CAROLYN PHILLIPS: Well, it looks like we've got

about 33 users with us, 33 participants from around the

country. And we're very excited that you're on board with

us today with the Pass It On Center.

A lot of this presentation was -- it was developed

from conversation that I had with some of you and -- and

it's also developed from conversations we've had with

several of you throughout the last couple of years as we're

growing the Pass It On Center.

So as I said before, this is actually probably a

series -- this is part 1 in a series of talks looking at

policies related to AT exchange programs. This one is

going to be laying some foundation and hopefully giving you

some things to think about.

If you are developing an exchange program online or

if you are tweaking yours, there's definitely things we can

learn from each other. No doubt about it. There are

several things that I wrote down last night that -- that

Georgia -- that gTRADE doesn't have on our exchange, and so

it's a continual learning process, and it's nice to be able

to learn from our peers.

That being said, definitely would welcome your

comments and questions throughout this presentation. As

many of you know, I am dyslexic, and so it's a little hard

for me to read the public chat, but I will definitely do my


And so Tom and Joy, if you see that I missed

something, just let me know.

So Tom Patterson, who is the Pass It On Center

coordinator, is going to be helping by navigating the

slides with us. We are going to be jumping in and out of

this presentation and going to Web sites and exploring some

of those so that we can learn from what some folks have


And Joy Kniskern is also going to be working with

us. She's done quite a bit of work throughout the years,

but especially in the last maybe six months, looking at

policies, working extensively with Jessica Brodey and

Jeremy Buzzell and Rob and Tom and myself. So we're going

to have Joy jump in on some of these slides and give her

expertise also.

So our agenda is pretty -- it's going to flow

pretty naturally. We're going to talk a little bit about

defining AT reuse/reutilization. Several of you had

questions about that.

We're also going to be exploring some liability

issues, just making sure that everybody is aware of some of

those things that are out there that can kind of get you if

you're not paying attention. So I want to make sure that

y'all at least hear it and can learn from one another.

We are going to talk about policies, and I've

defined those policies in this presentation. Some and --

and picked a lot of policies up from what y'all have out

there on your own Web sites.

Some of you -- I was excited to see the MonTECH

folks come on board and definitely Clayton from Arizona.

And several of you will see your own Web sites pop up

because y'all have good examples of policies and things

that folks might want to consider so -- and different ways

to approach some of these things. So you'll be seeing your

own Web sites on there.

And so we'll be then talking about procedures and

defining procedures and then practices. And we definitely

need your help, and so I'm going to talk to you a little

bit about what we need your help with when it comes to

looking at AT exchange programs, not just locally or

statewide but from a national perspective. And we'll

definitely get your questions and hopefully have answers

for you.

Joy, do you have anything you want to add at this


And Tom, we can move on to the next slide.

JOY KNISKERN: Hey, everybody. And thank you so

much, Carolyn. I think that we have a number of slides and

information that will really be helpful to you, and we're

just glad that you could join us today.

CAROLYN PHILLIPS: Excellent. Okay.

So when we were in Utah, the AT projects got

together, as many of you know, and -- AT programs from

across the country, and Jeremy and Rob were talking about

definitions of assistive technology reutilization. And

lots of folks seemed surprised. So we did want to cover

this, so we're going to spend just a few minutes talking

about this.

The overarching kind of field or the category, as

we see it, is assistive technology reutilization or

assistive technology reuse. And then, within assistive

technology reutilization or assistive technology reuse,

there are basically about five major activities.

We hear a lot of folks using these interchangeably.

And one of the first things that we did when we met our

national task force for the Pass It On Center is we talked

about, how do you define things? How do we classify


And we actually had a study group on

classification. And so we looked at those different --

looked at the different activities that were happening,

looked at what the AT programs were doing, looked at things

that are within the assistive technology community, and

then also looked at activities and definitions that are

outside of our own community.

And what we found is that we need to line ourselves

up more with what the industry is doing, not just

nationally but internationally.

So what we did is we actually looked at these and

defined it into -- and looked at these different

categories. So we've got exchange, reassign and

redistribute, refurbish, remanufacture, and recycle. And

I'm going to talk a little bit more about that in just a

few minutes.

We'll go on to the next slide that actually is one

that should be familiar to several of y'all who were at the

meeting. I actually borrowed this one from Rob. And this

is actually defining AT reutilization as what -- as what

the -- what RSA and how NATTAP and also ATAP have defined


So device reutilization includes device exchange

activities and device recycling, refurbishing, repair

activities. It also includes open-ended device loans in

which the borrower can keep the device for as long as it's

needed because these loans are considered a form of

acquisition. So that's how they're defining device

reutilization. That's how we collectively are defining

device reutilization.

Device exchange, as it's defined, once again

looking at what RSA presented last week, is it's actually

looking at -- it's want ads and that kind of approach.

They also went ahead and defined the device

recycle, refurbish, repair activities as those in which

devices are accepted, usually by donation -- and we would

say that's true -- into an inventory. They're repaired.

They're sanitized and/or refurbished as needed and then

offered for sale, loan, rental or giveaway to consumers as

recycled products.

Repair of these devices for an individual without

the ownership of the device changing hands are considered

device recycling.

So we're going to talk a little bit more about

those. That's what was presented last week. We're going

to get into more detail with that.

So the next slide actually talks about exchange and

how the Pass It On Center has defined "exchange." And the

way that -- we try to keep this very simple, that exchange

programs, which many of you have -- there are exchange

programs -- when we counted, we have about 30 -- maybe 38

states total that are involved in some type of exchange

network or exchange Web site.

Or you could be doing what Janet Gendron [phonetic]

is doing in South Carolina where you have a list serve.

But there's an exchange where you're actually connecting

users directly to AT similar to eBay or Craigslist or a

classified ad. So that's how the Pass It On Center

national task force defines that.

The next slide goes into defining reassignment and

redistribution. And we kind of see those as the same or

similar activities. So reassign, redistribute. This is

actually, you're physically touching this equipment. With

exchange you're not touching the equipment.

Here you're touching the equipment. You're

accepting it. You're making sure that it's clean. You're

identifying appropriate users. And you're matching --

you're actually matching new consumers to this reused


That's obviously a whole level of liability. You

know, your liability changes at that point. You have

different things that you're doing as far as more contact

obviously with consumers. It's definitely a more hands-on

approach. And we're actively, with the Pass It On Center,

developing policies around this and developing ways of

handling equipment and all of that.

So ... (audio skipped) ... activity that is under

the category of assistive technology reutilization. It's

similar to reassignment. But in addition to the program,

what we're actually doing is restoring the AT to its

original configuration, which means, you know, it's being

repaired, replacing parts, things like that.

Key here is that these parts are parts that

actually fit that specific piece of equipment. So you

wouldn't put a Quickie wheel, for example, on a Jazzy


I had the great privilege of meeting Josť, who's

working now with the Utah project. And he is handling a

lot of their -- he's the technician handling a lot of their

reuse and amazing work that he's doing there. And he was

very clear on this, you know -- the idea that things need

to match up.

So it's very important that -- for liability

reasons, that you keep yourself safe by -- if you're

actually refurbishing, that you're matching part for part.

So if this is a bolt that belongs ... (audio skipped) ...

Jazzy chair of the same make and model. The same thing ...

(audio skipped) ... so when you're refurbishing, you're not

adding to those. You're not creating something different.

The next slide actually talks about the activities

that we're going to -- well, one of the activities that

we're going to advise you to stay away from. And that is


We have seen this, as Tom and Joy and I have been

out and about and other folks have been out and about

meeting and providing technical assistance on site to

folks, where people are actually -- they say they're

refurbishing, but what they're actually doing is they're

stripping and building new configurations for AT.

And that's a pretty scary thing to get into. We

definitely do not ... (audio skipped) ... so hopefully

everybody's clear on that for many reasons, including --

this is when you start getting into trouble with

warranties, obviously, but liability. The FDA and other

folks have things to say about remanufacturing ... (audio


Recycling is the last of the five sections under AT

reutilization. And what recycling actually is, it's

end-of-life breakdown of AT for disposal and/or reuse and

refurbishing and remanufacturing.

So this is actually taking that Jazzy chair that

came in or the Invacare chair or the Dynavox or the HP

computer, what have you, taking that and actually pulling

parts out of it that still work, maybe storing those parts,

and then using those, matching those up to other pieces of

equipment that are the same make and model and using those


It also is the actual end of life -- or end of

useful life. Taking that chair, that computer, that

monitor, what have you, moving that on through a system

where perhaps -- for example, with a monitor that it's

smashed, the glass is used for carpet or used for any

number of other things. We've heard that monitor glass is

being used for a lot of things. That maybe the copper is

mined out of that. The plastic is being used for something

else. And gold is being mined.

And so it's actually taking that device and

changing it altogether or stripping it down. So it's very

important that we pay attention to these definitions.

A lot of us -- and I was navigating through a lot

of the exchange sites -- still use the term "recycle." So

I would nudge you in the direction of moving away from that

so that we collectively, as a organized group, can start

using these terms and so that we align ourselves with

what's happening in the reuse community nationally and also

internationally. So that's kind of where we are with those


Do y'all have any questions about any of that?

Or Tom or Joy or Rob, would y'all like to add

anything to that?

Okay. We'll move forward.

The next few slides, we actually want to talk about

liability and considering liability issues. Jessica Brodey

has been very, very helpful in helping guide us with

liability and understanding a lot more about what risks are

out there.

As I said, she will be doing a presentation on AT

exchange in much more detail looking at some of these

liability issues but also some much, much, much more detail

looking at some policy-related issues. And we're sorry

that she couldn't join us today.

But this is something that I wanted to make sure

everybody was aware of is that liability levels affect --

are affected by whether you're directly

rehabilitating/recycling the equipment or

reselling/redistributing the equipment, engaged in consumer

matching or pass-through redistribution or simply create

marketplace for exchange of goods.

So you need to pay attention to that there are

different levels of liability that you expose yourself to

even if you are just running an AT exchange Web site. And

we're going to obviously talk more about that.

Some of those, when you're looking specifically at

AT exchange, include on the next slide consumer privacy,

how is it that you get folks to sign on to your Web sites;

consumer fraud, is the person actually selling equipment

that's not theirs, or are they buying equipment and then

reselling it?

And towards the end of this slide -- of this

presentation, I'm actually going to talk to you about

something that happened here on gTRADE that was kind of

scary when it came to consumer fraud.

Also looking at safe and recommended buying or

acquisition processes and practices. Looking at illegal

activities and making sure that things are not being

exchanged on your Web site that you, first of all,

shouldn't be having exchanged.

I know one group was talking about that there was

an adapted gun, and they really didn't have any -- they

couldn't sell that on the Web site, but it did pop up on

their Web site. So making sure that those things are not

popping up on your Web site if that's against the law.

Also looking at state warranties and contract laws

and paying attention to some of those things when it comes

to your AT reuse exchange program.

The next slide actually is one that some of you

have seen probably before if you were at ATIA. And this

one actually gets much more detailed looking at Web sites.

And Tom. I see your hand is up.

TOM PATTERSON: Yeah. And Carolyn, before we move

on, I wanted to make you aware that Rob had a comment. And

he wanted folks to know how the definitions will look in

the new state plans for AT. And that is device exchange

and device reassignment, meaning everything that is not

device exchange. So those are -- that's another way of

looking at those definitions.

CAROLYN PHILLIPS: Excellent. Thank you for

letting me know that.

And so when Rob gets back with his mic -- let's see

if he's back -- just let me know. I'll pay attention to

that. And we'll keep moving forward. Thank you.

Some of what we are trying to do with the Pass It

On Center is actually come up with checklists. And

liability checklist is one of the first ones that we came

up with. And this one's specifically looking at exchange

programs. And this one is actually asking you if you have

some of these things.

So do you have written policies and procedures?

Are they posted and accepted by members outlining the

permissible use of the exchange Web site?

And that's pretty darn important ... (audio

skipped) ... where people actually commented on ... (audio

skipped) ... this had gone through their advisory council.

That's a good use of our advisory councils.

I know that we've presented some of those things to

advisory councils ... (audio skipped) ... handled through

... (audio skipped) ... are you having people use credit

cards? How are you doing that? And looking at successful

practices and tips for consumers to help them navigate the

process and ensuring that they're getting good equipment.

That's one of the things that makes me nervous,

whenever I'm going out and looking at different Web sites

is, how are we making sure that folks are getting good

equipment and making sure that they know how to navigate

this process?

And some of y'all are doing a really good job of

that. And some of you have covered yourself by saying, "We

are not responsible for that." And it's good. This is

where communication is very, very helpful.

Ensuring that sellers own the equipment that he or

she is selling and/or donating. And you may want to ask,

even if the equipment was purchased with VR funds, any

number of other funding streams, and just making sure that

they're not selling things that they should not be selling.

So, for example, a couple of the online exchange

programs, when you go through a checklist, it actually

asks, you know, "How did you acquire this equipment?" And

it has a drop-down box where you can actually see, okay,

Medicaid paid for it or VR paid for it, the school system

paid for it, what have you.

Having a privacy policy that addresses the use of

information, how you're going to use that information,

registration for use of online exchange. And also add a

notice that you will report abuse. That's very, very


An agreement checkbox. I saw, as I was navigating

through a lot of the exchange programs, that a good handful

of y'all have this agreement checkbox. Some of you even

have it so that you cannot even get through to see

equipment unless you check that you agree to the privacy

policies and you agree to the user agreements. And that's

a great thing.

Verifying insurance policies that cover this

activity and setting -- or setting aside money for claims.

Very important to do that. And once again, AT Match has on

their user agreement a piece where they say, you know,

"This is how much our insurance will cover," and it

actually -- it gets very specific. And that's a good

thing. And so I'll point you directly to where that is.

The next slide actually talks a little bit more

about some of these liability checklists and some things

that we just wanted to make sure everybody was aware of.

Disclaimers for each -- for each online exchange.

You know, releasing the organization, your board, your

staff, everyone from any liability. Very important. Some

of y'all got very detailed on this. And some other folks,

I couldn't find any disclaimer that released y'all from

liability. And so you want to make sure that you do that.

Buyer beware or buyer beware -- Joy actually says

"buyer be aware," and I like that language. Warranty

language before transactions are complete. And I even saw

on a couple of Web sites step by step how to go through

just if you have a disagreement and how to work through

that. And I thought that was very helpful.

Including a waiver checkbox so that folks actually

have to check that before they move forward. And also a

rating system for frequent sellers, kind of like you would

see on eBay. That seems to be a very helpful thing, and a

couple of y'all had incorporated that into your design.

Also looking at reporting systems. So ways that

sellers can report, ways to report sellers that fail to

deliver equipment as promised, and also means to report

illegal or inappropriate equipment that should not be

available for exchange on your exchange network. So paying

attention to those.

Also paying attention to what products are

available and making sure that that adapted gun doesn't

show up on your Web site or any number of other things.

Several of you have said that you're not going to

sell real estate even if it is adapted, you know, a

modified home. You're not going to sell it. And that's

good to be clear about those things on your Web site. So

making sure that you're aware of what products that you're

-- actually have on there, on your Web site.

And a means to track recalled and dangerous

products. So a way to actually figure out who got any

number of different wheelchairs or different devices.

We've even had computers that have been recalled -- as

y'all recall, with the Dell battery situation -- and being

able to track down those folks that might have gotten that

equipment through you to let them know that there's been a

product recall here. And then also providing information

to consumers about how to identify fraudulent products.

The next slide actually is just a reminder to me to

let you know that Jessica Brodey is going to be going even

more in depth in policies, and she's going to continue our

series in June. We'll be sending out the date and make

sure that everybody's on board for that.

And Rob, I was wondering if you were back and if

you had a mic so that you could talk to us about what you

wanted to talk to us about the definitions.

Okay. Joy is actually going to be walking us

through the next few slides, and these slides are actually

based on a lot, a lot of hard work that the Pass It On

Center and RSA and Jessica Brodey and several of our

national task force members have come together and worked

on. So these are basic guidelines for exchange programs

looking specifically at FDA.

And so, Joy, take it away.

JOY KNISKERN: Thank you, Carolyn.

And I wanted to share with you that Jessica and

some of you may have been a part of this webinar in March,

this past March. She did an entire webinar on the

applicability of the FDA Cosmetic Act and guidelines for AT

reuse programs. And it was very, very informative. And if

you go to the passitoncenter.org Web site, you can see the

entire presentation.

And so what we have done is an extract of some of

the materials that she has developed for us that relate

specifically to AT exchange programs. So this is content

that she graciously has developed for the Pass It On


And some of this information Carolyn has covered in

some of the checklist information that Jessica had also

developed for us in ways that you can reduce your

liability, mitigate risk for your programs.

And so it's very important, for example, for

exchange programs to be aware that any of the devices that

you make available for exchange, even on your Web sites

they are subject to any warning, bannings and recalls

issued by the FDA.

And so, therefore, if you're operating a program

that is facilitating the exchange of these devices that are

subject to a warning, banning or recall, you as a program

may be subject to the liability. So what can you do --

what steps can you take to mitigate that risk?

And the first thing you want to do is inform your

consumers. In some of your sign-off waiver forms in the

beginning of your Web site, you want to warn your buyers

about the risks of acquiring reutilized devices and clarify

what warranties, if any, are offered with the devices.

You want to perhaps list best practices and

buyer-beware guidelines for consumers who are acquiring

these devices. And one of the things that Jessica is going

to be working with us on is sort of like a tips or a

buyer-beware piece that you could put on your Web site.

You could modify it if you would like.

And I will say that one of the things that Carolyn

is going to be doing later on -- and Tom -- is they're

going to be walking us through a couple of Web sites. And

what you'll see up there is you will see where people have

addressed some of these things. It's very exciting to see

how many of the programs are beginning to incorporate some

of the pieces of information that you'll see here.

At a minimum, programs should request that sellers

also clarify what warranties, if any, are offered with the

device. Even if you can't control that whole process,

you're doing your job by just saying to them, "These are

the things that we want you to do to make sure that the

consumers can understand what it is that you're really

offering. And then in the consumers tips you want to

encourage those consumers to ask about the warranties and

user guides.

Okay. Let's take a look at some additional steps

that we can take here.

You want to also know your inventory. When you're

operating exchange programs, it's very important that you

have maybe one contact person in your organization ...

(audio skipped) ... on the exchange effort to be aware of

all the different types and brands of products that are

coming up on that exchange site.

And then, if that same person also goes to the FDA

Web site, you can register to receive electronic notices of

any products that are subject to bannings -- to warnings,

bannings, or recalls.

And so when you get the alert -- and I've done that

myself, so I -- in my e-mail I will get alerts about bans

and warnings and so on. And so if you're aware of your

inventory and you're also getting these alerts, if you see

something that goes up on your Web site, then you have the

wherewithal to really remove that.

You also want to include something in information

to your consumers about how to address sanitization

guidelines. Even though you're not doing that yourself,

you're informing both the sellers and the buyers that this

is important and why it's important. And again, as we

develop the tips and tools buyers-beware pieces, we'll

share that with you, and you can adopt it and incorporate

that into your online policies and guidelines about

exchange programs.

So we'll go on to the next slide.

And while we're getting to the next slide, in just

looking through some of the information that I've seen from

other Web sites, I'm not sure that anybody is really

addressing that yet to inform people that this is an

important thing to do.

One of the pieces that Jessica shared with us is in

tracking Class 1 FDA-issued warnings, bans, and recalls.

And she actually has given the Web site where you can take

a look at -- looking at whether devices that they may be

acquiring are subject to the FDA recalls or bans. So they

actually archive some of those devices there.

And so the other thing you need to do is encourage

your consumers using your site that, if they do have, you

know, a problem with a device, that they should let you

know. And then, in turn, if you -- if you get information

about -- you know, from the FDA that a product has been

recalled or banned, then you need to have some kind of --

as we were saying, some type of internal mechanism or

process by which you're going to remove that from your Web


And if you do have something that's alerted -- that

is alert that you get and you know that it's been on your

Web site, then you should have a mechanism in place where

you can let consumers know that, hey, you know, this is a

device that came out on the FDA alert list. We just want

to inform you that this is something that you need to not


We know that many of you operating your programs,

you may be working with a very small staff with many

volunteers. And as we put this document together, one of

the things we were concerned about is how are people going

to have enough staffing to manage all of this? And it's

like everything you do. You've just got to take one bite

at a time.

And so I would certainly subscribe to the FDA alert

list and certainly designate one person who can really

become aware of the inventory you've got out there and try

to implement that.

You also want to maintain business records of your

inventory and your customers. If you keep ordinary

business records regarding what inventory is up there and

the consumers who are using your database, that would be

important so that you can send out an e-mail alert about

recalls or warning issues.

Now, we know that not everybody has access to

e-mail. So you may want to have a provision in place

whereby you could notify something was -- you know, a

particular type of wheelchair battery, for example, was

recalled because it exploded or it was at risk of really

endangering somebody's life.

Exchange programs should also know whether or not a

particular type of device passed through the program which

the consumer possesses... (audio skipped) ... consumer to

inform him recall or warning. And that's -- you know, we

just think that that's an important step that somehow you

need to begin to think about implementing.

And you also want to comply -- have your program

comply with the prescription-use practices. So in some of

your information to consumers who are using your site, you

can inform them that prescription medical devices should

only be dispensed under the supervision of a licensed

practitioner. You can even lift that language right from

the slide and put it into your policies and procedures.

And we all know that even doctors prescribe devices

that you can -- you know, you don't need a prescription to

go out and purchase. And one of the things that Jessica

shared with us is there's no one place unfortunately -- for

better or worse, there's no one place where you can go and

say, "This is a prescription medical device."

So that said, I think that if you include some

language about this, and if you have some language

encouraging people to seek appropriate professional

assistance, to call your AT program if they have a listing

of providers who work with people who need higher-level

devices and things like that, those are some of the steps

you can take.

And I see that there's a question up here from

Sarah Johnnes. "Are these alerts a courtesy, or is there a

liability issue?"

Jessica has indicated that, if there's a ban or a

recall on a device that could create harm, injury, or death

to a person, and that is on your Web site and, you know,

you're providing that exchange service, that, you know,

your program potentially could be at risk if you're not

alerting that person to the fact that you received that

alert from, you know, the FDA as an example.

And if you have additional questions that go more

in depth with this, again, we can involve Jessica to work

with us on that. All right.

So exchange programs should also assess listing

products for sale to verify that the device being listed is

not a prescription device. You also want to report

adverse -- okay. You can go on to the next one about

reporting adverse events.

The FDA does not require that reutilizers report

incidents of serious injury or death involving a device to

the FDA or to the device manufacturer. However, reuse

programs should keep records of any complaints or reports

of such incidents. If a faulty device design does cause

serious injury or death, it's important that the

manufacturer becomes aware of the danger. Okay.

The other thing that you need to do is to look and

understand ... (audio skipped) ... some states have

actually regulated the reuse of medical devices. I don't

have a list right now of the states that do have

regulations regarding this. That is something that we're

taking a look at.

So what can you do? You can -- when we asked

Jessica about these questions, she had indicated you can

certainly talk with your Attorney General's office, a

vendor that you work with, a supplier that you work with,

and ask them if they're aware of whether or not your state

has any regulations regarding medical devices.

This may also be something that you need to take a

look at as it might govern contract relationships and

certain warranty promises for any kind of contractual

exchanges made through the exchange program Web site.

And it's important for you to understand in your

own state how these laws might impact your exchanges and

just inform consumers with any links that might be

available about the laws in a particular state.

So we -- our main advice is that do contact your

applicable state statutes and regulations, and just be sure

that you're in compliance with any state or local laws.

And so at this point, Carolyn is going to take it

over and talk about defining policies and procedures and

some definitions that she's found that will help you --

that will help you.

CAROLYN PHILLIPS: Okay. And sorry that we weren't

able to hear you, Merna.

So if you have a question, just let us know. We'd

be happy to answer it. And thank y'all for letting us

know. It's good to know that the sound is working or is

not working. So thank y'all.

Joy, that was excellent. Thank you for going

through that.

A few people -- as we've talked to people

throughout the country and actually internationally, we

have found that, when we're talking about you have got to

come up with policies, you've got to create policies,

you've got to create procedures, you've got to create --

you know, and look at different practices that are

successful and learn from those, that we are working with

folks who, as you know, some folks have been in the field

of reuse forever. Some folks are brand new. Some folks

are volunteers that are pulling some of these programs

together and doing a great job. So I've had several folks

actually say, "Well, what do you mean by 'policy'?"

So I went out and did a little search and looked up

several different sites. But I thought wikipedia.org had a

very good definition for policy. And basically two

different ideas here -- or not totally different but ...

(audio skipped).

So policies are basically statements on how the

authority is to achieve its goals and objectives with

regard to a specific subject area or class of subject area

or a plan of action adopted by a program which defines its

rationale for pursuing particular functions, projects,

actions or activities.

So that's basically -- when we're talking about

policies, that's what we're talking about. It's a

collection of statements of how you're going to achieve the

goals that you're trying to accomplish.

Our next slide actually gives you some ideas

building on what we've actually talked about just a few

minutes ago of what policies you need to consider.

So do you have policies addressing these areas?

And this is a very short list. We actually have a longer

list. But as we said, this is going to be a webinar series

that will grow.

So do you have a policy on accessibility; yea or

nay? It should be yea, that you are pro accessibility. So

anyway, do you have a policy that says that?

Do you have user agreements, and do you have

policies around user agreements? Do you have policies

around your users, including buyers, sellers who can

participate? Do they have to live within your county?

within your state? within your states that connect? within

the United States? within this galaxy?

Looking at donors and what's the role of donors.

And do you allow vendors to be participants or users on

your Web site? Do you have a policy on that? Very

important to make sure that you have a policy one way or

the other about some of these things because you want to

make sure you avoid trouble. Just don't leave yourself


Do you have a privacy policy? Very important to

let folks know that you do have a privacy policy, if you

do. If you don't, I would encourage you to get a privacy

policy so that folks have an idea of how you're going to

use their information.

And who's seeing their information? If everybody's

seeing their information, you know, that's a very important

thing to let people know. If nobody's going to see their

information, that's also important to let them know.

How are you going to use their e-mail? How are you

going to use their e-mail address? Also, some -- and I was

talking to Mike from Maryland, and he was actually bringing

up about the idea of anonymous e-mail that several --

Craigslist and eBay and some other groups have this feature

where you can actually send anonymous e-mail so that you

can ask questions.

And so making sure that, you know, if you have that

feature, that you let people know about that. If you don't

have that feature, maybe you want to consider that so that

folks can ask specific questions about a piece of ...

(audio skipped) ... items that can be posted, including the

condition of items, warranties, ownership.

Do you have policies around prohibited items? Do

you have policies around payments? Are they doing payments

through your Web site? And what are the policies about

that? And if they cannot do payments through your Web

site, what are your policies around that?

Shipping and transportation of items. Are people

expecting you to actually ship and transport these items,

or how are they expecting that to happen?

Dispute resolutions; do you have a policy around

that? Feedback complaints; what's your policy? And also

looking at disclaimers and do you actually have that?

So the -- it looks like a couple of people have

questions, and so if either Joy or Tom could read those to

me, that would be helpful.

JOY KNISKERN: Cathy Adams from Maine has asked a

question: "Is it becoming more common for vendors to use

exchange sites for used DME and AT?"

And then Paul Holland has responded that, "The

problem with anonymous e-mail postings is that it opens the

door to scammers praying upon shut-in (disabled)."

CAROLYN PHILLIPS: Okay. Thank you, Joy.

Yes, Cathy, to answer your first question, I have

seen that more where people are allowing vendors to use

their exchange sites. And they have a lot of policies

around that, though, of how they can use it, when they can

use it, things like that. And we can point you in the

direction of how some of these different groups are

actually doing this in practice.

And Paul, that's a great point. Thank you for

bringing that up.

The next slide actually is where I define

practices. And what do we mean ... (audio skipped) ...

practices -- I mean procedures. Sorry. Procedures.

So a procedure is a step-by-step description of how

the activity is being conducted, if appropriate

instructions should be included, precautions on how to

minimize liability.

And then the second part of that -- once again, I

got these from Wikipedia -- is a series or steps of

instructions describing a way of doing things. It's very

simple. So once again, looking at your exchange program.

On the next slide we're talking about procedures.

And do you actually have a procedure in place for the whole

range of activities that I asked you about? Do you have


But do you have procedures as far as, you know, how

it is, the step-by-step instruction of how people get into

your Web site? Do they have to log in, or is it open to

anyone? What does your welcome look like? What kind of

language are you using? And accessibility; do you have

step-by-step instructions of how to use and navigate your


Accessible user log-in and confirming user

agreements and making sure that you've got that in an

organized way, very succinct way of doing those things,

making sure that people have to actually click on or even

scroll down and read or at least look at the words in your

user agreement.

Finding items and equipment, categories, check

boxes. Do you have, you know, instructions on how to do

that, how people can actually navigate your system? Some

people have gotten very detailed -- actually a handful have

gotten really detailed on how you navigate the exchange Web

site that they've put together.

Also instructions on how to post or list equipment.

And some people have done a good job of actually making

bullet points and giving people examples of descriptions

and, you know, what kind of photos and how to take an

appropriate photo and things like that; making sure that

people are not necessarily in the photos of the equipment

that they're posting; things like that; and giving

step-by-step instructions.

Addressing ways to check the condition of the

items, the warranties, the ownerships. And then also that

step-by-step instruction of how to resolve different

disagreements. I think AT Match did a really good job of

that, so I'll show you that in just a minute.

And it looks like maybe there's another question.

Oh, okay. I think you said, "Thank you, Cathy." And

you're welcome. So all right.

The next slide actually gets into practices. And

what we mean by practices is -- once again, I went to

Wikipedia and defined this. And I did consider other

resources out there.

But practices are techniques, methodologies,

procedures, and processes that are used in an organization

to get the job done. It's a case study considered to be a

good example of a discipline. So looking at successful

practices, new ideas, or lessons learned about an effective

program activity that have been developed and implemented

in the field and have been shown to produce positive


So those are all -- when we're talking about

practices, what we're actually showing -- going to show you

is how these things have been implemented in the field.

So the next few slides actually take us back to

that conversation that we had with Rob and Jeremy in Utah

and looking at how are you defining your exchange program?

These were actually adapted by me from the state plan

program review questions. And we're going to zip through


So basically looking at how do you actually define

yours? What describes your type of exchange best? And

looking at who are you serving? Is it serving your state,

other states, what have you?

The next slide actually asks a question in more

detail of, you know, who is it that you're serving? Are

you serving an entity or an agency or certain community?

And what is the purpose of your exchange? Those things are

very important as you're defining your policies and writing

your policies, looking at your procedures, and then putting

those into practice.

The next slide actually talks about what happens

when a device is exchanged. Is it a direct, you know,

consumer-to-consumer transaction, or is the state AT

program involved?

And the reason why I pulled this one out in

particular is because you're definitely looking at very

different policies and different procedures with those two

different view of how your -- the device exchange is

happening and also different liability. So you want to pay

attention to those things.

The next slide actually takes us, you know, down

another road of asking some other questions about how are

you actually having folks pay for the device? Is it a flat

fee for posting a device on your Web site? Is there only a

few ... (audio skipped) ... devices exchanged? And -- you

know, is it a combination? Are there lots of folks, you

know, involved in this?

And then the next slide -- the next few slides

actually are ones that several of y'all came up and talked

to me about when we were in Utah, which is looking at the

program performance and seeing is there evidence that a

device reutilization activity increases the acquisition,

and what are some ideas around that?

And so we're actually going to be looking at some

strategies around that in marketing and making sure that

you're protecting yourself.

The next slide is another one -- is another one of

those program-performance questions that you want to

consider. Is there evidence that the structure of this

activity makes it possible to meet the needs of individuals

and entities of the state? And how do you do that? And

some folks are doing a really good job, and so we want to

be able to help share that information.

The next slide is the last in this series.

And Rob, I'm not sure if you wanted to add anything

to this conversation or this piece.

But this is making sure that there's evidence that

the grantee or that the program is employing safeguards to

protect the privacy of users and ensure the integrity of


So building this foundation of looking back at why

are we -- how are we defining AT programs and then the

liability issues involved. And then if you are part of the

AT act program, looking at now that there's program

performance is also a part of the reason why we want to do

these things.

We're now going to show you some of how your peers

have done some of these things around the country. And so

first I'm going to take you to the Pass It On Web site.

And this is our home page. And hopefully you have been

there. We're getting hits like crazy every day, which is

very exciting.

And we're actually going to go to the "Find AT"

piece of our Web site. So here, if you'll scroll down, you

would actually see that we have listed every exchange --

online exchange network that there is in the country.

So Martha and Liz Persaud on the Tools For Life

team actually went and got all this information for us.

And we found that there's anywhere from 32 to 38 states

that are involved in some way in exchange.

So if you don't see your exchange program listed,

please let us know, and we would be happy to put it up

there. And we do test these links just to make sure that

they're all active. And so -- so please let us know.

And we're going to talk to you in more detail about

an exciting idea that we have about creating a national way

of connecting everybody.

The first Web site that I wanted to show you is

just a different way of getting information across, which

is what Arizona did. And Arizona, if you click there on

the Arizona Web site -- and Tom's actually going to do that

for us -- then you can actually see the first thing that

comes up is actually -- okay. Actually, we'll go back to

Arizona in a moment.

AT Match -- AT Match also gives a lot of good

examples of how you would actually -- might want to list

some of your policies and your procedures.

And so if we go to AT Match -- and I'm not sure how

many of y'all have actually been online there -- you can

actually see it's very simple. They explain what it is

that they're doing. They give you the option ... (audio

skipped) ... to log in.

And if you actually go to the register, if you

click on their register part of their Web site, then it

gives you all the fields where they're actually asking very

detailed questions.

And a lot of people have actually done this -- you

know, they've done a similar layout. But they've actually

put in here different things -- for example, things that

are required. So ZIP Code absolutely required.

The folks actually have a user name. You know,

that makes sense on how you would actually do that -- that

they are entering their e-mail. That's another required


And then if you look down here at the very bottom,

it says, "The terms of use are required." And so you

accept or you don't accept, but you must accept in order to


And then they have a box that actually has their

user summary -- user agreement summary. And in here it

gets very, very detailed about who can use their site and

how you can use their site and, if you do have a problem,

you know, who to report that to.

And this is stuff that often a lot of people would

not pay attention to, and they would just hit "Continue,"

and that's okay. But they've at least covered themselves.

They do have -- within this box, they actually have

in there that the site and its services are as-is, no

warranty, no condition, no expressed or implied -- you

know, nothing is implied there. They specifically disclaim

any implied warranties of title, the fitness and all of

that of the equipment.

They also say very clearly that their staff, the

officers, the directors, the employees, the suppliers, are

not held responsible.

And if you scroll down further, it actually talks

about that any third parties and any circumstances limited

to the greater of amount of fees the member pays to

AT Match in the 12-month period prior to the action giving

rise to the liability or a hundred dollars. So they've

really watched themselves ... (audio skipped) ... within

their liability agreement point people to their privacy

policy, their fee schedule and listing policy, forbidden or

discouraged items policy, their transaction count, and

feedback and complaints policy.

All of those things I would encourage you to look

at and see what it is that AT Match has done and how

they're covering themselves.

And the very last thing that they do is they

actually say, you know, "If you are aware of something

that's going on and if you want to get in touch with us, if

there's something we need to be aware of, here's our

information," which is great. So very good information

that they have posted there.

The next piece with AT Match that I would like

y'all to pay attention to is, if you actually go to "Buy"

which is at the very top of their Web site, you can

actually click on if you want to buy an item.

And so you can click there, and it should pull up

different information related to -- you know, if you're a

buyer, here's some things that you need to be aware of.

And it talks in detail here. It gives you ideas about, you

know, how to file a complaint and how things are monitored.

AT Match -- at the very bottom, it says, "AT Match

will monitor complaints from buyers or sellers and may

suspend the registration of any person found to be in


It also points you to AT Match policies at the very

bottom. And so if we can go ahead and click on those

policies. And that -- and if you scroll down to the very

bottom of that page, it takes you to privacy policies.

And if you click on the "Privacy Policy," then that

actually brings up a very extensive privacy policy. And it

talks about, first of all, their commitment to privacy and

talks about how information is collected from the member;

that nothing is collected prior to registration; the

information -- how it's actually going to be used; and why

they would need this information. So that's why they

actually, in No. 2, talk about the use of the information.

They also talk about the disclosure of your

information. As a matter of policy, they're not going to

sell or rent your personal information to third parties.

That's very ... (audio skipped) ... how you can use their

information that you shouldn't be using it. So that you

agree other users may use your personal information to

communicate with you, and that's it, that it's not about

spam; it's about avoiding spam.

And then they actually get into how to control your

password and accessing, reviewing, and changing personal

information. And security is another area that's listed

here that they pay attention to.

At the very bottom they actually talk about, you

know, who accepted this -- these policies and how they

change their policies, which is very helpful, and also when

it was changed. So it was effective March 31st in 2005.

So very helpful.

If we go back to the main site of AT Match and we

actually go to "Seller," then that actually brings up other

things that you might want to consider when it comes to

policies and the way that you might want to word specific

things on your Web site in order to kind of protect


So here they talk very clearly about that you have

to register if you are going to sell. And AT Match, as

many of you know -- actually they do use PayPal. It is an

auction, and so they talk about how their auction works and

what that looks like and how to actually donate an item and

then also how things are bid. And they talk also in detail

about how to list. So they get into the procedures of how

to actually do some of these things.

So very, very helpful, the way that they've laid

some of this out.

And at the very bottom, they get into -- if you

click on that "Complaints," area then it's a hyperlink to

their complaints policy and transaction ... (audio


And this was -- I was very impressed with this, how

they actually get into -- it's an eight-step procedure of

how you file a complaint, things that you might want to

keep in mind. So very, very well done.

So it talks basically about you want to communicate

with the seller; you want to check your e-mail to make sure

that no messages have been blocked; you want to check your

own contact information; you want to call the other person;

you want to go to PayPal and also your credit card company,

make sure things are smooth there; allow sufficient time.

So very good way that they laid out the procedure

of how to handle complaints and all of that.

So it looks like that there's some questions that

have been asked. And so I'm going to pause here as we pull

up the next -- more of the presentation.

And Joy, if you'll read those to me, that would be


JOY KNISKERN: Yes. Let's see.

Paul Holland from DC Shares commented, and he says,

"Nit-picky point. Nowhere on the main pages does it tell

the reader where this is located geographically. Have to

dig it out from the policy complaint page to learn it's

Kansas." And I responded, "Good point, Paul."

Then Cathy Adams asked a very good question, and

that is, "Do you know if every item that is posted on the

AT Match page is reviewed before it goes live on the active

site." And I don't know the answer to that question, but

it is a good question.


To answer your question, Cathy, my understanding is

that that is how AT Match is set up, that items are

reviewed before they go on-site, go live. That's my

understanding of it whenever I've talked with folks.

And Paul, actually it's -- the AT Match is --

there's several states that are involved in that. So it's

not necessarily just a Kansas thing. So yeah. So that's

how that actually works.

Going back to -- and Tom, if you'll go back real

quick to the Arizona project.

I wanted to show y'all that, as soon as you log

into the Arizona Assistive Technology Exchange, the first

thing that they have is their disclaimer. So they are very

clear about -- you know, "First, well, welcome, and this is

what the AT exchange is. It's a classified ads. But here's

our disclaimer."

And in order to move forward in the site, you

actually have to click, "I've read and accept the terms."

So they've done a good job here, you know, protecting

themselves and, you know, moving forward. So they don't

even get into the log-in area or any of that. They move

straight from this is where -- this is the information that

we need to make sure that you know about us and how we

operate. So I would encourage you to spend some time and

look at that.

The next site that we're going to review is

actually looking at "getATstuff." And I was very excited

about where this group is moving.

And we'll keep moving through these slides, Tom.

And -- oh, well, actually, if you go back one

slide. This -- one more slide. Sorry. One more slide.

This is a slide that actually talks about what's

prohibited, and that's very good information there about

what they will not sell and what they will not exchange.

The next couple of slides actually take us through

some of their different policies for AT Match. And you'll

see alcohol beverages, tobacco, stolen property. None of

that. Their feedback and complaints policy ... (audio

skipped) ... I apologize.

The next couple of slides are about their feedback

and complaints. And we'll move through those.

And then they actually have some good information,

if you keep going, through how you can actually get the

equipment. And I thought that was very helpful that they

actually talked about freight and parcel and shipping and

some general things that people should be aware of.

And then they actually get much more detailed in

the next slide about possible shipping companies that you

might want to talk to or communicate with. And they give

direct links. So they've done a good job here researching

a lot of that.

The next site I want to take you to, as I said, is

actually the getATstuff site. I'm very impressed with what

they've done here. It's very friendly. And they have a

great welcome. And they also -- here what they've done is

kind of created this differently.

So Paul, you'll see that they actually list the

states that are partners in here. And they also have them

in their logo. And it's the Assistive Technology Exchange

For New England. And you can actually select your state

and move through this one and get connected.

So I was very impressed with their layout and how

clear it is. And they've also respected the individuality

of each of these states. And there are different policies

that seem to pertain to different states, so I was able to

find specific policies or specific things for each state if

I had a question. So that was very well organized.

If we go back to the presentation, I'll show you on

the next slide where the getATstuff folks have -- and we'll

go to the next slide -- and I was just going to show you

where they have done a good job being very simple in their

policy of how -- you know, who can use their Web site, what

types of equipment can be listed.

It's very friendly ... (audio skipped) ... easy to

understand. And this is actually -- you can find this

information in their frequently asked questions.

But once again, these are -- these lean towards

policies of who we are, what we do, why we do it, and also

what equipment will not be listed. And you'll see here

that they actually have ventilators and things like that.

AT For All has done a great job with their layout

and design. And they've got several folks that are using

their system. And I was very impressed with kind of the

way that they've actually got their policies laid out;

their agreements, you know, what you need to do before you

create an account, what you're agreeing to; their one-stop

resource, and all of that. So very impressed with the way

that they've done that.

So we'll go to the next slide, Tom.

And on the next slide, we actually have more

information ... (audio skipped) ... you know, age. And not

everybody -- when I was looking through a lot of

people's -- the way that they're actually putting their

policies and procedures into practice, not everybody has

included age. Not everybody has included things like that.

Their policies here are very simple, that they're

not responsible for technical support, repairs, misuse all

of those things. They're not responsible for that.

And they're actually very clear -- and I thought

this was very good, and I also saw this on the Delaware

site -- that it's very important that you also involve

appropriate professionals when choosing assistive

technology devices. And they list occupational therapists,

physical therapists, other folks. So I thought that was

very good in helping people understand the importance of


The next site that I wanted to bring your attention

to is actually MonTECH. And MonTECH -- they have a very

simple welcome and -- very, very simple, very easy to


And we'll go to the next slide, Tom.

And on that next slide, we actually have found

where -- and actually the next slide after that.

Excellent -- where they talk very simply about how they've

set up their exchange program.

The equipment exchange agreement, very simple;

whose responsibility it is, you know, to do certain

activities; it's the seller's responsibility to provide

accurate and detailed information; that the Montana

Assistive Technology Program functions only as information


So they're very clear about their role, and that's

helpful. And also how long listings are going to be on

their Web site.

The next slide goes a little deeper into some of

the agreements that they have on the equipment exchange.

They talk also about a customer satisfaction survey is

definitely going to be mailed out, and it's good to let

folks know about that. I thought this was very clear, very


And then also, once again, they were very clear

about, by accepting the terms, you're not going to hold the

Department of Public Health in Montana or the Montana

Assistive Technology Program or the University of Montana

liable. So very, very clear.

The next Web site that I just wanted to point out

just a few things -- and I'm actually going to just --

these are on the slides.

The next slide, it talks about the buyer scam

that's been out there. And so this is one of the first

things you find when you go to the gTRADE, Georgia

Assistive Technology Equipment Exchange Program's Web site.

And this is because we actually had this happen

where a ... (audio skipped) ... and then make out a money

order for more than the seller was asking. In return, the

seller was going to cash the money order and send the

difference back to the buyer. The money orders are

counterfeit. And if the seller cashes them in, then

they're held responsible.

So this is the first thing that you actually see --

one of the first things that you actually see on our Web

site because this did happen, and we want to make sure it

doesn't ever happen again.

Georgia also has our disclaimers. The next slide

just is a simple disclaimer that gTRADE -- you know, what

we're going to warrant or promote or endorse, any of that


So that's basically how a lot of these different AT

programs -- how they're implementing their policies, how

they actually have created some of their policies, some of

the policies that are out there. Very, very good


And this PowerPoint will be available to all of you

via our Web site. And if you want, I've already had a few

people ask if I could send the PowerPoint to you. We'd be

very happy to do that.

The next few slides are actually ten steps for

successful AT exchange programs. So we're going to zip

through these real quick.

First one is think safety first. Sanitization.

Make sure that you, in your procedures on your exchange Web

site, that you actually teach people about sanitization.

And you can point them to the Pass It On Web site. That's


The next slide actually talks about making sure

that you're considering accessibility and are Google and

Yahoo and other search engines able to find you and your


The slide that is the next one actually is -- Mike

Bullis from Maryland said this to me when we were sitting,

having lunch. And he said, "If you can't Google it -- you

know, if I can't Google it, then it doesn't exist." And I

thought that was very, very interesting when we're talking

about -- and I actually feel the same way sometimes, that,

if I can't find it through Google, it doesn't exist.

So see if you can Google your ... (audio

skipped) ... and actually get to your information.

Plan for the future. You know, anticipate the way

that your online exchange program is going to grow. I know

some you are still doing list serves, and that's great.

But think about where you want to move in the future and

how you want to move in the future.

The next slide actually encourages you to observe,

measure, and document your current activity. Because, when

we're looking back at what Rob and RSA are looking for,

it's trying to figure out, how are things growing?

So we encourage you to take a fresh look at your

exchange network and find out where people are going and

where they're not going and help people design their

slides -- I mean not their slides -- their ads so that it

encourages people to look at their information. So

document equipment flow and track trends.

The next one talks about analyzing your AT reuse

data, figuring out where are you marketing and where are

you not marketing. So pay attention to that.

And No. 6, I would encourage you to ask for input

and develop recommendations. I actually have had friends

and family try to find equipment.

My sister is a physical therapist, and I'll say,

"Hey, can you look and see if you can find this piece of

equipment on our Web site?" And that helps us figure out

how we need to navigate because she knows a lot about

equipment. So what is it she's looking for?

I've also asked my dad to do the same thing, who

does not know anything about assistive technology really,

aside from that his daughter is involved in it -- both

daughters. So, you know, get their input and see if your

language makes sense.

Evaluate the options that you have and see, you

know, what it is that you've got when it comes to -- and

based on your evaluations of safety, cost, implementation,

ease of operation. Making sure that things are flowing.

When are your ads going on? How are they coming off? Are

people checking that they agree when they first come onto

your Web site? Things like that.

No. 8 talks about selecting and verifying that you

have the best design for what works for your state, your

region, what it is that you're trying to do. And then

implement that design, if you're tweaking the design, if

you're adding your policies in a certain area. Just like

Paul asked, you know, how do I find out what state this is

for? Things like that.

And then No. 10 is one that you probably have heard

me say many times, which is evaluate and evolve. Be

proactive in your solutions and grow with your program.

So I'd encourage you to have happy exchanging and

call on us if you need any assistance. We hope you learned

something today. I know that, in putting this together, I

definitely learned quite a bit.

And we do need your help. We would like to hear

from y'all. Not necessarily right now. We're going to

send out a survey at some point about whether or not the

Pass It On Center should develop a national exchange

database to help search your different exchange programs.

We have a lot of folks coming directly to the Pass

It On Center. I was talking to Amy from Pennsylvania, and

she actually said that one of her consumers got connected

to their reuse program through our Web site. We see this

again and again, and I've heard it again and again. And

we're very excited about that. So we need to see how we

can maximize that.

And the last thought that I have is we want to

thank you so much for your time and your interest. We hope

this was helpful. We'll be sending out an evaluation. I

know that was a lot of information really quickly.

So do y'all have any questions? I'm going to be

around for just a little bit longer.

I see that we still have 38 people that are with

us, and glad y'all have stuck in there with us.

Joy and Rob and Tom, do y'all have anything you

would like to add or any questions?

JOY KNISKERN: I think this was a lot of

information. And again, the webinar presentation will be

posted on the Pass It On Center Web site. And so you're

certainly free to review that and share it with other


And we did get some questions today that we know we

need to do some more research about. Sort of thinking of a

survey of programs to find out how many of them are dealing

with this issue of vendors who want to vend on their Web

site and looking at specific policies around that.

So thanks, Cathy, for that suggestion.

And thank you all for joining us.

And thank you, Carolyn and Tom.

CAROLYN PHILLIPS: Excellent. It looks like we do

have a question or two.

It looks like the first question is, "What's the

most popular database that centers are using for tracking

the equipment?"

And the answer to that is that it varies. I'm not

sure that there necessarily is a most popular database.

But what we'll do is actually take that question and ask

several folks and see what their answers are and get back

with you. So if you'll actually send us your information,

then we can e-mail that to you.

And Mike, I see that you said sorry about showing

up as late as you did. "Is this downloadable?"

And Tom, do you want to address that?

It looks like you did. The presentation will be

available at the passitoncenter.org,


And it looks like, Paul, you wanted that

information about the database. So we'd be happy to share

that information with you also.

And we can actually -- I can add that to the

presentation, and we can create a slide and put it in there

if that would be helpful. No problem at all.

Other questions that you have?

Thank you, Mike.

I really appreciate y'all hanging in there with us.

I know this was a lot of information. I hope that it got

some of the answers to you that you ... (audio skipped) ...

where you can -- procedures that are out there as well as

some ways that they're turning into practices.

So thank you all. I really appreciate it, really

enjoy working with you. And as always, we here at the Pass

It On Center are here to help you. So keep in touch with

us. Take care.