--00000000000045d8a2062cb3c9b0 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable Hi Will, Based on additional review of how broad the Ohio law is, it is our assessment that it likely prohibits providing any compensation for a referral if the client is paying by long-term care insurance. The safe route is to exclude them from potential referrals. Happy to jump on a call to discuss further if needed. On Mon, Jan 27, 2025 at 9:51=E2=80=AFAM Will Reid wrote: > Steve, > Do you have an update? > > Thanks > > > Will Reid > Partner > * Please note my email has changed: * > wreid@thekey.com > 513-707-2304 > TheKey.com > [image: TheKey] > > > On Thu, Jan 16, 2025 at 12:42=E2=80=AFPM Steve Koyanagi > wrote: > >> I'll leverage some resources to see if we can get a more definitive >> answer. I'll be in touch when we know more. >> >> On Thu, Jan 16, 2025 at 9:38=E2=80=AFAM Will Reid wro= te: >> >>> I'd prefer to keep LTCi clients in the agreement. Is it possible to get >>> a definitive answer? If not we should exclude it. I don't want to put a= n >>> Ambassador at risk. >>> >>> Thanks, >>> >>> Will Reid >>> Partner >>> * Please note my email has changed: * >>> wreid@thekey.com >>> 513-707-2304 >>> TheKey.com >>> [image: TheKey] >>> >>> >>> On Thu, Jan 16, 2025 at 12:27=E2=80=AFPM Steve Koyanagi >>> wrote: >>> >>>> Hi Will, >>>> >>>> One other flag. Given the Company is looking to expand referral >>>> networks and preferred provider arrangements in 2025 we've been doing = some >>>> additional legal research in this area. There is potentially some risk= in >>>> Ohio if a referred client is using long-term care insurance as there i= s an >>>> Ohio criminal law that prohibits paying a referral fee is the services >>>> are reimbursed by a "health care plan." (See Ohio Rev. Code Ann. =C2= =A7 >>>> 3999.22(B) (creating criminal liability for offering/receiving any >>>> remuneration for referral of goods/services reimbursable by any health= care >>>> plan). Certainly, we can argue that long-term care insurance is not a >>>> "health care plan," but this is a gray area. >>>> >>>> Would you have an issue excluding LTC clients from the brand ambassado= r >>>> program or is this a significant revenue source? >>>> >>>> Let me know your thoughts and/or if you'd like to discuss via a quick >>>> call. Thanks! >>>> >>>> On Thu, Jan 16, 2025 at 9:11=E2=80=AFAM Will Reid w= rote: >>>> >>>>> Steve, >>>>> These are perfect! I will add our logo and start using them today. >>>>> >>>>> Thanks for the quick turnaround. >>>>> >>>>> Will Reid >>>>> Partner >>>>> * Please note my email has changed: * >>>>> wreid@thekey.com >>>>> 513-707-2304 >>>>> TheKey.com >>>>> [image: TheKey] >>>>> >>>>> >>>>> On Wed, Jan 15, 2025 at 1:33=E2=80=AFPM Steve Koyanagi >>>>> wrote: >>>>> >>>>>> Hi Will, >>>>>> >>>>>> I updated both the contract and exhibit based on your email below an= d >>>>>> the attachment. >>>>>> >>>>>> Can you take a look and make sure it meets what