Think You Know Workers’ Comp? The Times, They Are A Changing!

Episode Notes

Transcript

Speaker 1:

Workers Comp Matters, the podcast dedicated to the laws, the landmark cases, and the people that make up the diverse world of workers compensation. Here are your hosts, Judd and Alan Pierce.

Judson Pierce:

Hello and welcome to another edition of Workers Comp Matters. My name is Judson Pierce. I’m alongside my cohost Alan Pierce. Say hello, Alan.

Alan Pierce:

Hey Judd, how are you?

Judson Pierce:

Nice to see you and nice to talk to all of you. We have a special guest on our program today, and this subject could actually, well take four or five sessions of our time because it is so interesting and sort of predictive of future events perhaps, and I’ll let Alan get into that and our special guest get into that a little further. I’d like to introduce her right now. Her name is Dr. Emily A. Spieler. She’s the former Edward w Hadley professor of law at Northeastern University School of Law in Boston, Massachusetts, where she also served as Dean from 2002 to 2012. She’s one of the nation’s leading commentators on workers’ compensation and related issues. Prior to her academic career, she served as the commissioner of West Virginia’s Workers’ Compensation Fund and she was also a member of President Obama’s transition team for the US Department of Labor. As chair of the Workers’ Advocacy Advisory Committee, her law practice focused on issues of job security and worker health and safety, and she’s published widely in the areas of workers’ compensation and occupational safety and health. Emily is a fellow of the American Bar Foundation, the Pound Institute for Civil Justice and the College of Workers’ Compensation Lawyers, as well as an elected member of the National Academy of Social Insurance. She received her undergraduate degree from Harvard University in Cambridge, mass and her law degree from Yale Law School in New Haven, Connecticut.

Alan Pierce:

And the title of our show this time Judd, is

Judson Pierce:

Times are changing.

Alan Pierce:

The times are indeed changing in the field of workers’ compensation or perhaps put more specifically in the world surrounding workers’ compensation, the world of work. Today we hope to have a compensation with Emily. She is, as Judd had mentioned, a well-known researcher, commentator, speaker, lecturer, writer on matters involving workers’ compensation and access to this particular area of social insurance. Given the fact that workers’ compensation, as we know it is in this country, about 110 years or more old times have certainly changed as Bob Dylan remarks 60 years ago. So Emily, having said that, how do you see the system of workers’ compensation a hundred plus year old system designed and implemented in a much different world of society and work? How do you see it fitting into the 21st century given the number of trends we’ve already seen,

Emily Spieler:

Lots of different things are changing for workers and for employers, but we still have to worry about whether when workers get hurt or sick at work, whether they have enough to live on and whether they have medical care. And so we have to think about how old models fit into changing times. System has also undergone changes over the century that it’s been in place. Sometimes it’s been adapted to changing external factors and sometimes it has not adapted all that well. It’s very rooted as you know, Alan in the traditional concept of who a worker is and who an employer is, and it’s very rooted in the notion that there’s kind of an exchange that underlies it, that employers are free from tort liability in exchange for workers getting benefits irrespective of whether the employer was at fault. We have a huge debate now really going on in legal and political circles about how to define an employee for the purposes of various kinds of employment regulation. And that argument I think is the most robust in the field of wage and hour laws where the question of how you define an independent contractor is very important in terms of whether any of the wage and hour protections extend to people.

Judson Pierce:

Emily, you wrote an article for the Rutgers Law Review, I believe it was in 2017, is that right?

Emily Spieler:

I think that was the closeout date for the research

Judson Pierce:

Closeout date of the article, yeah. Okay. So you went through well over a hundred years of history and how our system has evolved and how it might continue to evolve, and I wanted to bring your attention to the issue that you posed about towards the end there. And for our audience, you can easily find this article online if you search with her name or search by Grand Bargain or Rutgers University. It’s very interesting. I’d like to ask you though, what do you see as the main difference between when the workers’ compensation laws were enacted? In today’s world?

Emily Spieler:

I think we live in a much more complex world, at least I think the original laws kind of imagined a world where a worker works for an employer, a single employer, and they really were only concerned about traumatic injury and the employer was going to provide some level of benefits to someone who was hurt at work so that they wouldn’t have to prove what we call tort liability, that the employer was at fault. We have a much more complicated world now. The nature of work has changed. Back then the vast majority of people who were covered by Comp worked in traditional factory and mining jobs, partly because although there were lots and lots and lots of people working in farming, they were largely excluded from the workers’ compensation programs. But now we have a notion that everybody should be included and that there should be some level of benefit adequacy, but the nature of injuries has changed and the nature of work has changed and who’s doing the work has changed. Back then there weren’t as many women in the market. The nature of the question of how this relates to some of the recent changes, does it have anything to do with workers who work at home now? Does it have anything to do with workers who drive for Uber or DoorDash? Does it have All of those kinds of questions I think are questions we’re going to have to start answering pretty soon if the program is going to maintain any level of relevance.

Alan Pierce:

And Emily, I think probably if you agree with me the most, one of the most pressing issues is what do you do and how do we handle injuries sustained by people in that what you call gig economy, people that are not traditional time clock or salaried or wage and hour employees, but basically are self-employed and pick up work through a platform such as Uber, Lyft, and this will soon evolve into other and has evolved into other types of jobs. Is this something that the workers’ compensation system should strive to include those workers or do you see an alternative type of compensation program that would cover those workers if they are not considered to be employees?

Emily Spieler:

So I don’t see any hope on the immediate horizon of a real rethinking of our social benefit systems in the United States. And so I mean, the question is what are the injuries that people are getting at work? How are they getting them and is it something that should be covered by a system that comes through the employing entity, the DoorDash or Uber or Lyft, or should it come from somewhere else? If we had a real social safety net in this country that provided adequate health care and took care of people if they became disabled or couldn’t work on short-term or long-term basis, I think we would have a very different conversation about workers’ compensation. But because we don’t, I think it’s really important that we see if we can cover as many people as possible with as adequate benefits as possible under the existing systems.

Right now, I think in most states those workers would not be considered employees and would not be covered, and right now would have pretty much nothing unless they are covered by some medical plan under Medicaid or the A CA. But I’m not sure that’s a hundred percent true in all states. I do worry about our becoming. The fact of the matter is that very serious injuries are happening in traditional occupations where people are having trouble getting workers’ Comp. So I sometimes find it frustrating for us to focus a lot of attention, not that it isn’t deserved, but all of our attention on these new types of employment relationships when people are still dying in trenches and falling off roofs, which are things we’ve known what to do about for decades or centuries.

Judson Pierce:

Also, when workers have meritorious claims and for whatever reason, even before they see an attorney, the insurers are denying them. They’re denying these claims that were either a witnessed or there’s really no doubt for them to have happened. So those are claims that aren’t being reported properly by employers who I’m putting on my employee advocate hat. Now there’s so many of those potential claimants out there that maybe don’t know their rights well enough, and how do we use the workers’ compensation system to educate folks about what their rights truly are? It’s been around for so long, people don’t still don’t know really what happens when they get hurt at work.

Emily Spieler:

I think that’s really true. It’s also true that because of our underlying employment law system, people are unlikely to be in unions. And if they’re not in unions, then they have very little job protection. And so they’re afraid of retaliation and the laws against retaliation aren’t strong enough. And so people are afraid of retaliation. They don’t know what they’re supposed to do, their doctors don’t necessarily, so a lot of claims never ever get filed. In some studies, the majority of case claims that could be filed aren’t filed. So we have a system that isn’t working even for the people who aren’t in a kind of gray area in terms of whether they’re covered. And it’s really not working for people who I think who are undocumented workers working in dangerous industries where they’re subject to all kinds of forms of retaliation and are very reluctant to file claims. If we were really going to step back and think through what are the problems we have now, we need to think both about the new forms of work and about why the system isn’t working for the existing and old forms of work.

Alan Pierce:

Emily, you talked a little bit, you made reference to the changing nature of work. There are probably less people working in factories and more people working in offices. It used to be that work injuries had to be a specific accident and now it has evolved to cover repetitive stress injuries. How do you see continuing changes in the workplace, robotics, artificial intelligence, things like that impacting not only the types of injuries, but whether the Workers’ Comp system is equipped as they define these things to cover these types of occurrences?

Emily Spieler:

So I have to say I’m not an expert on what affects robotics and AI is going to have on work, although I think that one of the things that’s going to happen is people who are getting a lot of injuries in places like the big warehouses for Amazon and other companies, they may just be losing their jobs as robotics takes over, there’ll be fewer jobs in some of those industries than exist now. Now where those people are going to go, I don’t really know. I think we’re kind of on a cusp of some kinds of change that are really hard to predict. Obviously, Workers’ Comp isn’t program that’s designed to address safety failures or that’s how I think about it. You wouldn’t have to have a Workers’ Comp program if people didn’t get injured and sick at work. You could prevent people from getting injured and sick at work, not maybe completely, but a lot if you paid more attention to safety. I don’t know what the effects are going to be of some of the changes that have been happening recently, both due to technology and due, I think to some extent to the effects of the pandemic, what that’s going to do to work and Workers’ Comp is sort of a follow on to that, but I still think we’re going to have people falling off roofs and dying in trenches.

Alan, I think you actually may be on this or have been on the panel where Frank New Hauser said, well, we should just do away with Comp. And my feeling was, well, there’s an argument to be made that it would be better to have a robust social safety net in this country, but without it, I think that paying attention to what happens to people at work and the risks that they face that aren’t being dealt with through whatever efforts and safety there are is incredibly important. So you have to ask first, what is the effect of these changes on safety and risk and injury at work? And I don’t think I know with regard to robotics and ai, I think that in the gig worker issues, the companies just don’t want to have any responsibility really for what happens to workers out there. And so they’re taking the position, they’re all independent contractors, we’re just tech companies with platforms, and that’s the end of the story. I think it’s probably important for the entities that are really employing these people to have some responsibility for the workers who are doing their work, but I think that’s probably outside the scope of the conversation we’re having here.

Alan Pierce:

Okay. We’re going to take a brief break and come back with Emily Spieler to continue our conversation about what the future holds for workers’ compensation.

Judson Pierce:

And we’re back, Emily. What has the pandemic taught us in terms of whether or not we need to increase coverage or have the government or private insurers look to increasing coverage for things such as occupational diseases or other sort of more novel illnesses that would be disabling?

Emily Spieler:

Well, let me just start by saying, we now know from a lot of studies that have been done that a lot of people that there was a much higher rate of disease and death for people who went to work during the pandemic than for people who could stay home or people who had to stay home because they lost their jobs. So there was a huge amount of difference among the states and how they dealt with this question of whether or not to think about this as an occupational disease. And I think one of the good things about that is that it made us start thinking about how to deal with the question of occupational diseases where people in the general community may have the same disease, but the risk is higher at work and should it be included in a compensation system. And I think it’s a really complicated question, frankly, I personally thought that, again, if we had really good health insurance and really good paid medical leave and that maybe it isn’t necessarily the kind of fight we should have in workers’ Comp, on the other hand, there are a lot of people still without health insurance in the US and a lot of people without any paid medical leave, and people were being put at risk by having to go to work sometimes at very high risk because they were going to work in very densely packed places like meat packing plants without any attempts at trying to give them any protections.

So what do we think about it now is a really interesting question, and I’m not sure I have the right answer to that. I mean, a lot of people who are on the worker’s side say you can’t leave it to a system that says, okay, now prove that you got it at work. I mean, how do you prove you got it at work? You rode public transportation, you live with other people, they go out to other jobs. There’s no way to prove that. Now, it used to be in workers’ Comp, there was a very liberal rule in terms of what counted as related to work. Most jurisdictions don’t do that anymore. And so it’s on the worker to prove that it came from the workplace.

Alan Pierce:

And I’m glad you brought that up, Emily, because I came up through the Workers’ Comp system over the last 50 years or so, and the liberal interpretation of workers’ compensation statutes and the way these cases were decided IC has changed markedly, and the employee of the injured worker always had the burden of proof, but in the close case, the tossup case, the case that could go either way, there seemed to be the general sense, at least expressed by the appellate courts that these cases should be adjudicated in a liberal fashion. I’ve seen that change going forward. Do you ever see that coming back as a concept, and what do you think of that as a concept?

Emily Spieler:

I think that if you think of workers’ compensation as a social insurance program that’s supposed to provide a safety net for workers, then you should tilt on behalf of workers. It’s the employers buying insurance. They get to spread the cost of the risk and the workers is going to be left out in the cold if they don’t get the benefits. So it seems to me where it’s a toss up, the workers should win. And I think you’re right, that has changed dramatically in the last 30 years. So that now it’s prove it, prove it, prove it.

Alan Pierce:

And to the extent that it becomes increasingly more difficult for injured workers to prove their case and hence they do not get workers’ compensation, who bears the burden of that loss?

Emily Spieler:

Well, I think it’s clearly, it’s initially the worker and then it’s the community at large,

Alan Pierce:

Which goes back to how workers’ Comp started. That burden was too much for the worker and the community. So let’s just pivot a little bit to post pandemic lessons, the adjudication of the processing of these claims through the agencies. I think we can all agree continue to almost seamlessly through the pandemic, especially the early days because we had the availability of virtual process as we’ve emerged and come out of and are still coming out of the pandemic. A great degree of previously in-person meetings or hearings are still being done virtual as a result of the expediency and the economics of it. Do you see this as a growing trend that workers’ Comp will tend to be treated more as a ministerial function that could be done in a technological forum as opposed to the what I think our clients injured workers and employers deserve in-person proceedings as plaintiffs and defendants have in courthouses?

Emily Spieler:

Well, first of all, that trend has also happened in some courts where initial conferences and other kinds of things are being done virtually. I think that one of the extraordinary changes that happened in our world, not just in Workers’ Comp, but everywhere is the growth of Zoom meetings, zoom hearings, zoom, that people don’t go in to have meetings, don’t meet each other, don’t in the workers’ Comp arena. I think it depends a lot on whether you think that if you’re taking testimony and thinking about whether or not there’s a issue of credibility, it seems to me those things have to be done in person. You can’t read people if you’re talking about conferences where only lawyers are talking and it’s a matter of law, then I think perhaps it’s a little different. I think I grew up in the same culture you did Alan, which included that if I was working on a case and I didn’t practice workers’ Comp, but I did employment law, and if you were working on a case, you often would talk to the lawyer on the other side outside the Courtroom, you might reach some deals, limited deals or settlements of a case.

And so there’s this informal interaction that I think can’t happen when you have things done with a time to start and a time to end and you can’t really say, well, hey, you would you just stay on for a little while for a private conversation. People don’t do that. So it’s hard for me to say because I also think that there were really big delays in a lot of the systems, some of which have gotten less as a result of the use of more technology. And so maybe the argument cuts both ways on some of the things that have to do with lawyers and motions and conferences and things like that.

Judson Pierce:

We’ve seen the topic of benefit adequacy being discussed in your articles since really the 1950s. We had the commission on standards in 1972 that said that many, if not all the states were doing a poor job and the states sort of rushed to try to correct those inadequacies. But then as you said, over the last 30 years, it’s been this sort of, so-called Race to the bottom. Do you see that trend continuing or is there going to be a buck to that trend?

Emily Spieler:

That’s a political question that you’re asking more than anything else. I think that the state, because this is a state-based system, all of this happens in the state legislatures and in the state executive offices, and it used to be certainly in West Virginia where I spent a long time, it used to be that it was the state A-F-L-C-I-O and the other unions that really stuck up for the Workers’ Comp system when it came up in the legislature. But the unions are incredibly weak now, and so there’s almost no voice for the adequacy of this program in most state legislatures at this point.

Judson Pierce:

And I’d push back on that because I think that we’ve seen, at least in the last six months to the year, we’ve seen the afta strike and we’ve seen a lot of unions, some teacher strikes in Massachusetts coming to the fore and really pressuring their employers to relook at their agreements. Don’t you see that the union structure might actually becoming stronger and not weaker?

Emily Spieler:

I have to confess that. I hope so. Which probably says something about how I view the world, but I also think that if you look at the Bureau of Labor Statistics numbers, the percentage of people in unions hasn’t actually been going up as these very public conversations are happening about very active activist approaches. And a lot of the expansion is in university adjunct professors and university graduate student assistants, and I’m not sure that those are going to replace the kind of advocacy that we had when people were coming out of the hospitals and the factories and the mines and really focused on questions of injury. Because if you have a real white collar workforce, that’s the bedrock of the union movement, you’re in danger of having people who don’t really think about safety as very high on their list of concerns. I think interesting. Now, that wouldn’t be true. If you look at what the Amazon workers care about, they care about safety and with good reason.

Judson Pierce:

Sure. And there are actors who are on movie sets who get shot and maybe movie sets should be a little bit more safe. But I’m sure that those types of topics aren’t, usually it’s the pay, right, that they’re trying to get a higher pay. You see, white collar, even doctors in hospitals are thinking about unionizing.

Emily Spieler:

I started my legal career representing interns and residents at Cambridge City Hospital when they filed for a union election in the 1970s, the question of how, and they were very concerned about the organization of care, and I think the teachers in Newton had a lot of concerns about whether the paraprofessionals in the schools that were enough of them and whether they were being paid well enough. And I think there are a lot of legitimate issues that the union activism now is raising. I’m just not sure it’s, and it’s very difficult to predict where it’s going at this point. I think if they become involved in their state federations and the state federations follow history in terms of what they’re concerned about in state legislatures, then you should see an uptick in the concerns about workers’ compensation.

Judson Pierce:

Before we continue a brief word from our sponsors and welcome back,

Alan Pierce:

Emily, I want to shift gears a little bit again as we continue to focus on the future. We came out of an experience about 6, 7, 8 years ago of an experiment typically referred to as opt-out where the state of Oklahoma passed a law that would allow large employers, mostly self-insured employers, but a good chunk of the workforce to bypass the workers’ compensation system of mandatory coverage and create their own system of benefits. That was admittedly, and everybody will agree, even that was on the other side of this issue, was very heavily weighted toward the employer and less weighted towards the injured worker. Hence, it’s being declared unconstitutional. But do you see a continuing trend to find alternative methods of compensating injured workers outside of the public sector like expansion of Medicare or expansion of Social security disability, but other forms of coverage that may not go through the legislative process and not be what we now know of is a typical workers’ compensation system.

Emily Spieler:

So I don’t think the opt-out system that was advanced in Oklahoma appears to have legs in other states at this point, although there was a flurry of attempts to get it passed in some places. The really appalling thing, by the way, about the opt-out proposal in Oklahoma, one of the appalling things was that employers could opt out and retain their protection from liability for tort Litigation if they were negligent. So they could design their own system, but they couldn’t be sued. I have thought for a very long time that what employers really buy when they pay for workers’ compensation system is protection from lawsuits. And so they don’t really care how low the benefits get. I do think that it’s entirely possible there’ll be something designed for the people who, the gig workers we were talking about before. Of course, these companies could do that on their own right now, they could offer these benefits without having any intervention from the state. They could argue that they’re not covered by the state systems, and so they’re giving benefits to their workers that because they’re worried about them, and notably, that has not happened. So I don’t see it as much as an opt-out system as much as I think that unless the trends of the last 30 years are reversed, it’s a system that inadequately protect workers and adequately protects employers.

Alan Pierce:

So that begs the question, the grand bargain that underlies this system, it was created in the absence of a social safety network and in the absence of health insurance and unemployment insurance and social security disability, and now that the employers on the other side have the wide availability of liability insurance to protect themselves from the risk of injury, do you see the grand bargain being irrelevant as where you get deeper into the 21st century as a quid pro quo?

Emily Spieler:

Well, I think employers could probably figure out that they could. I mean, it keeps their insurance rates down. Frankly, their liability rates down. If they can be shielded by workers’ compensation, which I think costs them in most industries, probably cost them less than full liability insurance in a dangerous industry, I’m guessing on that. I can’t really say that for certain. I think employers really benefit from workers’ compensation. So to the extent that they understand that they’re unlikely to try to get rid of it unless they can retain their protection from lawsuits. The thing is that the way the Grand Bargain was perceived in 1910 or 1915, I think is different from today. I think that it was a totally novel concept in this country to have the public sector intervene and create this kind of program that really changed the surrounding systems changed, starting with the New Deal really, and how that all shakes out in the world of work in this century, I think we really don’t know yet. It is not that big a program, but it’s as big if you count both all of the benefits that go out. It’s as big as the unemployment program and it serves a similar kind of need. So the problem with workers’ Comp, I think, is that unlike unemployment, there’s no federal standards for it.

Alan Pierce:

And you also raised another point. You were head of the commissioner of the West Virginia system, which was a state fund. So explain what a state fund is as opposed to a traditional insurance company paid Workers’ Comp benefits scheme.

Emily Spieler:

So a state fund basically plays the same role as the private sector insurance companies do in Massachusetts in all the other states. So the is required to buy insurance through the state fund and the state fund. Then there’s a system by which when claims are filed, they get adjudicated by the state. And most of the, in West Virginia and the other exclusive state funds states, employers were still allowed to self-insure that is they didn’t have to buy insurance if they could prove that they could pay the claims.

Alan Pierce:

So do you see an expansion of state fund mechanisms of providing insurance as opposed to the traditional private sector and liability casualty insurance companies?

Emily Spieler:

I’m deeply skeptical that that would ever happen, although I have to say they are more efficient, but they cut out in a very profitable side of the workers’ compensation industries. The only state fund that I think is really functioning in a way that is beneficial for everyone right now is in the state of Washington. And one of the things about the state of Washington is they also link their workers’ Comp system to their state OSHA system. And so they actually keep track of injuries and they use the information to try to do preventive work. And that’s not going on anywhere else in the US right now.

Judson Pierce:

Are there other countries that could play a role in determining how we go in the future? Have you looked at other nations?

Emily Spieler:

Yeah, I’m not as familiar with the nitty gritty of other countries as I probably think I should be, but I sit on the board of an institute in Toronto, which is largely funded by the province of Toronto. And so I’ve learned a little bit about how it works in Canada where they basically have no private insurance where they deal with things like arguments over who’s supposed to pay for healthcare by having the workers’ compensation system reimburse the general healthcare where they have universal healthcare for the cost of healthcare on claims where there is any dispute. We could use a little of that here in Massachusetts where people are ending up without healthcare because their Workers’ Comp claim is in dispute, and their general health plan, if they have one, is refusing to pay because they’ve filed a Comp claim. That’s just not okay. It’s not okay from a public health standpoint. It’s not okay from a social policy standpoint. And there are easy fixes to that we don’t seem to be able to do in most states.

Alan Pierce:

Emily, I know the politics is involved in most change that might occur in workers’ Comp outside of what the judiciary might do in a particular case. If you could wave your magic wand to take some steps now to ensure that the system of workers’ compensation as we know it continues and continues in a robust fashion, what steps would you take or what would you tap with that magic wand of yours?

Emily Spieler:

Well, for one thing, I think I would try to figure out how to include all workers no matter what the nature of their contractual relationship with the people they’re doing work for. And I would try to make sure that there were ways to guarantee that they got prompt and adequate healthcare for any injury or illness immediately. And then there’s the whole question of what counts as the right benefits and how much should be paid and how, and a lot of things that are kind of inside baseball in Workers’ Comp that I have a lot of opinions about, but I think if people knew they weren’t going to face retaliation, knew they were going to get healthcare, could go back to work after an injury, now we’re letting, and I’m sure you do this as well, in order to settle Kenny people waive their right to go back to work for the same employer, to me, that’s just not right. The ability to go back to work and go back to work without retaliation and to heal well, those are the kinds of things I think that we really need to keep our eye on in terms of how do we think about fashioning the program going forward and making sure that people are really covered. Those things are all really important.

Alan Pierce:

I want to wrap up with this. Emily, first of all, thank you for being here. Thank you for all your scholarship and your willingness to share your expertise. And again, I would echo what Judge said at the beginning of the program, the Law Review article entitled, reassessing the Grand Bargain at the Rutgers University Law School Law Review is an excellent overview of the workers’ compensation system from its very antiquity to your prognostications into the future, along with extremely footnoted and referenced group of resources.

Emily Spieler:

Yeah, they had rules about references that were truly insane.

Alan Pierce:

The title of our discussion really was The Times They Are a Changing, and that song was very meaningful to me in 1964. I can’t believe it was 64 years ago when Bob Dylan wrote the song. But thinking about today’s topic, I had an occasion to listen to the song again, and I’ll close with this. Dylan indicated for he that gets hurt will be he who has stalled. And I think one thing we want to make sure of is that the injured worker for whom the system was designed to protect and compensate in a fair, efficient manner that it doesn’t stall or continue to stall.

Emily Spieler:

I hope we can make it better in the coming decades.

Judson Pierce:

It’s been a pleasure having you on Professor Spieler Dean Spieler, attorney Spieler, all the other monikers that are so aptly appropriate for you and your scholarly writing. It’s been a pleasure talking with you today. I hope to talk to you in the future and have you on our show again. And for all of us at Workers Comp Matters and Legal Talk Network, go out and make it a day that matters. Take care.

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