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Camlaw details

Listing ID: 959

Title: Camlaw

Description: Discussing complementary, alternative, holistic, and integrative medicine law.

Category: Health : Alternative Medicine

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listed on: June 10, 2008 08:14:04 PM

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Anti-kickback intent changed by health reform bill - Thu, 29 Jul 2010 15:10:56 -0500

ThePatient Protection and Affordable Health Care Act makes it easier for the government to prosecute under the federal anti-kickback statute.

This is an excellent write-up from attorney Greg Piche of Holland& Hart through hishealth care blog. The anti-kickback statute ("AKS") formerly read:

(b)(1) Whoever knowingly and willfully solicits or receives any remuneration (including any kickback, bribe, or rebate) directly or indirectly, overtly or covertly, in cash or in kind—

(A) in return for referring an individual to a person for the furnishing or arranging for the furnishing of any item or service for which payment may be made in whole or in part under a Federal health care program, or

(B) in return for purchasing, leasing, ordering, or arranging for or recommending purchasing, leasing, or ordering any good, facility, service, or item for which payment may be made in whole or in part under Federal health care program,

shall be guilty of a felony and upon conviction thereof, shall be fined not more than $25,000 or imprisoned for not more than five years, or both.

(2) Whoever knowingly and willfully offers or pays any remuneration (including any kickback, bribe, or rebate) directly or indirectly, overtly or covertly, in cash or in kind to any person to induce such person—

(A) to refer an individual to a person for the furnishing or arranging for the furnishing of any item or service for which payment may be made in whole or in part under a Federal health care program, or

(B) to purchase, lease, order, or arrange for or recommend purchasing, leasing, or ordering any good, facility, service, or item for which payment may be made in whole or in part under a Federal health care program,

shall be guilty of a felony and upon conviction thereof, shall be fined not more than $25,000 or imprisoned for not more than five years, or both.

Mr. Piche notes:

The Act adds the following to the AKS:

[W]ith respect to violations of this section, a person need not have actual knowledge of this section or specific intent to commit a violation of this section.

Under existing case law, the AKS has an elevated standard of proof with respect tomens reaor intent to violate the statute, requiring knowing and willful violation, including the specific intent to violate the AKS. “Willfully”’ means unjustifiably and wrongly and known to be be such by the Defendant.U.S. v. Jain,93 F. 3rd 436 8th Cir. 1996) (“good faith” is a defense to the charge of violation of the AKS, if defendant believed that he was being paid for promotion, not for referring patients). Scienter under the AKS requires 1) that the defendant know that the AKS prohibits offering or paying remuneration to induce referrals and 2) that the defendant engage in the prohibited conduct with the specific intent to violate the law.Hanlester Network, v. Shalala51 F. 3rd 1390, 1398 (9th Cir. 1995).supra. SeeU.S. v. James,2007 WL 2174650 (W.D. KY) (payments for medical equipment referrals not a violation of AKS where defendant didn’t believe that non-physicians could give referrals and receive kickbacks under the statute).
The Act strips health care providers of an important protective barrier under the AKS and substantially tips the playing field in favor of the government by effectively eliminating the good faith defense to the AKS.

What more need be said? With the requirement of"intent" watered away, health care providers and institutions need to be ever-more careful of how they structure their compensation arrangements to as to avoid kickback penalties.

Our attorneys help clients structure their arrangements so as to properly manage thorny and complex legal arenas. For more information on our Stark and anti-kickback / fee-splitting practice, please contact our office and/or read our additional post:

Creating Legally Successful, Multidisciplinary Health Care Practices: Fee-Splitting, Kickbacks, Stark Analysis, Corporate Practice of Medicine, Unlicensed Practice, Employment, and Other Issues

Michael H. Cohenis an attorney providing business legal advice to green entrepreneurs and companies, and health care law advice to businesses and physicians, acupuncturists, naturopaths, homeopaths and others in the holistic health, wellness, and green industries. As afounding attorneyof theGlobal Vision Law Group, he represents businesses poised for vertical lift, whose leaders are conscious, intuitive, and committed to shaping a better world. Michael also advises medical spas and integrative medicine clinics, physicians, chiropractors, naturopathic physicians, massage therapists, energy healers, nutritionists and herbalists, dietary supplement and cosmetics companies, and businesses with bio-energy and other technologies and medical devices. Michael offers theEntrepreneur’s Legal Toolkitas a series of legal guides to businesses. The first legal e-book deals withContract Essentials, giving legal tips every business needs to negotiate its legal agreements; the second addresseslegal issues faced by multi-level marketing companies and individualsinvolved in multilevel marketing and direct sales; and aHIPAA Regulations and Privacy Manual.

Michael also sponsorsBeing Central, a Portal for Potential, which gives access to other,pre-paid legal services.

Read reviews of Michael’s work on the ComplementaryComplementary and Alternative Medicine Law Blog. And visit theFlat Rate Legal Servicespage for information on legal services where a flat rate or project feecan be discussed (such as incorporation for entrepreneurs, review and drafting of business contracts, trademark, and health law services for CAM providers and others).

Michael’sclientele through the Global Vision Law Group includes businesses not only in California, New York, Maryland, Massachusetts, Washington, D.C., and other U.S. states, but also abroad. Our firmalso provides special expertise to attorneys and law firms whose clients are involved in wellness industry projects or who require guidance regarding fee-splitting, Stark, anti-kickback, medical board discipline, and other health law and regulatory compliance issues.

To speak with a lawyer about health care law issues pertaining to complementary and alternative medicine, or to consult a business lawyer about laws and legal issues for entrepreneurs and new enterprises that are seeking legal advice, contact theGlobal Vision Law Grouptoday.

Complementary regulation in Canada very mixed - Thu, 29 Jul 2010 14:20:53 -0500

Canadian health law is often as muddled as U.S. law when it comes to homeopathy and traditional oriental medicine.

CMAJ reports a"hodgepodge" of regulation of CAM in Canada:

As Ontario drafts standards of practice for homeopathy and traditional Chinese medicine, the debate continues across Canada over whether or not it's necessary to regulate complementary and alternative medicine.
Province-appointed transitional councils for practitioners of homeopathy and traditional Chinese medicine are in the midst of establishing professional colleges, entry to practice requirements, standards of practice and effective disciplinary systems. This transition phase is expected to wrap up by 2012, at which time draft regulations will be submitted to the Ontario government for approval.
Right now, both homeopathy and traditional Chinese medicine remain almost entirely unregulated in Canada, as are most complementary and alternative medicine (CAM) practices.
"It's a hodge-podge patchwork, which can be confusing for the consumer at the best of times," says Heather Boon, founding chair and principal investigator of the Canadian Interdisciplinary Network for CAM Research.
Ontario will be the only province to regulate homeopathy, the practice of stimulating a patient's natural healing processes by administering minute doses of drugs thought to produce the same symptoms as the patient's disease, also known as treating"like with like." Practitioners of traditional Chinese medicine, who treat disease by restoring the flow of energy through the body with herbal remedies and therapies like acupuncture, were first regulated in British Columbia.
With regard to Canada's other CAM practitioners, only chiropractors are regulated across the country. While BC has the most stringent educational standards for massage therapy in North America— requiring three years of training for entry to practice— the profession is only regulated in two other provinces: Ontario and Newfoundland and Labrador. Acupuncturists are regulated in BC, Alberta and Quebec. The practice will also fall under Ontario's new regulations for traditional Chinese medicine. Naturopathic medicine, a system of therapeutics that emphasizes the body's ability to heal itself, is regulated in BC, Saskatchewan, Manitoba, Ontario and Nova Scotia. Alberta expects to introduce its own regulations in 2011.
Some CAM practices, like homeopathy, were once regulated under the provincial colleges of physicians and surgeons, but were dropped from the colleges' regulatory purview in the mid-20^thcentury.
"There's been a resurgence of interest in complementary medicine since the 1990s, but with that interest there's also been growing concern about the quality of care these practitioners provide," says Boon.
Despite the relative safety of the therapies they employ, CAM practitioners can still cause harm to their patients and therefore need regulations, says Janet Blanchard, policy and communications officer for the Transitional Council of the College of Homeopaths of Ontario."Unregulated practitioners may make inappropriate claims, or they may fail to refer a patient to a colleague or another profession, which can certainly cause harm. There's also the issue of sexual impropriety, which is something all health professions have to be aware of and have mechanisms for dealing with."
Without regulation, anyone can put up their shingle as a CAM practitioner, says Boon."Some naturopaths, for example, might have trained at an accredited college or school, some might have taken a weekend course, and others may have no training at all. They can all call themselves naturopaths, unless the term is protected by regulation."
Those patients who receive bad advice or care from unregulated and potentially untrained practitioners have no legal or institutional recourse, says Mirsada Vins, head of the homeopathy department at the Toronto-based Ontario College of Homeopathic Medicine."There've been individuals in the past who've tried contacting different associations for help, but without regulatory powers from the province, there's nothing those groups can do. They're just volunteers."
Where there aren't any regulations in place, a patient"may as well complain they've received bad advice or care from a neighbor," adds Boon."When a profession is regulated their college will have quality assurance programs and disciplinary committees set up to investigate complaints. But if you see someone who isn't regulated, the courts view it as poor judgment on your part, not poor practice on the part of the practitioner, unless they physically harm you. But that's pretty rare because alternative therapies are usually quite subtle and noninvasive."
For those skeptical of CAM, the"subtlety" of treatment begs the question: how can you set standards for something many people argue does not and cannot work?
"Just like setting standards for any other profession," says Basil Ziv, registrar of the transitional council."If you look beyond the homeopathic remedy, we're looking at ethical issues. And also, I think the idea is to bring all health care professions onto a level playing field and hopefully encourage inter-professional collaboration."
The medical community, however, is less eager to see that playing field leveled, says Boon."It's been argued that the state is attempting to take away the medical dominance which has been a part of our health care system since it was founded by allowing a larger range healthcare providers perform tasks that once were the exclusive domain of physicians."
Last year, naturopathic doctors in Ontario and BC celebrated legislative gains that will allow them to prescribe drugs as well as natural products (www.cmaj.ca/cgi/doi/10.1503/cmaj.109-3112).
Regulation also makes it possible for CAM practitioners to lobby for increased coverage by public and private health payers, says Boon."The government has said,‘No way, we're not paying for your services.' But at very least, regulation is a minimum prerequisite for coverage, and private health payers are maybe more flexible."
But not all CAM practitioners are welcoming regulation. Most recently, the Canadian Society of Homeopaths has stated strong opposition to the regulation of their profession in Ontario. According to a release from the society, the province needs"many more homeopaths" than it currently has in order to adequately fund a professional college and the profession should be building unity among its members before making any attempt to impose regulations from the top down (www.csoh.ca/PA_Regulation_Ontario_Background.htm).
The number of CAM practitioners in a province often plays a role in whether or not CAM is regulated, says Boon."The profession has to bear the cost of regulating and when you get to the smaller provinces, particularly out east, the economies of scale just don't make sense. There's been discussion about setting up a college that would regulate practitioners from more than one province, but there's no precedent for doing that. It's also possible to have colleges that regulate more than one profession."
According to a survey of more than 100 Ontario homeopaths conducted by the Canadian Society of Homeopathy, 86% were opposed to sharing a college with another profession, while 40% were opposed to the suggestion of regulation in any form.
"There's always going to be people who don't want restrictions on their practices, fees to pay, and who fear they may have to go through extra training to meet the requirements," says Vin.
Ultimately, Boon says, it's a question of where to draw the line on regulation."There comes a point when you just have to use some common sense, and it doesn't make sense to take advice from someone who isn't held accountable and has no education. You can only regulate so much before you're protecting people from their own stupidity."

A drum a drum NCCAM's meeting must come:

Pursuant to section 10(d) of the Federal Advisory Committee Act, as amended (5 U.S.C. App), notice is hereby given of the National Advisory Council for Complementary and Alternative Medicine (NACCAM) meeting.Show citation box
The meeting will be open to the public as indicated below, with attendance limited to space available. Individuals who plan to attend and need special assistance, such as sign language interpretation or other reasonable accommodations, should notify the Contact Person listed below in advance of the meeting.Show citation box
The meeting will be closed to the public in accordance with the provisions set forth in sections 552b(c)(4) and 552b(c)(6), Title 5 U.S.C., as amended. The grant applications and the discussions could disclose confidential trade secrets or commercial property such as patentable materials, and personal information concerning individuals associated with the grant applications, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy.Show citation box
Name of Committee:National Advisory Council for Complementary and Alternative Medicine.Show citation box
Date:September 3, 2010.Show citation box
Closed:September 3, 2010, 8:30 a.m. to 10:30 a.m.Show citation box
Agenda:To review and evaluate grant applications and/or proposals.Show citation box
Place:National Institutes of Health, Neuroscience Building, 6001 Executive Boulevard, Conference Rooms C D, Bethesda, MD 20892.Show citation box
Open:September 3, 2010, 11 a.m. to 4 p.m.Show citation box
Agenda:Opening remarks by the Director of the National Center for Complementary and Alternative Medicine, presentation of a new research initiative, and other business of the Council.Show citation box
Place:National Institutes of Health, Neuroscience Building, 6001 Executive Boulevard, Conference Rooms C D, Bethesda, MD 20892.Show citation box
Contact Person:Martin H. Goldrosen, PhD, Executive Secretary, Director, Division of Extramural Activities, National Center for Complementary and Alternative Medicine, National Institutes of Health, 6707 Democracy Blvd., Suite 401, Bethesda, MD 20892, (301) 594-2014.Show citation box
The public comments session is scheduled from 3:30 to 4 p.m. on September 3, 2010, but could change depending on the actual time spent on each agenda item. Each speaker will be permitted 5 minutes for their presentation. Interested individuals and representatives of organizations are requested to notify Dr. Martin H. Goldrosen, National Center for Complementary and Alternative Medicine, NIH, 6707 Democracy Boulevard, Suite 401, Bethesda, Maryland 20892, 301-594-2014, Fax: 301-480-9970. Letters of intent to present comments, along with a brief description of the organization represented, should be received no later than 5 p.m. on August 26, 2010. Only one representative of an organization may present oral comments. Any person attending the meeting who does not request an opportunity to speak in advance of the meeting may be considered for oral presentation, if time permits, and at the discretion of the Chairperson. In addition, written comments may be submitted to Dr. Martin H. Goldrosen at the address listed above up to ten calendar days (September 13, 2010) following the meeting.Show citation box
Copies of the meeting agenda and the roster of members will be furnished upon request by contacting Dr. Martin H. Goldrosen, Executive Secretary, NACCAM, National Center for Complementary and Alternative Medicine, National Institutes of Health, 6707 Democracy Boulevard, Suite 401, Bethesda, Maryland 20892, 301-594-2014, Fax 301-480-9970, or via e-mail atnaccames@mail.nih.gov.Show citation box
In the interest of security, NIH has instituted stringent procedures for entrance into the building by non-government employees. Persons without a government I.D. will need to show a photo I.D. and sign-in at the security desk upon entering the building.Show citation box
(Catalogue of Federal Domestic Assistance Program Nos. 93.701, ARRA Related Biomedical Research and Research Support Awards; 93.213, Research and Training in Complementary and Alternative Medicine, National Institutes of Health, HHS)Show citation box

Dated: July 21, 2010.

Jennifer Spaeth

Michael also sponsorsBeing Central, a Portal for Potential, which gives access to other,pre-paid legal services.

More healing at the borderland of medicine and religion - Wed, 28 Jul 2010 14:02:03 -0500

No surprise that religious professionals are using alternative therapies to help heal people.

CAM is used by religious professionals:

Complementary alternative medicine practices used by religious professionals.
J Health Care Chaplain. 2010 Jul;16(3):172-82
Authors: Jankowski KR, Silton NR, Galek K, Montonye MG
Religious professionals completed an online survey of their use of health related practices currently known as complementary and alternative medicine (CAM). They indicated how often they engaged in these practices and how often they had used these practices when helping other people. The majority of religious professionals used at least one of the practices when alone and when helping other people. The most frequently used practices were meditation and deep breathing exercises used both when alone and when helping others. Female respondents were more likely to use these practices on their own and when helping others than were males, and older respondents were more likely to use multiple CAM practices than their younger counterparts. Other Faith/Humanists used the most CAM practices when alone and Jewish respondents used the fewest. In general, religious professionals used fewer practices when helping others than they used for themselves. Limitations of this study and suggestions for future studies for examining CAM practices among religious professionals are discussed.

Alliance urgesuse of ABCover CPT codes for legally compliant billing and coding of medical technologies involving alternative and complementary medicine:

The world of medicine is run by billing codes. Every hospital, doctor, and practitioner who accepts insurance or Medicare uses billing codes so they can be reimbursed. But where are the codes for integrative and alternative medical services? OurAction Alertto the DHS this week asks for the incorporation of these integrative codes.
Healthcare codes describe medical, surgical, and diagnostic services, remedies, and supply items provided to patients. They are designed to communicate uniform information about medical services and procedures among physicians, coders, patients, accreditation organizations, payers (insurance, managed care, Medicare, Medicaid, etc.).
The code set copyrighted and maintained by the American Medical Association is called the Current Procedural Terminology (CPT) code. In 1983, an agreement between the HCFA (the government’s Health Care Financing Administration, which is under the Department of Health and Human Services) and the AMA made the CPT the sole coding system that could be used for billing Medicare. This monopoly completely squeezes out alternative and integrative medical practitioners.
The AMA’s codes are for treatments by conventional medical doctors, in allopathic medical care systems. There are no codes for complementary and alternative medicine (CAM) because the AMA doesn’t deal in that type of medicine; for them to create CAM codes would in fact be a conflict of interest.
There is a competing system that can fill those gaps: the ABC codes—a system of 4,400 new codes specifically designed for those 4,300,000 non-MD practitioners working in professions such as nursing, behavioral health, alternative medicine, ethnic and minority care, midwifery, and spiritual care. They are important for a number of reasons:
they are HIPAA-compliant (HIPAA is the Health Insurance Portability and Accountability Act; passed by Congress in 1996, it allows for people to transfer and continue their health insurance coverage when they change or lose their jobs, mandates industry-wide standards for healthcare information on electronic billing, and requires the protection and confidential handling of protected health information);
they can be used by both licensed and non-licensed healthcare practitioners on standard claim forms;
they complement existing code systems used in the allopathic setting;
they accurately document the care patients receive, covering a vast range of healthcare practices; and
they fulfill requirements imposed by both state medical boards and payers.
Widespread use of ABC codes is desperately needed so alternative medical providers can be fairly compensated for the services they provide, and can document and quantify the safety and efficacy of their treatments.
However, the AMA’s coding system is being spread across the board—and physicians are charged to use it, even thoughonly 15–19% of practicing physicians are AMA members. And it’s a huge business.The AMA’s own website says,“The AMA is a successful business entity that generates approximately two-thirds of its annual $230 million operating budget from non-dues sources”—which includes the hefty fees to use the CPT codes.
In 1997, the US Court of Appeals, Ninth Circuit,ruled that the AMA’s exclusivity agreement with HCFAfor using CPT“gave the AMA a substantial and unfair advantage over its competitors” and“constituted a misuse of the copyright by the AMA.” The court did not address whether the AMA’s conditions and high prices for a licensee’s use of the CPT code constituted violations of anti-trust law as well.
In 2001, when he was Senate Minority Leader, Trent Lott (D–MS)asked the Department of Health and Human Services to clarify the exclusivity arrangement it had with the AMA’s coding system. In response, the HHS approved a two year pilot project using the ABC codes. The pilot project was an amazing success, providing stunning statistics in a report showing the need for a revised billing code system—one that would include billing codes for ALL health practitioners.
According to ABC Coding Solutions, which developed the ABC codes, the AMA is now open to other coding systems, and ABC codes can work with CPT and provide supplemental information for billing, but the government has been unwilling to implement any changes that would have a greater effect on the healthcare billing system.OurAction Alertto the DHS this week asks for the incorporation of these integrative codes.
As we pointed out last week, doctors often have their hands tied by healthcare regulations. A doctor can be charged with a crime for billing an“unnecessary” treatment to the government or a private insurance company, because the CPT codes often do not allow for non-traditional services. This makes it difficult for doctors to bill their services accurately and puts them at risk of running afoul of government regulations.
There are several ways for an integrative doctor to reduce this risk. One is to not participate in any government program or accept private insurance. Another is to avoid using the CPT codes and instead substitute the ABC codes—ABC will automatically convert its code to the AMA’s code for such billing purposes. This makes the treatment more likely to be covered, and it will therefore be harder to say that it is“unnecessary.” This can be especially useful for an integrative clinic that is part of a hospital system that requires the AMA’s code.

Tai Chi keeps you young:

Tai Chi Boosts Efficacy of Antidepressant Therapy in Older Adults
July 25, 2010– Adding an abbreviated version of Tai Chi to antidepressant therapy with escitalopram improved resilience, quality of life, and cognitive function in adults with major depression 60 years and older, according to a new research conducted by the David Geffen School of Medicine at the University of California, Los Angeles.
“Fewer than half of elderly depressed patients respond to first-line antidepressant pharmacotherapy,” said Helen Lavretsky, MD, when talking about her research.“There is some information in the literature about the benefits of Tai Chi in older adults, but this relates to their balance and their physical functioning. We wanted to see whether Tai Chi would be helpful in improving depression.”
The study recruited 112 adults with major depression and treated them with 10 mg of escitalopram daily for 6 weeks. The 70 subjects who partially responded to escitalopram continued to receive 10 mg of escitalopram per day. In addition, they were randomly assigned to receive either 10 weeks of Tai chi Chih for 2 hours a week or to a lecture on health education for 2 hours a week.“Tai chi Chih is a shortened form of Tai Chi that has only 20 movements and is easier to remember over the course of 10 weeks,” Dr. Lavretsky explained.
Most of the patients (62%) were women, and their mean age was 70 years. The patients were evaluated for depression, anxiety, resilience, health-related quality of life, psychomotor speed, and cognition.
Both Tai Chi and health education patients showed similar improvement in the severity of depression, with mean Hamilton Rating Scale for Depression scores of 6.0 in both groups, Dr. Lavretsky reported. However, subjects in the Tai Chi group showed significantly greater improvement in resilience than did subjects in the health education group. The Tai Chi group also had better health-related quality of life.“Patients who were in the Tai Chi arm had a greater resilience to stress, and I thought the improvement in cognitive measures, such as memory and executive function measures, with Tai Chi was particularly impressive,” Dr. Lavretsky said in an interview.
“I’m in Los Angeles, so people tend to like alternative medicine interventions,” she added.“The limiting measure was the degree of arthritis that patients had. The patients who were in the education group liked that intervention, too, but it was very interesting to me to see that this gentle form of exercise had these superior results. Even C-reactive protein levels in the Tai Chi group were improved.”
This study was funded by the National Center for Complementary and Alternative Medicine. It has been presented at the American Psychiatric Association’s Annual Meeting in May and then at the New Clinical Drug Evaluation Unit (NCDEU) 50th Anniversary Meeting in June.

More CAM law news:

Bastyr University of Kenmore is the recent recipient, along with Fred Hutchinson Cancer Research Center in Seattle, of a $3.1 million grant for the study of complementary and integrative care for breast cancer. The grant, awarded by the National Institutes of Health (NIH) and National Center for Complementary and Alternative Medicine (NCCAM), will officially fund a project titled“Breast Cancer Integrative Oncology: Prospective Matched Controlled Outcomes Study.”
CAM use in Canada studied.....Purpose:To conduct a systematic review of reasons for and sociodemographic and disease characteristics associated with complementary and alternative medicine (CAM) use in cancer patients.Methods:Eligible studies were identified by searching the following databases: Alt Health Watch, AMED, CINAHL, CancerLit, PremMEDLINE, MEDLINE, Pub-Med, Ingenta, EMBASE, and Health Star, as well as reference lists in review articles. Only English-language articles published between 1994 and 2004 were included. Search terms includedCAM and oncology/cancer,decision making and CAM and oncology/cancer,treatment decision making and CAM and oncology/cancer, andhealth care choices and CAM and oncology/cancer.Results:Fifty-two eligible studies were identified and summarized. These studies were conducted in 14 different countries, with the largest number of studies being completed in the United States (34.6%). A therapeutic response, wanting control, a strong belief in CAM, CAM as a last resort, and finding hope were the most commonly cited reasons for using CAM. Age, socioeconomic status, and gender were the dominant characteristics associated with CAM use.Conclusion:Reasons for and characteristics associated with CAM use among cancer patients have been studied extensively. Future CAM research among cancer patients should focus on identifying decision-making processes and building theoretical decision-making models. These can be used in the development of decisional aids for patients when confronted with the choice to use CAM as part of their cancer treatment.

Michael also sponsorsBeing Central, a Portal for Potential, which gives access to other,pre-paid legal services.

Read reviews of Michael’s work on the ComplementaryComplementary and Alternative Medicine Law Blog. And visit theFlat Rate Legal Servicespage for information on legal services offered at aflat rate or project fee(such as incorporation for entrepreneurs, review and drafting of business contracts, trademark, and health law services for CAM providers and others).

Michael’sclientele through the Global Vision Law Group includes businesses not only in California, New York, Maryland, Massachusetts, Washington, D.C., and other U.S. states, but also abroad. To speak with a lawyer about health care law issues pertaining to complementary and alternative medicine, or to consult a business lawyer about laws and legal issues for entrepreneurs and new enterprises that are seeking legal advice, contact theGlobal Vision Law Grouptoday.