What now? Draft a 2-page memorandum explaining to your customer what is at stake with the lawsuits and investigations, and give a recommendation as to whether it is likely that the customer's HCSM model would prevail in a DTPA action brought by the hospital or the state attorney general. Also explain what the ramifications could be should the insurance department conclude that the HCSM was offering insurance, and recommend how to approach the insurance department to ensure such a finding does not occur