Surviving a DEA Audit | Natalia Mazina, Attorney, RxPolicy

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Mike Koelzer, Host: gonna tell you for those who haven't come across you online, introduce yourself and tell our listeners what we're talking about today. 

Natalia Mazina, Attorney: I'm Natalia Mazina. I'm a pharmacy attorney. And for the last 10 years I've been working almost exclusively with pharmacies, um, representing them in regulatory compliance, disciplinary matters, PBM audits, litigation.

It's very challenging. Very interesting. Um, pharmacists are very, very pleasant to work with as 

Mike Koelzer, Host: well. I guess you could argue that pharmacists have this too, that nobody stops by the pharmacy just to say, Hey, I'm doing great. Just wanted to stop by and say, thanks for all your help and so on. I mean, in your position, your first phone call with these pharmacists, you must pick up and say hello, and they must go on like a 10 minute bitch session about.

They're problems. Does that get depressing? I mean, you say pharmacists are pleasant and I know that's what you get paid for, but that's gotta be a pain in the ass to hear those kinds of complaints every day. No, 

Natalia Mazina, Attorney: I am absolutely honest saying that I love working with pharmacists because, uh, I come across physicians, uh, very often as well, nurse practitioners and believe me working with physicians versus pharmacists is very different.

And I don't know why. And of course, I don't want to stereotype anybody, but pharmacists are usually much more respectful, much more pleasant to work with. And, um, and they listen, they, they really listen and they respect what you do and hardly ever I pick up the phone and they just start, you know, throwing out everything what's going on with 

Mike Koelzer, Host: pharmacy.

Why would physicians be worse? 

Natalia Mazina, Attorney: I don't know. I think maybe it also, um, reflects that pharmacists work with patients more. Um, I mean, they're like customer service very often. They have to be pleasant. They have to be respectful to listen, usually more. So I'll give you an example. I had a newer surgeon, uh, as a client once and, um, the guy with tons of education, you know, millions of dollars a year, he makes, um, and every time I give him advice and say, you know, we need to do this.

Uh, it was an administrative action, actually. Um, he will say, no, I know better. We're gonna do it this way. Mm-hmm um, I do not think this is the right approach. And I will be like, well, you pay me money for giving you professional legal advice, but you know, everything. So, and hardly ever I'm the pharmacist.

Who's telling me what to 

Mike Koelzer, Host: do a community Pharmacy. Maybe trying to please more people throughout the day than the average surgeon. I mean, the person's asleep when they're seeing the surgeon. So they probably just don't , it's kinda like their way goes, right? Yeah. 

Natalia Mazina, Attorney: I think that more social pharmacists.

Yeah. Versus somebody's who's working has five minutes per patient not listening to the patient, looking at the chart prescribing go, you know, and they didn't really interact with patients versus pharmacists who have this hands on approach, uh, approach to, to customer care. , 

Mike Koelzer, Host: I'm in a little bit of a fight with a wholesaler.

So I've got this attorney that I'm working with. And sometimes I don't like getting a call from him because I feel bad if I don't take his advice. I know I'm paying for the advice and a lot. And I kind of feel like I should, but it's just advice. It's not gospel truth all the time. So that's gotta be.

Kind of strange, I suppose you should get maybe a little fight back from your clients, but you don't want a lot, at some point you would just say, ah, just go do your own damn thing. If you're not gonna take any of my advice. 

Natalia Mazina, Attorney: Well, it depends what kind of advice they're seeking. So if we have, for example, a federal investigation, I probably know better which route to go, but if they ask me about potential buyers of their pharmacy, they are probably in a better position to understand their business and to take this offer, not to take this offer.

And I of course cannot advise them realistically in business terms, but from a legal perspective, I can tell 'em we know this transaction will be very expensive or, you know, we're gonna come across these hurdles during this transaction. Yeah. Versus if we are dealing with the government, they probably should listen to what I say or any other attorney, because yeah, we deal with the government on, I at least deal with them on, on a daily basis.

And I know what they want. I know their strategies, I know their procedure and it's not gonna be very wise if my client will just ignore my advice. It 

Mike Koelzer, Host: kind of makes me nervous thinking about dealing with the government. But I guess a lot of people deal with the government when it comes to parking tickets or speeding tickets, or not that I deal with them.

That's my wife, but no, I'm just, [00:05:00] lucky you . But I suppose we're always dealing with the government, but when it comes to dealing with the government, as far as the DEA and those kinds of things, they've got all this power and you said pharmacists are pleasant when they come to you. But I imagine I'd get kinda freaked out when I had to deal with the government at those kinds of levels.

Natalia Mazina, Attorney: Yeah. Yeah, they do freak out. They, they, they are nervous. Um, and it's understandable. A typical da audit involves several da agents. They're not very nice. They come armed. Usually they are very skeptical. They interrogate people armed with guns. You mean? Yeah. Yeah. Usually they come armed. That's at least what I hear from my clients.

Um, and I think they come armed when there is a reasonable suspicion of that. Something is going on in the pharmacy. Um, that's a lot of stress, especially if they do have a reasonable suspicion that fraudulent or illegal activities are taking place. Very often, they came, they came with the FBI as well. Hmm. And these people, even, more pleasant to 

Mike Koelzer, Host: work with.

And they've got their dark blue windbreakers on with their big yellow lettering and stuff like that on there. That's gotta be intimidating. 

Natalia Mazina, Attorney: It's very intimidating on 

Mike Koelzer, Host: purpose. They make it that intimidating, right? Yeah. Cause they wanna let you know who's boss right up front. 

Natalia Mazina, Attorney: Well, we can understand, you know, sometimes they have to deal with a lot of crap too.

Um, what very often they do routine. And given all this attitude, um, unnecessary, in my opinion, unnecessary. And they scare everybody, especially technicians. So people, uh, who are just still doing their work, who, not owners of the pharmacy, um, they close them some similar separate. They interview them separately.

They take their phones, they go through their personal belongings and they cry sometimes. And they're calling me saying, what am I supposed to be doing? I'm like, just, just wait, don't talk. You don't have to talk. Um, and the law they're supposed to review certain records. Yes. But they are not entitled to interview anybody.

So you don't really have to talk. So it could be very, very stressful. And what I've seen, um, is that very often when they're pressured like that, pharmacy staff make all kinds of admissions and that's when it becomes very dangerous. Hmm. 

Mike Koelzer, Host: Well, And I imagine that most people that are calling you don't have your information.

I mean, if they're repeat customers, but most of 'em that are calling you freaked out the first time. It's not like the agents come in and 30 seconds later, they're on the phone with you. They've already sat down for 24 hours and have been slapped silly by the DEA and the feds. A lot of people, when they get nervous, they just start babbling talking, talking, 

Natalia Mazina, Attorney: they start talking and guess who's paying attention and noting everything down.

Mike Koelzer, Host: They are yep. Listeners today to this show who hopefully never think they're gonna have to talk to you. That's probably pretty darn good advice, right? Just to shut their, ya 

just 

Natalia Mazina, Attorney: don't talk. Yes. Uh, especially if they come in with a warrant, so it's not a routine audit and especially if it's a rest warrant and I have cases like that when they come off the bat with an arrest warrant, people try to explain.

And a lot of pharmacists they're naive. They say, because they're so focused on patient care and they're very often not involved in the business aspect. And they will be, uh, saying, well, I have nothing to hide this, all my records. This is what I do. There's nothing wrong. Why should I call an attorney? Why should I even discuss this issue?

And you are right. Usually I come in, not during the first 20 seconds of interaction. I come when we have a whole pile of mess. Maybe like a few days later when my client has some sort of a subpoena to come for an interview with a department of just something like that. So very often I come much, much later.

And that could be, of course it's more difficult to deal with the case at that stage when they already got all the evidence lined up all the prosecution and, um, it's more difficult to dismiss the whole thing 

Mike Koelzer, Host: I've heard, you know, don't talk to people till your attorney's president. So on, it seems like some of those things that a pharmacist would say, like, I'm innocent, I haven't done anything wrong.

[00:10:00] Those kinds of things. Can those get someone in trouble? Just like the opening comments like that, part of me wants to say no, because almost everybody's gonna say stuff like that. Is there damage? Opening up your mouth that 

Natalia Mazina, Attorney: much? No. So what I suggest, um, always value the situation. If they come in with an arrest warrant, do not open your mouth.

because they've given you Miranda the warning, they're saying you have a ride to call your counsel LA LA blah. So we'll call your counsel take advantage of that because this is arrest 

Mike Koelzer, Host: and an arrest means they're taking you. 

Natalia Mazina, Attorney: Yes. Yes. Well, the first, my interview for the first, my get the, I had, for example, a recent FBI audit that they came with two warrants, search warrant and arrest warrant.

Um, so that was a little bit tricky. Um, and the client actually didn't. Have an idea there was an arrest warrant. Um, maybe they said it, maybe they didn't, but a client didn't understand that. Um, so always evaluate the situation. So if this is, let's say, um, DA's coming to the pharmacy and this is a routine audit, for example.

Of course you don't wanna tell them, you know, well, some people do that and I can't really say if it's wise or not, they say, you know, I need to call my attorney and talk to them if you can. Well, the DA has the power to, to audit premises. Um, and again, it could be a good tactic depending on what's going on in the pharmacy to tell them, no, I'm not gonna allow you to come in.

I'm my, my attorney will be here. Maybe that could be just. If it's a regular pharmacy, everything is fine. They have a good compliance program and there's an upcoming audit. It's always good to establish. This is a local da guys. Uh, most likely they are renewing your registration. You are dealing with them.

If they have questions, things like that. So you want to establish a relationship with them. You want to show them what they are entitled to. Uh, you don't want to talk too much though. You don't want to explain every single thing and answer questions, which are not asked. Uh, but, uh, it, it depends if they start digging, for example, I'll give you, uh, an example of my recent case.

I have. I actually have it right now. Um, uh, the day came to this pharmacy, um, topnotch compliance, everything is good. Um, and they came based on a, uh, investigation of, uh, a prescriber. It was a doctor who was implicating this illegal prescription writing. And some of the patients filled prescriptions at this pharmacy.

And for some reason, the pharmacist did not flag those patients. So when the day came and they said, you know, this doctor is a restaurant now. Um, so I knew of filling his script. So the pharmacy, uh, the pharmacy staff actually was so scared that they started making all kinds of admissions saying, well, we, we thought there was something wrong.

We thought there was something sufficient. There was this suspicion, but we'll do a better, better job. Next time. We'll do much better in the future. It doesn't, the day doesn't, it doesn't care if you're gonna do a better job in the future. They got this admission. And then we got to the pharmacy a few weeks later, a letter from the department of justice saying, okay, based on this admission, uh, you filled this, uh, pres violate corresponding responsibility.

And if they violate corresponding responsibility, uh, a fine monetary penalties, um, 64,000 per occurrence. And there were, I think, 12 prescriptions. So something like that. So it was almost close to a million. um, and I got involved and we started talking to the AA that's a federal attorney. Um, and I'm like, look, they ran, ran PDMP reports.

They did absolutely everything. This patient's been a patient with the Pharmac for many, many years. We don't know what's happening with the doctor, but this is legitimate, and this attorney, he is armed with admissions. He's like your staff said, we saw there was something wrong with them, but we just didn't call the prescriber very far.

And I'm like, why did you guys say it? But they're like, well, we, we, we just wanted to cooperate. So right. That's how dangerous it could be talking too much if the day. Um, you know, these prescriptions are illegitimate. Just don't say anything, don't argue with 'em like you, you will have your chance to argue later.

You are entitled to show evidence to them saying, no, this is, you know, a patient profile. This is PDMP reports. We're in, this is our call. These are our notes, but don't argue with him saying, oh, you are so right. You know? Yeah. I shouldn't have filled it. That's just not a good approach. 

Mike Koelzer, Host: People just do that as a way to, um, yeah.

Natalia Mazina, Attorney: Compromise. They're 

Mike Koelzer, Host: trying to compromise, [00:15:00] compromise, you know, like in a conversation like a, you know, customers come in and they say, I'm so upset. And my wife hates when I do this mirroring on her, but you know, with a customer you're like, well, I understand you're upset, you know? And I can see why you'd be upset and things like that.

But when the DEA comes in, don't mirror them. When they say, we think there's a problem here. Don't say yeah. I can understand why you think there's a problem. Don't do that with them. Mm-hmm 

Natalia Mazina, Attorney: yeah. Yeah. I agree. And um, some da, uh, agents, they could be even nice. I'm saying it's with quotes, but some of them do want to work with you.

I've had very nasty audits and I had very educational audits when they pointed out what could have been done better. And that was the end of it. I did have audits like that. So again, I don't wanna. Scare the hell out of everybody saying, well, if the day comes and we have to call an attorney, we have to hide everything.

No, it depends again. Um, if, especially you might know the da agents from prior interactions and you know, the style, but you have to be careful, always, always about what you say 

Mike Koelzer, Host: as far as their demeanor, when they come in. It's surprising. I don't think a lot of professions spend a lot of time on stuff.

For example, I don't know how much time is spent with the police force on how to inform someone that someone has died. I don't know if enough time is spent with surgeons, how to talk about bad news. Maybe they do. And maybe it's better now, but it seems almost cliche that in the past you would hear that, well, they don't have any training on that.

They just have never had it. But I'm wondering with these audits, I'm wondering if these companies tell them what their demeanor should be, you know, because some come in so nasty even like PBM audits and some come in very friendly. And I wonder if they give them that choice or even tell them how to do that, or if it's all just the personality of the.

Natalia Mazina, Attorney: So when we talk about PBM audits, I don't know exactly how they're training the auditors. I don't, I really don't think they talk about demeanor and whether to be nice or mean the purpose is just to collect as much information as possible. It's usually done even remotely, usually. So, but when we talk about DA agents, um, I have a very good friend.

He's a special agent in charge, um, in one of the divisions. Um, and I talk to him about him, like why are you guys so mean? They, they just play mean, are they like, mean like that in everyday life? I mean, too bad for their families. He's like, are they like this at home? Yeah, he says, no. So usually, um, There is this power training, um, special and they're trained to deal with bad guys, real bad guys.

Right? So when they come to quote good pharmacies, I don't think there's such a good, good, bad pharmacy, but people who are not in trouble, they still use the same tactics because that's how they train. This is what we're supposed to be doing. But they actually train to deal with illegal activities, not with record keeping issues.

And they just don't know how to deal with record keeping issues. They don't separate in their head. Yeah. Yeah. And very often they use this Curion to, to, I, I had so many cases when the pharmacist surrendered the permit voluntarily on the premise. . And when I look at the case, I'm like, she just had record keeping issues.

Come on. We could have dismissed the whole case, maybe paid something, um, not significant. Uh, and they surrender the registration because the DA says, you know, you did so many legal activities and if you don't cooperate well, we'll C you with subversion of investigation, things like those who are in corporations.

And they're scared. They're like, I don't need this anymore. I don't need anything. I don't sign anything just to make you go away. 

Mike Koelzer, Host: Yeah. A lot of people probably have come from different childhood backgrounds, maybe an abusive parent or something like that, or an overbearing parent or something where they'll bow down to any authority just to get them to stop that pressure.

Even if they looked 10 minutes later after they left. And they said, I just gave away my pharmacy license or something like that. . 

Natalia Mazina, Attorney: Yeah, they're just scared. They're just scared. Yeah. They're really scared. I think it's, uh, this even physical fear. Think about this. You are, you know, you're in the middle of your work.

You're doing your daily activities and somebody comes, not just somebody I had, uh, a few years ago, it was so funny. My client called me and he had this tiniest, tiniest pharmacy tiniest, and there were 10 agents on the pharmacist. Wow. I mean, they couldn't even stand there. comfortably. And imagine these 10 big guys with guns in uniform, come in and [00:20:00] say, we have a tip that there's something illegal going on here.

Uh, shut down your business, uh, right now for the day, at least. He closes the door. He says, now he thinks, okay, that's it. They're gonna take me to prison or something. I mean, this is just a physical fear. Sure. You know, psychologists tell us, and if we are, if we are confronted with a group and we are by ourselves, that's why we have this public speaking fear because we are confronting the whole group.

And we are afraid it's in our G um, to be afraid of the group, which is kind, which is on the other side, 

Mike Koelzer, Host: I just told my wife yesterday, we were driving home from being up north. And I said, you know, Margaret, almost all of the pain that I have felt in life has been mental pain and has been being too nervous about things.

And then trying to look in every direction, something could go and then getting all tense up from that and not liking that feeling. And so on. Almost all of my pain has been from being nervous. And she said, oh, I'm sorry about that. And it's like, No, actually, it's a good thing because I can kind of put all of that into a ball and say, there's all my pain in life has been just in my head.

But the point I'm making is with all those DEA agents there with guns and all the things people have seen about let's even leave out any brutality. Let's just say, getting handcuffs put on and maybe pushed this way and pushed in the car and things like that. That's like a physical thing. Not many people get physically scared, but to your point, that's a physical thing to be afraid of with all of that power in there.

Natalia Mazina, Attorney: Yep. Yep. It's very stressful. It's very stressful. I had that client. She's a very good friend of mine. She we've been with her for, I don't know, since day one of my practice and somebody, um, I think we, we think is a competitor, um, called actually FBI and complained that she actually faking wholesaling voices and they presented some sort of tape conversation as evidence as we learned later.

So they came to her house in the morning to arrest her. She was feeding her child. Who's like seven years old. They budged in, they handcuffed her, you know, the child is screaming. She doesn't even know what this is all about. And they arrested her. We got her out the same day, but imagine how stressful that is.

And she's a pharmacist. She is not some drug dealer or anything like that. That just makes me so mad. So unnecessary. And there's all our money. You know, we are spending money for this unnecessary case and I understand the agents, you know, sometimes it's difficult to understand who is really doing something criminal and who is actually, maybe there's an oversight or record CIA.

Maybe there is nothing. So very often they don't do enough due diligence. Mm-hmm to understand, is this really a pill mill? Is this really something fraudulent going on? So they don't do this homework very, 

Mike Koelzer, Host: very often. So you're sitting there at work one day, God forbid, you're sitting there and. Six people bust through your door, you know, and they've got, like I say, they're blue wind jackets on and, and they've got the initials, either the DEA or the FBI, is there a chance in a pharmacy you're gonna see both of those.

And what's the difference as far as what each of those different groups would be there 

Natalia Mazina, Attorney: for? Yes, you can have both of them. So it's not very usual. So what usually happens is the day comes with a board of pharmacy. So they don't usually come with the FBI unless there is some indictment, uh, or there is something serious going on that they already have enough evidence to involve the FBI.

Yeah. So the DA is different from the FBI. The FBI will be dealing with any fraud. and da will be dealing with control 

Mike Koelzer, Host: substance fraud in the terms of financial fraud usually. 

Natalia Mazina, Attorney: No, no, no. Oh, it could be, but I don't do financial fraud. So I can't talk about this, but usually let me give you an example. So some PBMs are notorious for referring cases to OIGs, the federal department to the, to the same.

We think there's criminal activity going on. For example, I had a Caremark audit and an issue was waiver of copays. So the pharmacy was waiving copays for Medicare patients. Um, and actually we had good defense as well, but still they flagged this issue. They referred the case to the federal government, uh, and the FBI came in, so this is healthcare fraud.

Um, so that could justify the FBI coming in. If, um, we are talking about if, if the issues [00:25:00] are crossed, we're talking about controlled substances and building fraud at the same time these guys are likely to come in together. 

Mike Koelzer, Host: When you say fraud, then I guess that reminded me. Yes. Besides just financial fraud, there's billing kickbacks and things like that.

Natalia Mazina, Attorney: Right? So fraud, uh, waste and abuse in healthcare. That's paying kickbacks. Uh, kickbacks could be, um, paying to your marketer, a commission and your marketer is not your employee. It's a market at 10: 99. You pay him $20 per patient. He brings in, or you pay him 10% of your revenues. So that's one type of kickback.

Another kickback is if you pay something to the patient that is not, not necessarily as a payment, it could be free service, waiving, copay, or similar. That's not the kickback, it's a criminal statute. So potentially we are talking about criminal investigation. That's the FBI. 

Mike Koelzer, Host: One of my team members was complaining about how these Medicare plans seemed to be given copay discounts, but I didn't think they were supposed to do that.

I thought that was kind of a kickback thing. 

Natalia Mazina, Attorney: As long as they, this reduction or copay assistance does not involve Medicare, Medicaid patients it does not fit with an anti back statute. So the anti-back statute on the federal level applies only to any government sponsored program, Medicare, Medicaid, Tricare, and so on.

So you should not apply for any coupons or, uh, waiver reduction or anything like that for government sponsored patients. Every state has anti kickback state laws as well in California. For example, it's more punitive. It's anybody, third plans, cash patients, but on a federal level is only Medicaid.

Medicare, 

Mike Koelzer, Host: what actions in a pharmacy. Whether DEA actions or FBI actions, what actions more than likely is a pharmacist gonna end up in prison for there's different attorneys and different judges and all that. But what's something that you can say more than likely a person who does this is probably gonna go to prison for some time, 

Natalia Mazina, Attorney: any fraud and fraud, uh, implicates intention.

So if it's an oversight, if it's record keeping, they could put, try to label as a criminal investigation, but chances are, you have good defense, but if you do intend to violate the law, um, and if you do commit fraud, um, that's very likely to have some sort of, and if you're caught, of course, that's very likely to cause some sort of a criminal implications.

Mike Koelzer, Host: Ignorance of the law, especially when people have to get fraud, waste and abuse training is not an excuse. Right, right, 

Natalia Mazina, Attorney: right, right. But very often, if you can show that this was an oversight, uh, I mean, usually criminal cases, it's obvious to laypeople. I mean, something is going on. They will look at the case and, um, and again, it's very, very difficult to define it, but I'll give you an example.

So, uh, in one of my cases, um, the pharmacy was, um, uh, undergoing a PBM audit and PBM identified drug shortages. Uh, they did invoice reconciliation. They didn't have enough purchases. So to remedy this, the pharmacy owner, uh, conspired with a wholesaler and they presented fake invoices. I mean, what do you think, is it a criminal case or is it the record keeping issue or oversight?

I think that's pretty straightforward fraud. So the person is in jail right now, actually in prison. And it's an older gentleman and it's difficult. Uh, but he decided to do that. Um, and, uh, he was caught, uh, on the other hand, if, for example, you, um, uh, feel controlled substances, uh, ignoring red flags. Some of the red flags.

Let's not say it was just like a pill mill, but you were doing your due diligence, but you missed some red flags. There is a law that you have to, um, exercise, correspond responsibility, but you don't, let's say so. That's already a gray area case. You have to prove that there was no really bla ignorance of law.

This is, you know, you did some steps, but you ignored some of them and you corrected, you know, your behavior going forward. So you have much better chances for the [00:30:00] case, just to end up with monetary penalties. 

Mike Koelzer, Host: I imagine because you're fighting on the side of the pharmacist, that you would have a lot of these examples, but do any cases come to mind where someone actually went to prison and you say to yourself, and maybe you think most of your peers would say that doesn't make any sense.

Natalia Mazina, Attorney: no. If somebody goes to prison, usually in, in healthcare fraud context, that's usually there was really something 

Mike Koelzer, Host: going on. Someone who is in prison is there because they intended to do fraud. Yep. And almost everybody would agree that person's guilty. Now maybe the term of their punishment, someone could argue, but they're not there by chance.

They're there because it's proven fraud and nearly everybody would agree upon it. 

Natalia Mazina, Attorney: Yeah. Cause remember, um, to go to prison, you have to go through a trial and if you are, you have good healthcare fraud, criminal attorney, um, if there are any defense, they'll bring it up. Of course. Anything possible witnesses, anything you will have your.

To argue your case. And if there is any doubt, uh, I don't, I've never had anybody who didn't really commit the crime who actually went to prison. Yeah. So my cases that did end up in prison usually were pretty, pretty serious, 

Mike Koelzer, Host: obvious intent, pretty serious. There's not a chance of anybody sitting there as an innocent soul in prison from pharmacy.

Right. 

Natalia Mazina, Attorney: But on the other hand, I had cases which did not end up with prison or criminal sentences, but end up for example, losing business and justifiably. So when somebody didn't do anything really, especially with the PBM audit, Or some sort of monetary penalties imposed by the government. They lost their business and that was completely unjustified.

It could have been oversight could have been some mistake, uh, might have been some delegation, uh, unwise, delegation of duty, something like 

Mike Koelzer, Host: that. And in most of those cases, their business is gone because the financial punishment was so big or recoupment. It wasn't necessarily, they just lost their license.

Natalia Mazina, Attorney: Yeah. So usually, uh, what I'm thinking is PBM audits when they terminate pharmacies and, uh, ODA, when they impose their, have the penalties monitor 

Mike Koelzer, Host: penalties, I've heard it with PBM audits and I'm thinking this is true. The more I'm talking to you, the more PBMs. I like to say it in a negative context, they like to snitch on their pharmacies and tell the government about you.

So even if it's a small monetary recoupment, it behooves the pharmacist to put up a fight and to show the paper trail of that fight, which might slow down the PBM from giving this to the government. If they know there's at least a decent argument behind it, would that be good advice? 

Natalia Mazina, Attorney: So, first of all, I don't think PBMs refer cases to the government in every instance, when they identify something shady because the government is not going to be involved.

If it's not justified. They don't want to waste their time. So PBMs need to show some sort of pattern of Rondo. If it's just not something really, really nominal or does not justify federal time, most likely they will not send the case. Um, and they don't do it all the time. Uh, only when they do think that this is a pretty serious case, but I do agree with you that every time you get a notice from PBM, you need to take it seriously.

So the audit results and they identify some drug shortages. Let's say they identify some patients, Deni, that they received prescriptions from the prescriber, the night that they wrote this prescription and the pharmacist gets these, you know, results and says, you know, this is, they can charge back. That's fine.

I don't care. It's just a few thousand dollars. I'm not gonna spend, you know, money on the attorney's fees or my time and disputing this. They can take it, but that's not a very wise approach because they flag your pharmacist pharmacy. So, okay. Some patients deny they receive medication. That means you build, but you do not deliver, that's fraud.

Okay. Some prescribers deny that they wrote scripts that's fraud. Where do you dispense? [00:35:00] Not based on a valid prescription, that means drug shortages, maybe you bought medication on black market, or maybe you just didn't dispense anything. So you should, even if it's a nominal amount and it doesn't seem like it's a series or big deal, you should respond and you should have, uh, reach out to these patients who denied getting the medication, get their statements, if possible, reach out to prescriber, get their statements, why they denied.

And it happens all the time with prescribers because they just don't have time. The office they're like, oh, we don't remember, um, preliminary review. Doesn't show this prescription and that's it. And it was somebody else who wrote it in the office or something like that. So dig, dig in the case and present everything you can, because again, they will flag you as potential.

They can even terminate the contract. And nowadays PDMs are so punitive, for example, in a vision suspends pharmacies, uh, when, without even giving them an opportunity to respond. So they do a preliminary audit, they identify some issues and they suspend the pharmacy pending the audit. And I had a client who recently was suspended like that.

And, uh, 60% of her business was on vision. Geez, she can't function. That's it. She has to close. She has to sell her pharmacy and nobody will buy it now. And, uh, we are working with them. We want to expedite, we want to show them there's no fraud. It takes them not very long, not as long as board of pharmacies investigations, of course, but still they process information.

You have to appeal, you have to do all different things and it's at least six months suspension usually. So it's very important to pay attention to, to how you respond to PBMs and respond to absolutely 

Mike Koelzer, Host: everything. Because even if the results are the same, which hopefully they're not, if you've done your homework, you're gonna bring up some important issues that maybe the financial hits are not as bad, but even if the results are the same.

Just that fight, just that paper trail and so on, might prevent them from throwing a red flag on something or whatever. 

Natalia Mazina, Attorney: They will probably still recoup, but at least they won't terminate the pharmacy because your reasons, um, they, they have something in it. They understand that's probably was not fraud.

This looks like an oversight. And if you assign, send a corrective action plan saying, okay, maybe there was an oversight, this is our new policy acknowledged by all staff. Um, probably there will be no recoupment and that's it. And we 

Mike Koelzer, Host: continue. Yeah. What's the difference between an oversight in fraud?

The financial hit might be the same, but there's a difference on the back end of the right. Of losing the contract or whatever. Right. So Natalia, someone comes to you. And when you're fighting something as an attorney against the other side, are you trying to block tricks from the other side, like legal tricks that they think they can pull on someone who doesn't have the experience?

Let's say a pharmacy didn't have an attorney. Are they trying to pull tricks on them? Are you there mainly to make sure things fit into the legal structure or are you able to pull tricks on them? No, , 

Natalia Mazina, Attorney: It's a tricky question. Um, so it depends when I'm involved in the case. First of all, if I'm, if they call me when.

So are you too late, but it's nothing usual I can do besides find them a good criminal defense attorney. Hmm. Uh, if it is at the very initial stage, uh, I mostly work with, uh, DEA in the west. So I usually know people and I know the approach to audits, 

Mike Koelzer, Host: You know, people actually like their individual approach.

Right, 

Natalia Mazina, Attorney: right. Who goes in the field. Yeah. Right, right, right. The special agent in charge or diversion investigators who come to the pharmacy. So I usually know, uh, what they're trying to get. So I had this di he's no longer here diversion investigator who always ask pharmacies to S. On the spot he'll always come no matter what he finds.

He's like, it doesn't look very good, better surrender right now. And that's the end of it. We won't seek any monetary penalties and I don't really understand why they do that. 

Mike Koelzer, Host: Surrender your 

Natalia Mazina, Attorney: pharmacy. No, the registration, DEA 

Mike Koelzer, Host: registrations, which then would prevent them from doing controlled 

Natalia Mazina, Attorney: drugs. Right.

Control substances. Yeah. But that's pretty much [00:40:00] the end of the pharmacy too. Yeah. You know? Sure. Yeah. So that was a trick. Uh, and if the pharmacist calls me and says, you know, there's, DI's here. I'm like just, just, just, you know, just keep him happy. Just, you know, just, just don't do anything. Don't do not, of course, you know, surrender, just, you know, tell him, you know, I'll think about this and just, just be nice to him.

He likes, you know, nice pharmacists and just appears that you're trying to incorporate, but you'll need more time. Um, so that will work with his di, but maybe it won't work with another di. Um, so it, again, depends on their tricks as you call them, could very, very depend on geographical geographical location.

Um, I have a client, for example, in Hawaii, and we had a recent audit and the agent was the most pleasant guy I've ever met. He was so nice. He identified some issues and some issues where actually could be considered pretty serious in other states. And he just said, you know, I really think you need to change your policy.

How are you doing this? And I'm here to help you. So, I mean, no tricks. He sees that the pharmacy is a legitimate pharmacy. It's not something he needs to worry about in his district. And he wants to make sure the 

Mike Koelzer, Host: complaint is that case over yet. Uh, yes. Cause watch those nice guys. No, it's over.

It's over. You gotta look at the whole 

Natalia Mazina, Attorney: picture. Yeah. We got a letter of admonishment, which is pretty much like a slap on your hand. Don't do this anymore. And that's it. The case is closed. Yes. But I do agree that some very nice guys could turn out to be very nasty in the end. I do agree. Yeah. Yeah. That 

Mike Koelzer, Host: investigator sounds like a real part of my French, but a real ask that he will have people surrender their license.

And if they don't think about it, like we talked earlier, if they're blabbing, they could surrender their license. If that's his. Mo across the board, he could have people surrounding their license for almost nothing. 

Natalia Mazina, Attorney: You know, honestly, I don't understand why some of the eyes do that because I mean, what's the incentive?

I mean, when they, they, they come with a monitored panel as you understand, that's kind of on their record that they made so much money for the government. But if he's closing all the pharmacies, you know, his neighborhood in his district, I mean, how is that benefiting anybody? So I don't know where he's coming from, but I think maybe it's a concern that if there's this record, keeping the nation can escalate something more and he just doesn't wanna deal with it.

That's easier for him. Mm. Maybe I don't, I don't know. Uh, but again, not Odis will ask you to S. Um, some of them really will go after monetary penalties. I had a case where a pharmacy was missing patient addresses. Yeah. On every script, there were no addresses and they had thousands, thousands of scripts like this and a penalty, uh, monetary penalty for record keeping similar to that is 15,000 per violation.

So multiply that 15,000 for 10,000 scripts. For example, we're talking. 150 million or something. I dunno, we are bad with math. That's a hell of a lot of money. Yeah. Yeah. So they were going after this pharmacy to say, well, we could take all this that much, but we actually agreed on 10 million and that's a small pharmacy.

Um, so of course, you know, and some of them are very aggressive, uh, in, in trying to collect, they will file a case in court to get my third penalties. And remember, this is the penalty set by statute. So it's not like it's their discretion, but the statute says you miss for any record keeping issues, this is your penalty.

Okay. So if they go to court and they can prove every single violation, the judges will very likely say, well, that's the statute that tells me to impose 15,000 on every single violation. And well, we settled this case for much, much, much less, of course, but DA's are very aggressive in, um, getting monitored. 

Mike Koelzer, Host: are those agents, are they a lot of times trying to climb the ladder of the agency and if they get so many feathers in their hat for closing pharmacies or raising so much money and penalties and so on, is that a good thing?

Natalia Mazina, Attorney: Uh, so I can't talk about DEA because I don't know the internal policy, but if we talk about the Department of Justice, uh, these USA attorneys who work on the case, yes. More cases, the better. They usually, and again, I'm not a hundred percent sure, but I think the bonuses depend on that as well.

And the reputation, for example, [00:45:00] every time there's a big settlement there's announcement, press release this case, uh, prosecuted by this division by an attorney. So and so, so if this attorney, so and so is having all these large settlements. I mean, that's his reputation. Um, they do want, um, to collect as much as possible for the government and, um, prosecute as many cases as possible.

Mike Koelzer, Host: If you needed to put your stats on the front page of the newspaper or the internet, and so on as sort of the defense attorney, let's say, what would be your feathers in your cap? Would you say how many pharmacies you kept open or how many DEA licenses you saved as a business person? Also, it's making a living wage, but what would you put as your markers of success?

Natalia Mazina, Attorney: Well, I usually don't put any feathers as you call them. Um, cuz sometimes I don't think it's very ethical because every case is from a legal perspective. Every case is so different, so different. 

Mike Koelzer, Host: You don't want to have a certain goal for each one because all the goals are different. It 

Natalia Mazina, Attorney: looks like I am, I'm promising something.

And very often, you know, people come and say, well, she did it on her website. She says she could dismiss this and she didn't dismiss this case for me. And it's like representing that you 're given this, you know, sense of hope. But you know, if, for example, um, if I'm talking about any achievement, so I just closed the case.

For example, da case two, uh, the client was hit with 3 million penalty. um, and he was represented by another attorney, uh, also a healthcare attorney, but not specialized with pharmacy. So the case revoked around CSAW confirmation. So what I did when he came to the pharmacy, he went to the pharmacist's email and he downloaded and printed CSAW confirmation from the wholesaler, every single one of them.

And if you know, the email confirmation does not state the quantity and date received. so they went after the pharmacy saying that he never recorded the quantity and they received it, he never logged it in. And his 

Mike Koelzer, Host: CSAW for our listeners. This is when you get this special order in that you have ordered your very strict, controlled drugs on CTUs mm-hmm you then have to say, yes, I received this on this date and signed it and dated and so on.

And then save these, this guy didn't have those. So he went in though and just downloaded them in the email. 

Natalia Mazina, Attorney: Right? So they claim that the Pharmac did not have, did not record the quantity received when they got, uh, received the CAWS. I mean, C2 S from the wholesaler. So the healthcare attorney working on this case recommended it to.

And the government went down to 1.8, I think. And they wouldn't go down anymore. So, the pharmacist decided to call me and I looked and said like, wait a minute. This is just your email confirmation from the wholesaler. They cannot go after you for not recording quantity and date based on email confirmation.

So we actually went to the seesaw system and every single entry was. And the case was closed. Mm. So yeah, we were able to show and da really didn't want to believe us. They subpoenaed the records from the wholesaler, and ceased audit records. So usually it's not a paper trail, uh, when there's a shipment of C2, S the pharmacy goes to the caw portal and they're like, okay, on this date, we did receive this quantity.

That's it? And the pharmacy was doing that. They just, for some reason, didn't look at CAWS portal. They looked at email confirmations. 

Mike Koelzer, Host: So they wanted a couple million dollars because they just didn't have the physical paper printed off. When they had done all this on the CSAW program, they 

Natalia Mazina, Attorney: just didn't understand how the CSAW system works.

So, because the pharmacy does not, the wholesaler will sell, send the CAWS confirmation when the product is not received yet. So the pharmacy cannot input, receive the date on the email. Copy. But they will were going physically into CSOs portal and input in this 

Mike Koelzer, Host: information. I know everybody's gotta follow the rules, but that's an example there of like fraud versus, 

Natalia Mazina, Attorney: but this is not even an oversight.

This is, this is just the, DA's inability to understand how the system 

Mike Koelzer, Host: works. That was an oversight that was incompetence by the DEA, they doing 

everything. 

Natalia Mazina, Attorney: Right. But the problem here was that the pharmacy was so scary. Mm-hmm that? They're like, yeah, we did something [00:50:00] wrong. We're gonna pay 3 million. And they were ready to pay that $1 million.

Yeah. With the other attorney, the other attorney said, you know, I met with a U a and the case doesn't look good, but good news. They're going down to 1.8 million. Let's accept it. So he decided to get a second opinion. And he involved me because I specialize in pharmacy, not recent healthcare. And this is so unique to pharmacy, right.

Again, right. Physicians are not gonna be dealing with 

Mike Koelzer, Host: CSAW. Yeah. That's a great example of living this and. It's simple. I mean, it's simple for you, but it's only simple because you've dedicated your career to pharmacy, right? 

Natalia Mazina, Attorney: Yeah. 

Mike Koelzer, Host: NATA, we talked about getting ahold of you. If they see the blue coats walk in, if you would like to go into a pharmacy and well, just talking to the listeners, what should we be doing that on average, we might not be doing well enough.

There 

Natalia Mazina, Attorney: There are so many things and it depends again on the pharmacy. For example, I went to one of my clients, um, I think last year, um, and I came to the counter and she has a pad, um, where every single patient signs puts the date, the name, the drug and signs, but. You can see other patient's information as well.

So, I mean, this is such an obvious HIPAA violation. So some pharmacies might not pay enough attention to HIPAA privacy. Some of them might not, um, pay form record keeping properly, properly. Uh, it, it depends. It depends. Every pharmacy is so different. There are some specialty pharmacies. They have completely different issues like compounding pharmacies, completely different issues.

So, but on, uh, average, if you can prioritize record keeping that could save a lot of headache, and for example, makes it easy. If you go to the website, a diversion. I think that got or something like that. But if you put a diversion, the very first side is the site and they have tons of resources there. Uh, they have the whole code of federal regulations pertaining to control substances.

There, they have the control substances act and they make it easier. They go, okay, this section deals with record keeping. This is all you need to do. This goes to background screening checks. This is all you have to do. So, many pharmacies do not do that. I mean, they do have policies and procedures.

They do have manuals, but they don't follow them. They don't read them. They buy it somewhere and that's it. That's the end of, um, uh, so, and da also has a database on their website of all the. Of all the, um, not the investigations, but the cases which ended up with administrative hearing. So where pharmacies were arguing.

So there are lots of resources and I think compliance is easy nowadays. I mean, of course it's not as easy as it wants to be. We want it to be, but it's very doable. And if you want to stay in this business compliance record, keeping is your foundation upon which you can build your. So it's very, very important.

Um, when we started this COVID quarantine, we launched a website called direct policy where we sell compliance documents. So, because I saw this need, you know, they don't customize their policies and procedures. They don't pay attention to it. Um, sometimes they just tell me it's difficult and it's expensive to find something online.

Um, so we started this website. Um, we had some great feedback, uh, but it's just a drop in the ocean, which you can do. It's just, just getting policy and procedures, not enough. You have to be on top of it. And it really pays off. If you have certain people dedicated to make sure you are compliant, uh, or you are doing proper record keeping you're separating your C2, C three C fives in different files, things like that.

It pays off 

Mike Koelzer, Host: different people know they should do certain things. They maybe just don't like them. Exercise to lose weight. This that there's a ton of things that people say I should be doing. And I think across the board, there's probably pharmacies that are just more lax on certain things with no real justifiable reason.

They just maybe have never gotten around to something. They figure that is not that big of a deal because they don't know anybody that's been in trouble for it ever. And just doesn't seem like that big of a deal, but that doesn't [00:55:00] necessarily correlate with how the. The DEA sees that. 

Natalia Mazina, Attorney: Right. Right. And I think the problem is very often, uh, pharmacists are very busy with running the business dispensing.

They're busy with their work, uh, and with all this low reimbursement rate and all these cuts, they very often cannot dedicate a certain person for compliance or for making sure policy and procedures are updated every year. Or they do all this training, which is recommended. Um, it's difficult. It's a very difficult profession.

I really admire them, but they are still dispensing. And they're still retail pharmacies out there. It's it's, uh, I think that's just, um, they're real heroes out there because their reimbursement rates nowadays, you probably know better than I do are not as they used to be. And some pharmacies are just making a very, very small profit margin, or they're not making any money.

Some of them have been losing money. And when the, you end this business, climate compliance is not on your top priority 

Mike Koelzer, Host: list, your business. So with your RX policy, you can hit people across the country as an attorney. Are you pretty much in your area or can you do attorney work across the country somehow?

Natalia Mazina, Attorney: So I am licensed in California. That means that any state matters are only limited to California, any federal matters I can do them. So federal matters. We're talking about FDA, OIG compliance, um, PBM audits, Medicare billing, Medicare disputes, DME, licensure. Um, so anything on the federal arena. I can help if it goes into state specific issues.

Uh, I usually refer people to my vast network of other pharmacy attorneys. I'm a member, I'm a membership committee, extra for American society for pharmacy law. And I should, uh, throw a little pitch out there for the group. It's a great organization to stay taught, you know, the breast of all legal developments.

And it turns from all over the country to come to, we have anal conferences. One is coming up in November. Great group. Great networking. Say the 

name 

Mike Koelzer, Host: of the group again, 

Natalia Mazina, Attorney: American society for pharmacy. , it's not only attorneys. We have quite a few pharmacists, um, um, all change, um, represented, um, because they have regulatory compliance, people just dedicated to compliance.

We have some retail pharmacies, um, and, um, we have anal conferences. We have tons of materials. Uh, we have a referral list. For example, you're in Michigan. You're looking for a pharmacy attorney specialized in Michigan law board of pharmacy representation. You'll be able to find one there and great networking op DM attorneys there too.

So before I joined this group, I remember I would call PBM. So I will email the legal team. I wouldn't hear anything now that I know some of them through this group. It takes me a few hours to get a hold of them and explain what's going on so they can look into this. And it's, it doesn't mean that I'm getting what I want from them, but I get attention because of this person connection through the 

Mike Koelzer, Host: group, the dark side has attorneys in this group also.

Natalia Mazina, Attorney: Yes, because it's a pharmacy law, so we have wholesalers. Gotcha. Um, we have an annual chain, chain stores, I think. Represent. Um, for example, we have a conference coming up in November, we'll be talking about all kinds of regulatory updates, what's going on in the legal arena, and updates every year. Uh, and we share what we see in our cases.

It's a great, great, great group. Interesting. So, and if you were, for example, a first time member, you usually assign a mentor and I've done it many times when people just come into the group and I'm volunteering to be the mentor. And I introduce them to, for example, a pharmacy student and they want to, they're more interested in pharmacy compliance, regulatory compliance, and I introduced them to people in the area if I know them, for example.

So it's a, it's, it's a, it's a, it's a, it's a very, very good networking 

Mike Koelzer, Host: group. So we talk about the DEA guys and gals, let's say they like to go up the ladder, you know, and get these bigger wins. Are they just picking on the independence because they're easier to pick on or will they go into chains and do this stuff too.

So 

Natalia Mazina, Attorney: Usually they target independent pharmacies because if you think about it chains, they have a, usually a robust compliance department and it's [01:00:00] not like one owner who is financially interested, uh, in, in some fraudulent activity. This is a pharmacist that pays per hour. They have no financial incentive to defraud or commit any violations.

So engage in any pill activity. Ah, so, and plus. Every single chain, they have a very large legal department, right. Which is staying on top of compliance NDA or any of other investigators or board of pharmacists. They know that they know that they are doing their fraud and abuse training every year, right.

Or HIPAA training every year versus independent pharmacies. What's the oversight could be one owner, one pick business, and who is overseeing whom , there's more room to commit any, any, any kind of fraudulent, uh, activity. Um, 

Mike Koelzer, Host: yeah, a pharmacist is listening to this and they say, ah, I'm not fraudulent. Maybe I could do a little bit better on my record.

What should a pharmacist do? Let's say they have 10 minutes to do something in their pharmacy. After listening to this, what are some steps they should be looking at double checking, et cetera. 

Natalia Mazina, Attorney: probably, I would say updating new policies on procedures because people really don't pay attention to them, but this is one of the first documents board of pharmacy reviews.

When they come in and many pharmacists, they don't update them and they have outdated policies out there. Nobody reads them. So go through new policy and procedures, uh, make sure it complies with da regulation. And I already explained how to access them and your local board of pharmacy regulations.

Uh, and they're there and everybody in the pharmacy, uh, train on that that's number one step to prevent any troubles going forward, 

Mike Koelzer, Host: Just pulling one out and saying I've got one from 12 years ago. One of the main things is dusting it off, making sure it complies with what's happening in the real world with your state and with the feds and probably hoping.

Some of that's actually being done at your pharmacy too. It's kind of a combo kit. Mm-hmm 

Natalia Mazina, Attorney: yeah. It's actually better not to have a policy and procedure than to have a policy and not to follow it because then the board cites you for not following your own internal policy. 

Mike Koelzer, Host: Oh, that's interesting. So, yes. So we gotta make sure that anybody who's got policies just because their state board said they should have one or something.

Mm-hmm , you're saying it's worse to have one and not follow it than just to not even have one. 

Natalia Mazina, Attorney: Right. Yeah. Yeah, right. Yeah. There are only a handful of policies that are required by state laws in California. I think we have just like, I think five or six, which are actually required by law to have, uh, like technician description, job description, for example, or what happens if there's an impaired employee?

Um, so only a few, but usually the manual contains much more. And if you have all these optional policies and procedures, which do not apply to you, it's like why you're not following your internal policy and you are cited for it very often. So that's number one, I think, uh, step two to kind of bring, you know, come to up to date with compliance, I think, um, and stay informed of, of course, in a board of pharmacy alerts or anything, government alerts and what's going on in the industry, because as we talked about, many pharmacists are very busy.

In the field that they just don't know what's happening. Uh, I have a lot of clients who are much older and they are still doing business as they used to do 20 years ago, but that's not working anymore. Um, with this aggressive regulatory environment with PBMs, um, I mean, they're like you that they still didn't get in trouble, but they could be one day when they really have to, they may lose their investment.

They invest a lifetime just because they're just not paying attention. What's going on in the field? What's 

Mike Koelzer, Host: your blog, which is interesting. You put some cool stuff out on there. 

Natalia Mazina, Attorney: Yes. It's farm health law.com. Farm health law.com. Yes. Yeah. So I try to cover some of the, uh, uh, practical points that I come across.

So for example, I come across some settlements and I'm like, oh, this is relevant. I deal with it all the time. Um, or some practice points for my practice. For example, I just recently this year learned that, uh, when you do, uh, when they're, um, you know, a variant, uh, quantities list and with Caremark. So I had no idea that they take it into consideration.

When, when they compute in a [01:05:00] bearing quantity. So I'm like, okay, everybody should know that. So make sure your reversals and I'm going over 25% of this bearing quantity list. So I'm writing a blog about that. Um, things like that, that is pretty practical. I have good feedback about it. Uh, we don't have that much engagement.

I've noticed with pharmacists, they've shy to say something, but oh, this is what's happening with me or they more, they, they, they quiet. much. Sure. Yeah. But I do put information out 

Mike Koelzer, Host: there. Yeah. Well, Natalia, you'll be my first phone call from prison. No, no, no, no, no, no, no, no, no, no. That never happened to you.

we're not going to prison. No, we're not going to prison, but pleasure talking to you, Natalia. And thanks for all you're doing for the profession. 

Natalia Mazina, Attorney: Well, thank you for putting this together because I think it's useful as well. More information they have pharmacists have more equipped. They are to understand what's going on and properly address issues.

Yeah. 

Mike Koelzer, Host: And I think the real life stuff's important because there's a ton of rules out there and all of 'em are important, but hearing the ones that rise up to the top, that's important. It's good that everybody is adding in thoughts and stuff. It's good. 

Natalia Mazina, Attorney: Yes. Yes. I'm glad we need more information out there.

And I really applaud when I see pharmacists forming their own associations, um, independent associations, where they just share experience. Somebody's having this crazy guy write to everybody in the group, you know, You in lookout, this is what they're doing to everybody nowadays. And, but, you know, again, we are in a very competitive industry as well.

So, but I do applaud pharmacists who are willing to share the experience and educate others. Um, because I saw people who are actually trying to be very competitive and actual, not sharing information and actually damaging each other. And I have tons of cases where pharmacists are calling on each other and saying, you know, this pharmacist doing something shady should investigate

Yeah. So it's, it's an, it's an interesting profession interest in dynamic. 

Mike Koelzer, Host: Independence by nature of the name being independent. You got people that are independent helping each other. You also have people that are independent competitors of each other and maybe go in the opposite direction a little bit.

Natalia Mazina, Attorney: Mm-hmm yeah. Yeah. 

Mike Koelzer, Host: Well, thanks a lot, Natalia. Pleasure talking to you. Thank you, Mike. Talk again. Bye-bye.