To: Speechbdispeechbd@nysed.

gov
From: irene Christoforou-Gioules
Sent: Thur 17/09/2017 4:37:25 PM UTC
Subject: Fwd: Please forward to Mr. Williams
Received: Thur 11/09/2017 1:37:31 PM UTC

Dear Mr. Wilhams,

Hope you are weil. 1 am so sorry to bother you again about the email I sent regardmg some clarification of questions I had.
This matter is very urgent and I need to have the questions below answered as soon as possible. Is there any way we can
speak te the beard attorney you have consulted with directly to let him know how urgent the answers to our questions are?
Thank you!!
Irene Christeforeu-Gioules, Ph.D, CCC/SLP

Begin forwarded message:

From: Irene Christoforeu-Gioules <mynmspecehegmail com>

Date: November 2, 2017 at 5:25:08 PM EDT
To: SPEECHBD <SPEECHBDG@
nysed. gov>
Subject: Please forward to Mr. Williams

Dear Mr. Wikhams,

We are requesting some clarification of a situation described below. There is a general LLC company that wants to work with our
(professtonal limited Hability company) and is requestmeg te do an arrangement for PEO {professional employer organization) ar
ASO (administrative services organization) services te our PLLC:

This veneral LLC has proposed an arrangement that they would obtain most of the revenues from our PLLC . while our PLLC 1s paid based on the
nercentage of payrall costs if has generated.
Since our company that is owned by licensed speech, ohysical and occupational therapists and a psycholopist, and is a professional limited liability
company, we beheve that this proposed arrancement would violate New York's prohibitions on fee-splitting and the corporate practice of
the professions (New York Education Law §

A non-professional company, such as this general LLC that is trvinw to work with us, cannot retain the entire revenues earned by our PLLC ina
narticular service line, while leaving the PLLO's members with a commission based payment.
Fisthermore, we stronely believe that this general LLC cannot operations and financial management of a professional entity such
usurp the as our

PLEC. as such conduct would violate New York's long standing prohibition on the corporate practice of professions.

general LLC has no ownership or contralhny interest in our PLLC, it has no night to dictate how much our PLLC will earn. This
Given that this
company 18 attempting to force us to work with them in this manner but we strongly believe this is a violation of New York State Law.
We are working with an attorney and he stated that this type of arrangement that they are proposing 15 a violation.
We wont Gre state board fo confine thet the arsangeent proposed above to ous company isindegs violation of New Fork State Law. Please
iar FEF

‘iso. can the questions below be answered. as u relates to the above

i-Cana PEO/SASO campany share rn the profits with a PLLC?

2-What kind of services can a PEOSASO campany provide to a PLLC and how should they get reimbursed for thase services?

3-Can a PEO/ASO retain the revenues of a PLLC, pay out the employees and pay the PLLC a percentage of the payroll for the work the PLLC
conducted?

4-Can a PEO/ASO eam more than fair market value for services provided ta a PLLC?
S-Can a PEO/ASO company earn more of the profits then the PLLC?

PHANK YOUR

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