MUST READ: R.E.A.C.H. Comment Opposing CMS’ Proposed Rule– “The End of How Many Family Businesses?”

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So R.E.A.C.H. is up and running with members hopping on board daily. Super cool to see.

The final standards were just submitted today to CMS along with a comment that you absolutely must read. This thing is amazing. You can find it here–REACH Comment

Here’s a little taste:

Adopting a rule that prevents TPMOs from working with each other, assures that all of the small players are dead. They cannot offer services to beneficiaries when they have no connection to any company that can assist those beneficiaries directly. So the small companies cease operation.

And a business is not just a place where people work. It is a dream that someone turned into reality. Every business takes investment of time, money, and self. No government entity or regulator should carelessly end such a dream or lay such investment to waste without compelling reason—especially where, as here, it is being done without any form of due process.

The companies to be put out of business have not been found to have engaged in illegal activity. Yet, it seems, CMS has found all guilty by association. Because some in their midst have sinned, a collective death penalty is to be issued.

R.E.A.C.H. urges CMS to recognize the impact of its Rule and course correct. There is a better way.

No punches pulled.

This proposed Rule would destroy countless lives and R.E.A.C.H. is going to do everything in its power to prevent that from happening. Give the overall comment–which I suspect will be the most impactful CMS receives–a read and share your thoughts.

Want to help the cause? Reach (pun) out and let’s connect. Thanks to all–especially the FOUNDING MEMBERS that are joining now.

Hats off to Queenie and Countess for this outstanding comment. They really are amazing. And I hope everyone appreciates their work here!

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Published by Eric J. Troutman

The Czar of TCPAWorld Eric Troutman is one of the country’s prominent class action defense lawyers and is nationally recognized in Telephone Consumer Protection Act (TCPA) litigation and compliance. He has served as lead defense counsel in more than 70 national TCPA class actions and has litigated nearly a thousand individual TCPA cases in his role as national strategic litigation counsel for major banks and finance companies. He also helps industry participants build TCPA-compliant processes, policies, and systems. Eric has built a national litigation practice based upon deep experience, rigorous analysis and extraordinary responsiveness. Eric and his team feel equally at home litigating multibillion dollar telecommunications class actions in federal court as they do developing and executing national litigation strategies for institutions facing an onslaught of individual TCPA matters. They thrive in each of these roles – delivering consistently excellent results – while never losing sight of the client experience. While many firms now tout TCPA expertise, Eric has been there from the beginning. He built one of the country’s first TCPA-only defense teams and began serving as national TCPA counsel for his clients nearly a decade ago. This perspective allows him to swiftly develop the right litigation strategies for dealing with recurring problems, without wasting time on tactics that are bound to fail. Eric’s rich historical perspective and encyclopedic knowledge of the TCPA landscape also make him an invaluable resource to institutional compliance teams struggling to comply with the shifting regulatory landscape. No task is too small – or too big. Indeed, Eric and his team have helped build TCPA-compliant systems and processes for some of the largest and most complex corporate entities in the country. He commonly works with in-house compliance counsel to build and implement enterprise and business-line specific TCPA solutions, performs TCPA audits and drafts and reviews proposed TCPA policies and procedures. He and his team also have the technical expertise necessary to assist call centers seeking to develop TCPA-resistant call path architecture or to modify existing telephony and software integration to better insulate from potential TCPA exposure. Eric has built a reputation for thought leadership. An avid blogger and speaker, he has been at the forefront of the industry’s effort to push for clarity and a return to sanity for the TCPA for years. He was selected to advocate for the financial services industry on important TCPA issues before the Federal Communications Commission and co-authored the nation’s only comprehensive practice guide on TCPA defense. In his spare time, Eric leads defense teams representing banks and other financial services companies in consumer finance litigation matters. He has experience representing clients in UCC, TILA, RESPA FCRA, CCRA, CLRA, FDCPA, RFDCPA and FCCPA claims, as well as in fraud and bank operations issues.

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