Whether pursuant to Medicare regulations defining the terms "off-site," "campus," "remote location," and "satellite facility," established that Petitioner's PHP was not operation in violation of Medicare's requirement that treatment must have occurred under a licensed physicians "direct supervision"?

Whether the appellate court's opinion denying COA was in error pursuant to Strickland v. Washington and Slack v. McDaniel?

Whether Petitioner's PHP was in violation of Medicare's requirement that treatment must have occurred under a licensed physician's direct supervision?