAKER_02 (09:19):
Right now, MA plans
are dealing with several
pressures and all of themsimultaneously.
tightening margins due to CMS'srisk adjustment and rate
changes, increased regulatoryscrutiny, particularly around
marketing practices, and thenalso growing expectations for
(09:40):
supplemental benefits.
I think on top of that, ofcourse, the star ratings
volatility is causing majorrevenue swings for some of the
plans across the country.
I think to adapt, payers arereally doubling down on
analytics, improvingdocumentation and coding
accuracy, and then tighteningtheir medical cost management
(10:05):
strategies.
I think there's a lot ofreevaluating going on as far as
benefit packages.
You see plans prioritizing morecost-effective and high-value
supplemental offerings, and thenMore often than ever, we're
seeing a lot more emphasis onmember retention and experience
(10:27):
because really the bottom lineis that acquiring new members
has become more expensive andcomplex than we've seen in
recent history.
SPEAKER_03 (10:38):
Very helpful.
And let's continue thisconversation, but let's, Joe,
let me ask you to zoom in just alittle bit in light of the
challenges just mentioned.
And let's talk aboutprovider-sponsored plans.
How are provider-sponsored plansuniquely positioned to weather
the uncertainty in the MedicareAdvantage landscape?
Or are they?
SPEAKER_02 (11:01):
Yeah, one of my
favorite topics.
Provider-sponsored health plansdo have a key advantage.
They control both the financingand the delivery of care.
And that type of integrationallows them to manage medical
costs a lot more effectivelythrough aligned incentives,
through real-time carecoordination, and a lot better
(11:24):
use of population health data.
I also think that in a lot ofthese uncertain times that we're
facing, provider-sponsoredhealth plans can move a lot
faster.
They're more agile.
They can pivot their strategybased on clinical insight and
not just claims data, right?
(11:45):
So I also think back to themembership point that we talked
about earlier, they're seen asmore trustworthy by members and
that is particularly so in localor regional markets and that
helps with engagement andretention.
And I think as national payersadjust to the CMS changes that I
(12:05):
alluded to previously, Theprovider-sponsored plans can
really stand out by emphasizingtheir quality of care, local
roots, and tighter caremanagement.
SPEAKER_03 (12:19):
Great.
So Christine, how can providersstructure value-based
arrangements with MA plans toimprove quality, receive fair
payment, and mitigate risk?
For example, ACC coding audits,MLR targets, and others.
SPEAKER_01 (12:34):
So we've seen trends
evolve where providers can
partner for things like plannedresources.
A lot of times providers don'thave the team, people needed to
do certain things.
And so they're looking topartner with plans to assist
(12:55):
with efforts, as well asunderstand the value of the data
that they have to secureadequate reimbursement.
So for example, we know thatcomplete and accurate coding
benefits both the payer andprovider, especially as
providers look to betterunderstand their patients and
plan ahead, identifying thosehigh-risk, high-cost patients We
(13:18):
see that providers are stillreluctant to have two-way data
feeds, but one-way data forreporting on the provider side
is very helpful and reducesburdens such that you have an
ongoing data refresh, say on amonthly basis, then that reduces
the need to have to go back withchart chases and the like.
(13:43):
The other component isstandardization across the
plans.
Most of the payers that we workwith do base their value-based
reimbursement on the stars.
And so from the providerstandpoint, understanding what
those stars are, incorporatingstars into KPIs and strategic
(14:05):
planning, knowing what the cutpoints are, and making sure that
they're achievable.
And if you're seeing thatthey're not achievable, to make
sure that you have anopportunity to reopen and
adjust.
The whole theme is to share inthe savings.
When providers and payers in therelationships that we've seen
where they are actuallyflourishing, there is
(14:27):
collaboration in terms ofunderstanding that optimizing,
coding, data, all of that yieldsa higher pool from which they
can distribute savings.
SPEAKER_03 (14:43):
Thank you,
Christine.
Joe, I'm going to come back toyou here.
With increasing regulatoryscrutiny and shifting CMS
payment policies, what steps canMA plans take to maintain margin
while still delivering value tomembers?
And you began to address some ofthis, but could you just go a
little deeper here?
SPEAKER_02 (15:03):
Yeah, I completely
agree with everything Christine
said.
I think on the plan side, theplans need to get extremely
serious about their starstrategy.
And I think it used to be planswere serious about it, but they
looked at it more as a qualityindicator.
But now it needs to be looked atas a margin lever because really
(15:27):
every single measure impacts theplan's revenue.
And Beyond that, I think we'reseeing plans take a hard look at
their vendor ecosystem.
So much of STARS and riskadjustment has to do with that
vendor ecosystem, especiallyaround the supplemental
benefits, like I talked aboutbefore.
(15:48):
You have to ask, are you gettingthe value that we expect?
Looking at, obviously, UM, riskadjustment coding, prior auth
workflows, all those things needto be streamlined.
And then I think that in manycases, plans that are succeeding
in this new environment, they'reshifting towards value-based
(16:11):
partnerships with providers toshare the risk and rewards more
equally.
I just think, you know,Christine mentioned the
partnerships.
It really comes down to that,and it's going to be crucial
even more so coming up in thenext few years.
SPEAKER_03 (16:29):
Really appreciate
that.
Christine, coming back to you,what are provider trends in
dealing with UM issues such asdenials?
And you did mention the finalrule.
I just wanted to give you theopportunity to also go deeper on
that if you feel like this wouldbe a time to do so.
SPEAKER_01 (16:48):
Sure.
So as I previously noted, theproviders are really looking to
better manage their expectedreimbursement.
Bill charges, as we all know, islargely irrelevant.
Providers really need to payattention to what denial codes
they're seeing, for example, sothat they can identify things
that are true denials, patternsin those denials.
(17:11):
Are they seeing contractuals?
Are those contractuals properand in accordance with the
contract?
Are they seeing more technicaldenials?
And what does that mean from theperspective of appeals?
And pause there cannot...
cannot stress enough howimportant it is to ensure you're
following the appeals process tobe able to preserve rights in
(17:35):
the event that you are not ableto solve problems.
I think the final rule offersgreater clarity on things that
were addressed.
For example, in the 2024 CMS FAQthat was issued, I think it was
February 2024, when CMS wasaddressing issues like the two
(17:56):
midnight rule What does it mean?
Folks having some confusionabout the benchmark and
presumption.
And what does prior authissuance mean?
And when can you have areopening for issues that are
(18:17):
outlined in the regulations, forexample?
We know that providers makemedical decision-making based on
the patient at the time, andthen other things may come out
afterwards.
I think the final rule reallytakes that FAQ and puts it into
perspective so that folksunderstand that now this is part
of the regulations.
(18:40):
I think I see also providerspushing back on technical
denials where you have a endlessmedical records requests, it
seems.
And when is that appropriate?
And when is that going farbeyond what's needed and is
(19:00):
causing a real administrativeburden on the provider?
They're also making sure to payattention to denials for
previously authorized services,especially DRG downgrades, and
really understanding and readingthose denials and understanding
how to push back if they feelthat the denial is inappropriate
(19:24):
based on the receipt of a priorauthorization.
SPEAKER_03 (19:27):
Fantastic.
Let's continue this part of theconversation.
I'd like to pivot just a littlebit to the uncertainty in ACA
and Medicaid.
And so Christine, with thechallenges in regard to those
and with the uncertainty inregard to those, while this is
focused on MA reimbursement, ifyou have additional comments
(19:49):
regarding the ACA funding,Medicaid funding and things
along those lines, would you bewilling to provide your insight
into those issues?
SPEAKER_01 (19:59):
Sure.
I think fundamentally what theproviders with whom I've been
working are really taking aholistic look at the MA plans
with whom they are in networkand asking who is a good
partner?
What does it mean to be a goodpartner?
Where's reimbursement beingeroded?
Where's our expected allowed notbeing realized?
(20:22):
We negotiated a contract.
We think these are the rules ofthe road, but we're not getting
paid.
And what kind of resources doyou need as a provider in order
to be able to be successful?
For example, if you'venegotiated MLR targets and you
(20:42):
have certain things that youneed to do, do you have the
right resources to be able toaddress the things that you've
agreed to do in terms of qualitymonitoring, making sure patients
are getting in for their visits,coding capture, etc.?
UNKNOWN (00:00):
?
SPEAKER_01 (20:59):
Providers are also
taking a look at whether they
really need to be in networkwith every single plan.
I think you mentioned that,Alan, at the beginning.
More providers are now saying,You know, do we need to be a
network with every single one oftheir plans?
But what does it mean to be outof network?
And whether, if they do go outof network, are they going to
accept a patient on anout-of-network basis, aside, of
(21:21):
course, from their Intalaobligations?
So even going further to thinkthrough whether they would want
to even see patients on anout-of-network basis.
We know that sustainabilitymeans getting paid for medically
necessary services delivered andalso working with the payers who
want to pay for care inaccordance with the contract
(21:44):
versus having some of thesegotchas that we've seen when the
contract language they believemeans one thing, but in reality,
from an operational perspectiveand adjudication, it means
another.
We also see providers looking atmore opportunities with regional
payers, especially as we've seenwith the shift in markets, and
(22:06):
some of the regional payerspicking up some additional
lives.
I think that the ACA subsidies,what's going to happen, the
budgets and Medicaid, I thinkthat the providers ensuring that
they've got a you know, awell-laid plan for Medicare
(22:26):
Advantage so that they can gettheir arms around and get the
reimbursement to help to weatherthe storms, the inevitable
storms that are going tocontinue and the uncertainty
that we're facing.
People are being, providers arebeing more proactive than ever,
at least in my experience, withreally taking a hard look at the
(22:46):
MA plans.
SPEAKER_03 (22:48):
Fantastic.
So Joe, What trends are youseeing in how payers are
approaching network design,supplemental benefits, and
otherwise to stay competitive inMA?
SPEAKER_02 (23:02):
I think there's a
definite move towards narrower,
high-performing networks.
Plans are realizing that thistype of broad access that
they've usually focused on, itdoesn't always equal better
outcomes and, frankly, lowercosts either.
So instead, now what we'reseeing is a focus on steering
(23:25):
members towards preferredproviders who deliver the
results that they're lookingfor.
I think on the supplementalbenefits side, we've seen a
shift from quote unquote flashybenefits, ones that we have seen
over the past few years, likegym memberships, things like
that, towards more of the socialdeterminants of health type
(23:46):
oriented offerings.
You think of transportation,meal delivery, in home support.
I've even seen utilitiesassistance, but also have to
realize on the plan side,there's a lot more scrutiny now,
right?
CMS wants to see these benefitsused appropriately and then tie
them to an actual clinical need.
(24:07):
But I think the bottom line isthat plans are becoming more
sophisticated and evaluatingROI.
It's not just does this attractmembers, but does it improve
retention, satisfaction, andlong-term health?
Very helpful.
SPEAKER_03 (24:28):
Very helpful.
And let me move to the issue ofdata.
I know, Christine, you mentionedthis earlier in the
conversation, and this will be aquestion for both you,
Christine, and for you, Joe.
But what are the value driversof data to providers, Christine,
to payers, Joe, in terms ofKPIs, other metrics, EMR data?
(24:52):
And I'd love to know yourperspective on what role this
will play in the go forward.
And Christine, you mentioned AI.
Let's go a little bit deeper onthat since that seems to be a
significant topic of discoveryand discussion across all of
healthcare today.
So Christine, data.
SPEAKER_01 (25:09):
Sure.
The data strategy is fundamentalto success.
Successful providers arelearning to integrate clinical
and claims data.
They're understanding where tolook at incorporating AI tools
and understanding the ROIbecause there's a lot of things
that they've deployed and notreally understanding whether and
(25:31):
to what extent they're getting areturn on investment, but really
looking at the opportunities asthey pilot some of these
initiatives.
For example, we We already knowthat risk stratification for
low, medium, and high risk isone of those basic tools in the
toolkit in order to manage apatient population.
Now providers are looking tostratify based on other drivers,
(25:57):
such as behavioral health andsocial needs, integrating
behavioral health into a primarycare setting, looking at all
those additional care managementprograms that CMS has
implemented.
especially on the behavioralhealth side.
Social needs, things likehealthy food access and housing,
(26:18):
transportation, all of thesethings that help folks adhere to
things like chronic conditionmanagement and enable them to do
some of the things that theymight not otherwise be able to
because of their socialsituation.
I mentioned before, KPIs beingtied to STARS is one option.
(26:41):
But others are to look at yourcommunity health needs
assessment, if you are a healthsystem that has to do those, and
really looking at integratingyour Medicare Advantage
strategy, not only with theresults of your community health
needs assessment, but also othervalue-based efforts that you
might have underway.
Other initiatives that clientsare looking at is ED planning.
(27:03):
What is the emergency departmentplanning?
strategic plan of the future,given the aging population, the
ongoing trends and decreases instaffed beds, ensuring a
relationship between the patientand the care team.
That means getting a betterhandle on how patients access
care, which in turn can avoidthe avoidable, so to speak, and
(27:26):
improve patient engagement andsatisfaction.
And all of these help to drivesustainable reimbursement,
especially as you move to or youadvance within the risk models
as a provider.
And relationship building withpatients also helps in the event
you do need to terminate aMedicare Advantage plan.
(27:46):
As we know, Medicare Advantagepatients don't switch their
plans often.
So building that ongoing patientrelationship across the care
continuum is extremelyimportant.
And so the data can help toanchor the care delivery model.
It can inform what's workingwell and what's not working
well.
(28:07):
updates and measures.
For example, with the qualitymeasures being updated to
include readmissions, that meanstaking an opportunity to review
post-acute care patterns andaddress the issues, such as
delays in prior auths going toSNPs and your overall
relationship with post-acutecare providers, as well as your
(28:28):
service line and care settingplanning.
I think all of these help withand underscore the need for a
good data governance internally,both in terms of improving
patient care, patientrelationships, and hopefully
having a smoother process withthe plans with whom the
(28:49):
providers are in network andhopefully improving some of
those relationships there.
SPEAKER_03 (28:55):
Interesting,
immensely insightful.
And then Joe, what are the valuedrivers of data for payers?
SPEAKER_02 (29:07):
Yeah, data is an
incredibly strategic asset when
it comes to Medicare Advantageon the payer side.
Data underpins nearly everylever of financial and
operational performance.
So we think about on the revenueside, it drives performance.
accurate HCC risk adjustmentthat directly affects capitation
(29:29):
payments from CMS.
On the quality front, robustdata enables precise tracking of
star ratings measures, andthat's particularly HEDIS caps,
operational metrics.
It allows plans to close gapsproactively.
It's also central to medicalcost management, enabling
(29:50):
predictive modeling, populationsatisfaction, and targeted care
interventions.
When we think about it from thenetwork perspective, data really
supports the value-basedcontracting.
And that's just simply becauseit highlights provider level
performance variability.
And with all the increasedregulatory scrutiny that we've
(30:14):
talked about, maintaining clean,auditable data is really
essential for RAD-B audits.
It's essential for priorauthorization reporting and just
the general compliance that wethink about, particularly for
any of the more rigorous CMSaudits that we see yearly.
(30:36):
And then plans that canintegrate clinical and claims
data effectively, translate itinto actionable insights, that
they're the ones that are goingto have a significant advantage
in both margin preservation andultimately in member outcomes.
SPEAKER_03 (30:56):
Thank you so much.
Again, incredibly insightful andI'm sure that it's one of those
areas that we're all gonnacontinue to pursue.
It's gonna go further and deeperthan we have previously and
understanding both the payer andprovider perspective from the
data assets and how thoseintegrate and how they must
interrelate, I think will bevery helpful in the future and
having people that can help themactually navigate those issues
(31:19):
effectively.
It seems that we've juststarted, but we do need to
conclude today's conversation.
But let me just say this.
As we conclude today'sconversation, I want to thank
both of you, both you,Christine, and you, Joe, for a
rich and insightfulconversation.
We discussed Medicare Advantagefrom both the provider and payer
(31:40):
perspective.
Clearly, there is going to needto be ongoing integration and
alignment between the tworelationships that go further
and do not always end up into anadversarial position.
And you've outlined ways that wecan consider this and how we
might be able to move forward tobe effective.
Before we close, I would like toask both of you if you have any
(32:03):
final comments.
And with that, Christine, let mestart with you.
SPEAKER_01 (32:06):
Sure.
Thanks, Alan.
I think it's certainly anexciting time to be involved in
the Medicare Advantage spacewith lots of things going on,
lots of opportunities forproviders, whether in terms of
(32:27):
You know, optimizing currentstrategies, planning for the
future, kind of rethinking thewhole way of looking at
reimbursement and provider-payerrelations.
Of course, not You don't alwayshave to look at the relationship
as it's going straight to andout of network.
I think there are lots ofopportunities to improve the
(32:50):
relationship and collaborateand, of course, takes effort on
both sides.
And I think there's a lot ofopportunity there.
Also, just like to mention, aswe're on the topic of
collaboration.
Medicare Advantage that I am oneof the vice chairs of the Payers
Plans and Managed Care PracticeGroup at AHLA.
And that is a forum wherethere's lots of rich content and
(33:16):
opportunities for learning.
So to the extent anyone in theaudience is interested in being
a member of that practice group,it's impartial.
It's a good one.
Thanks, Alan.
SPEAKER_03 (33:28):
Joe?
SPEAKER_02 (33:31):
Yeah, I think at the
end of the day, success in MA is
all about alignment.
We think about alignment betweenpayers and providers and then
between financial goals andpatient outcomes.
And I think that's been apparentduring this conversation.
A lot of what Christine and Iboth said from both different
perspectives overlaps andaligns.
(33:53):
And it's important that we keepthat in mind.
I think the more we collaborate,share data and build
relationships, trust-basedcontracts, then the better we'll
all navigate this uncertaintyahead and most importantly,
deliver better care for ourmembers and patients.
So thanks for your time today.
(34:14):
It's been a great conversation.
Yes.
SPEAKER_03 (34:17):
And with that, thank
you again to both of you.
We'll conclude today's podcastand thank you to those who are
listening for taking time tolisten in.
SPEAKER_00 (34:31):
Thank you for
listening.
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