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

QUESTION(S) PRESENTED ‘ . 1. 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"? « 2. Whether the appellate court's opinion denying COA was in error pursuant to Strickland v. Washington and Slack v. McDaniel? ;