AHLA's Speaking of Health Law
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AHLA's Speaking of Health Law
Hospitals and House Slippers: Shifting Care to the Patient’s Home
Hope Levy-Biehl, Partner, Davis Wright Tremaine LLP, and Ryan Thurber, Shareholder, Polsinelli PC, discuss the growing trend of shifting patient care for acute illnesses into the home. They cover the federal hospital at-home waiver, state-level developments, special considerations related to the at-home care model, factors driving the growth of the model, and the future of at-home care. Hope and Ryan spoke about this topic at AHLA’s 2024 Institute on Medicare and Medicaid Payment Issues in Baltimore, MD.
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Speaker 2:This episode of A HLA speaking of health law is brought to you by A HLA members and donors like you. For more information, visit american health law.org.
Speaker 3:Hi, everyone. Uh , my name is Hope Livi Beal , and I am a Los Angeles based healthcare regulatory attorney. I'm co-chair of the Healthcare Practice Group at Davis Wright Tain . I'm here today with Ryan Thurber , who's a fellow healthcare attorney at Postelli in its Denver office. Uh , Ryan and I had the chance to present about the shift of hospital and other care to the home setting at the A HLA Medicare Medicaid Institute program in March of this year. Um, I have had the opportunity in my practice to work with a number of hospitals exploring hospital at home programs, and Ryan has a different lens and has had the opportunity to work with other providers and suppliers who are looking to build up hospital or care at home programs. Um, and so we have slightly different perspectives, and we're excited to have the chance to get together again today and to share , uh, share some updated thoughts. Um, so Ryan, why don't we, why don't we start with you? We'd love to , um, get an update on the federal Medicare Hospital at Home Waiver. The last time we spoke, I know it was a big open question. It came up at a few different sessions about what would happen with the Medicare waiver after 12 31 20 24.
Speaker 4:Thanks, hope and, and hello everybody. It's a pleasure to get to spend some time with you and then talk a little bit about this fun issue, which affects all kinds of provider types all across the country and a whole wide range of different , uh, parts of the healthcare continuum. Uh, I hope you're right. It's still, when we, when we spoke back in March, we had a lot of uncertainty about what was gonna happen. The, the Hospital at Home Waiver program, which is kind of the, the genesis really for the dramatic expansion of hospital at home programs across the country during the, during the pandemic , uh, is a little bit hanging in the balance right now. It is set to expire that formal, you know, waiver authority is set , set to expire at the end of this year unless Congress takes action , uh, to move it forward. At the time of the MMI conference, there was a proposed bill in the Senate. It was pretty skinny. It didn't do a whole lot, but there was a bill out there to extend it , uh, at least for a brief period of time. Since the conference, though, we've had some action on the house side of Congress, there is a bill that's been introduced and has actually made its way all the way through committee , uh, at this point, and is ready at some point here to be, you know , have action taken outta the house floor , uh, that would extend the hospital at home program for another five years. Um, it is a bipartisan bill that passed unanimously at a committee. Uh, and, you know, the way it looks, it's, it's tied also to a lot of other kind of important healthcare priorities, like the extension of telehealth flexibility, for example. And so it does look like there's room here, or there's motion here , uh, to, you know, preserve the program to keep it going and, and to allow folks who have already invested a lot of time, energy, and resources , uh, and to developing these programs to get to do so. So that's the good news. The good news is, you know , at the federal level, we are , uh, tracking towards at least having momentum towards an extension here. Um , and so that will help a lot of providers , uh, feel more comfortable, hopefully, about continuing their programs, about investing additional resources , uh, and moving things forward. What makes things a little bit more challenging, I think, for our, our providers, especially those that are doing the traditional path, is how states are reacting to action at the federal level towards the end of the pandemic. And , and hope, why don't you give us an update there? What's happening in the states?
Speaker 3:Sure. Um, it is exciting to, to see some traction on the federal side. I think, you know, at the state level, it's still a bit of a smorgasborg. So I think, you know, if you've seen one state's approach to hospital at home or care at home, you've seen one state's approach. Um, really the bottom line is that I think if you're considering one of these programs to deliver acute care at home or, or a similar lookalike program, it's always gonna be important to look at both the federal requirements and the state requirements since states have taken really such a wide range of approaches to how to regulate these types of programs. Um, I guess today for, for our conversation, I just wanted to highlight a few examples to show the range of approaches that states have taken. Um, this is also evolving in real time , and certainly, you know, I think as there's more certainty with the federal program, that will also impact the states as well. Um, so start with California, which is where I live, and the landscape that I work in. Um, cutting right to the chase. There is currently no hospital at home program in California. Um, during the public health emergency, California , um, did have a modest program, the Department of Public Health, our state licensing agency took the position that in order to operate a hospital at home program, a hospital had to obtain the state equivalent of waivers , um, but not a blanket waiver, actually , uh, individual waivers for each and ever every regulatory requirement that needed to be flexed in order to allow the programs to operate. So it was a pretty onerous process in California. Um, there were only a handful of providers that made it through that process. Um, and even fewer actually got their hospital at homes propped up before the end of the public health emergency. Um, and as the public health emergency came to an end, the Department of Public Health in California determined that it no longer had the authority to grant those flexibilities. And so at the end of PHE , the California PHE , um, all of the California hospital at home waivers cease to be effective. Um, so today, hospital at home programs in California are on pause. Um, they can't go further pending a legislative change. Um, so that's sort of the, the state of affairs in California. That's pretty extreme. I think there are other states that , um, have taken a hybrid approach. So a state like Arizona, for example, started off with a three year pilot program for a hospital at home program. Um , it's since extended that, so it's now extended out to 2026. It's a voluntary program. Um , it is akin to the hospital level of care that hospitals are permitted to provide at home if they meet programmatic requirements and they get approval from the state. Um, so things interestingly, in the Arizona program , um, the requirements are very detailed. So it starts off with , um, the fact that patients need to be seen in person, either in the emergency room or they need to be hospital inpatients before they can be discharged to home their various inpatient , their various inclusion criteria, exclusion criteria, and also some safety requirements. And so the hospitals need to be, the patients need to be residing within 30 minutes of the hospital. So a relatively small geography. Um, and it's also critical that emergency care is available to those patients at home also within 30 minutes. So, again, Arizona pretty detailed requirements, but available to hospitals on a voluntary basis that wanna extend care to the home setting. There's a number of other states that just have followed the Medicare program. So Massachusetts as an example, it has a really big hospital at home presence. Um, and process is pretty straightforward. So if a hospital in Massachusetts wants to deliver care at home , um, it submits a special application. It's a special project form that goes into the State Department of Public Health. Um, it goes in with the CMS waiver. Um , and that effectively serves the basis, serves as the basis for Massachusetts approval. So it doesn't have the equivalent of Arizona with all of those state specific requirements that have to be met in addition to the Medicare requirements. Another thing to just keep in mind , um, North Carolina is an example of this, but this is sort of an overarching theme , um, that it's not just about the licensing status. So of course, it's important to make sure that however care is delivered at home, that the right licensing , um, requirements are met. Um, but it's also important to keep coverage in mine too . And North Carolina is interesting in that when it first developed its hospital at home program , um, the Medicaid program in North Carolina covered it. So it was available to Medicaid beneficiaries. Hospitals could get paid by the North Carolina Medicaid program for these services akin to how they would get paid for hospital services. But pretty quickly, the North Carolina Medicaid Agency had some questions about the program, questions about its efficacy for Medicaid beneficiaries. And , uh, and because of that, put a pause on reimbursement. So the Medicaid program in North Carolina went from covering hospital at home to not covering hospital at home. Um, the punchline is it then initiated coverage again. And that took a good bit of work between the North Carolina Medicaid Agency and the hospitals , um, really working together collaboratively to come up with various inclusion and exclusion criteria, focusing on various societal , uh, socioeconomic environmental factors , um, really to make everybody comfortable that the program could be available safely and offer good outcomes for North Carolina Medicaid beneficiaries. So really, again, just an example of the kind of licensing frameworks we see in different states, and also some of the payment considerations to keep in mind , um, at the state level beyond what, what Ryan talked about at the federal level. Um, so Ryan, if, if I can turn it back to you . I know , um, hospitals are not the only game in town when it comes to delivering care at home, so it would be great to get your perspective on who else is trying to get involved and , and how it's working out for them .
Speaker 4:Yeah, thanks. Hope it's, you're right. It , you know, the , the Hospital at Home waiver , uh, and the, the impetus behind that, the growth behind that is certainly like a catalyst for one very recognizable path to providing hospital care at home. When you have a traditional hospital provider figuring out how to take its services and move them into the community, it's, it's part of probably a broader trend towards moving care from more acute settings to lower acute , you know, to lower acuity settings and trying to, you know, provide , uh, care in , in more community-based environments, less restrictive environments. And there's a lot of people out there who frankly don't really wanna wait for the feds to figure out how to do all this and, and don't wanna wait and , and say catch up . And so there's a lot of other provider types who are moving into this space and what they do and what they try to do. At least it varies there . There's a wide range of, of what they're trying to do. Some of them are really just focused on, you know, bringing back the physician house call model, right? The doctor, the doctor going around the countryside with a little black bag and visiting all the p farmsteads and, and bringing that into 21st century while others are focused , uh, on more specific episodic care, trying to find a specific condition potentially, or, or a specific type of illness that we think we can manage just as effectively in a patient's home. Thanks to all the technological developments over the past few years. Uh, we can do it just as well there as we could in an inpatient setting with perhaps closer supervision , uh, from, or more ready availability of the clinical personnel. And so you have not just, you have this explosion , uh, of people who are really trying to, to get into this space and to expand what's possible , uh, and kind of building a program, I guess, from the ground up, as opposed to having that institutional infrastructure already in place. Uh, some examples of that, you know, you have a , an organization like Moving Health Home, which is a con conglomeration of a lot of different organizations all playing around in this space and pushing the boundaries of what's possible and , and, and good for patients under our current, you know, clinical paradigms. You also have a con entrance like Best Buy , uh, you know, the Geek Squad is coming for your healthcare. Uh, they want to be and are kind of trying to position themselves to be that party that's gonna make your home connected enough , uh, that you can enjoy these kinds of services, enjoy this level of comfort at home and recovery at home, because you have access now to all the technology. Your wifi is stable, the sensors are there, the communication platforms are there, whatever else you need, you know, to help make that happen. So there's a lot of people interested in this space. There's a lot of people investing in this space and putting time, energy, effort into making these programs a reality. And sort of just like you described for the institutional providers, where , uh, the states have to adapt and figure out how does, how does this change from an institutional perspective impact what we have right now in our rules and regulations? We have the same issue just coming from the different direction , uh, for all of these other kinds of non-traditional healthcare providers , uh, states. The first question they will ask you is, what are you , uh, and if you look at the, you know, the scope of, of typically what kinds of healthcare facilities or organizations are , are licensed in a state , uh, there's often not a great match. The closest is probably home health , uh, because that kind of feels and sounds like , uh, maybe what's happening for some of these , uh, providers, depending on what they're doing. You're furnishing healthcare services, you're in a patient's home, why are you're not home health? Um, but for the same reason hospitals have this issue, you have to go state by state , look at the licensing rules, look at the requirements and the definitions. 'cause you're probably not that. And you have to have this kind of ongoing dialogue, both with yourself, with your clinical teams and, and occasionally with state regulators to say, this isn't us. This is what we're doing, and here's what we think the right story is. The answer is often that there isn't , uh, states are behind, they haven't caught up yet. They haven't figured out what these things are. They seem to, from a policy perspective like them. Um, and so, you know, try to be supportive, but at the same time, I think maybe feel a little shackled , uh, by the framework of what they have in place. They're always gonna be asking, it's always, it's like a, it's like a , a grade school English class exercise. Who, what, when, where, why, what are we doing? Who are we doing it for? Where are we doing it? Answering all these questions lead you down this path of trying to find the right, you know, the , the right place to slot yourself in , uh, from kind of a facility and organization perspective. At the same time, you have those same exact issues for your providers. Uh, you know, kind of taking care outside an institutional setting, moving it to the community , um, opens the door for working with a lot of different provider types. All of those individual licensed providers have different scopes of practice. They have different rules about who they can delegate to, who they can supervise. They have different rules about how far they have to be away from someone who is supervising them, or what methodologies you can use to accomplish that. And so, again, every, like , again, every state has different rules about this. Every jurisdiction with has , you know, different kinds of licensed professionals had different rules about what they could do. And you had to kind of go on a granular level and figure out, Hey, are we using the right people? Are they working with the right people? Are we doing the right thing? Um, a particular example of this is EMS personnel, EMS use of paramedics community paramedicine. Or you can , like you advance EMTs , uh, as an extremely popular idea , uh, for a lot of these models, because they have a lot of very kind of , you know, valuable training , uh, for, you know, for purposes of thinking about going into somebody's home and evaluating situation and figuring out what's going on. They're, they're trained for that. It's kind of what they do. But a lot of states also have restricted EMS practice laws . And so there's this constant tension of what are we allowed to do under what setting, under what facility license, under whose direction that , uh, is kind of a constant struggle for providers that wanna do this. Uh , you also, to your point earlier, hope have to figure out how you get paid. Um , you know , for , for an institutional provider like a hospital, when you take the hospital at home model, it's , it's perhaps a little easier to see the transition, right? Where you were gonna get paid A DRG before, we're gonna pay you, you know, something like A DRG . Now, it's just the difference is the patient's at home and not at a hospital. There's already kind of a defined framework for that. When you think about building a program from the ground up, there's a lot of different possibilities. And it depends on, you know, kind of who you're talking to. The reason that, you know, so many of these programs are starting out with a focus on things like Medicare advantage patients, commercial patients, as opposed to the broader healthcare ecosystem is because some of those payers have more flexibility to think creatively about the service packages they cover and about how they pay for those . And so where you see the most development in these kinds of programs are places where there's enough, you know, population with those payer types to sustain these kinds of models because you're , it really doesn't work, I don't think, to just do, you know, fee for service for every little individual thing that happens. Part of the reason to do this kind of coordinated care model, whether it's institutionally or building from the ground up, is that you have the , the benefit of the overlap and the coordination between all these different provider types that just, you know, straight fee for service does a really kind of poor job of capturing. So there's gotta be some other element, some other bundle, some other fee, some other component to it that, that makes kind of the extra effort to do this worthwhile. And that just doesn't really work in your kind of traditional settings. And so it takes creativity, it takes a payer who's a willing partner to work through it with you. And , and payers do like these kinds of things. They, they, they really do. But it just takes time, effort, energy to work through that process to find a , a , a pattern and a , and a system that works, you know, kind of for everybody. The last, the last thing is that people I think struggle with when they think about doing this, is thinking about who their partners are. Um, you know, a lot of times somebody has a really good idea for a specific model that's gonna work for a specific kind of condition, but it's, you know, it's a physician with their practice and they realize that, well, actually to do this, right, what we really need is also access to easy access to labs, easy access to pharmacy, easy access to imaging, access to any of these other ancillary services. And all of a sudden you're in a position where you've got to find partners in the community to work with. And you gotta find a way and a structure because of all the wonderful rules we deal with as healthcare lawyers , uh, that makes all of that compliance too. And so thinking about those community partnerships, and especially finding people whose values align with the model that you're trying to implement , uh, can be a significant challenge. So on the one hand, I think, you know, to summarize it, there's a lot of energy in this space. There's a lot of people that like to do this, that are trying to, you know, push the boundaries of what's possible, really outside the context of a hospital, and do it in a lot of new and creative ways. And that's fantastic. And they, they should do it, and they wanna do it. And for the most part, I think people are willing partners in doing that. But on , you know, the kind of the how side, it , it takes quite a bit of effort to deal with what we have now, what we have in place , uh, and to figure out how to make those models work within a framework that just frankly, you know, kind of hasn't caught up yet. <laugh> . So hope we've spent, you know, the first part of this, talking a lot about the how about how hospitals figure out how to move care to patient homes about , uh, how people with a good or creative idea about something new and exciting can build a program, you know, from the ground and get going. We haven't talked a lot yet about the why, but why are people doing this?
Speaker 3:Yeah. Um, it's a great question and I think it is important to kind of level set the conversation to get back to the why. Um, I think there's a number of different drivers for why folks are exploring providing care at home. And I think some of it depends on who you are, right? So for hospitals, for example, one aspiration, one hope for the care at home model is that it could be a solution to hospitals that are struggling with really high volume emergency departments and inpatient capacity challenges. So if you are a hospital that , um, has a large volume of ED visits and maybe a lot of that volume is driven by lower acuity conditions. So patients who have chronic problems, pneumonia, COPD, other chronic conditions , um, those folks are coming into the ed, they come in regularly, they may get admitted to the hospital, but they don't require, you know, a high degree of hospital resources. Those patients may do really well in a hospital at home program. So for that kind of hospital , um, hospital at home opportunity may really help alleviate some of the challenges that the brick and mortar hospital is experiencing. If we think more broadly about the why , um, for all of the different participants in this care delivery model or that are exploring it , um, we think about the construct of providing the right care in the right setting. And the hospital truly is just not a preferred or ideal setting for certain patients. So when we think about geriatric patients or pediatric patients , um, broadly, or when we think about oncology patients or other patients who are immunocompromised, if those folks can get the care they need, but they don't have to be in the hospital, that's really preferred. And so I think that's a big why for a number of folks exploring these alternatives to traditional hospital care. Another reason that , um, providers are considering care at home truly is cost. And so we hear about the financial challenges that hospitals and other providers are experiencing. We know hospital care is expensive. Um, it is , um, the cost of providing care in the brick and mortar hospital is really high, and some of these costs can be shed , um, when there's an opportunity to provide care at home. And this might be as a result of different interventions, it might be as a result of really scrutinizing what kinds of additional services are required for patients at home. Um, and it also may come as the result of different clinicians and team members who can provide care at home. You talked, Ryan, a little bit about , um, you know, mobile emergency care providers as an alternative, for example. So I think there's, you know , there's a cost component that, that certainly goes into this as folks are exploring care at home. The other is, and we've touched on this a few times already, but I think flexibility and creativity in reimbursement models. And so I think traditionally care at home, if this is a truly a hospital at home program, it may be that some payers are paying for care at home just like they would pay for any other hospital stay . Um, but increasingly I think we're seeing , um, that the hospitals and the health systems and the other providers that are really experienced with building those teams of providers, that network that you talked about , um, and that are also experienced with bundle payment initiatives and really managing episodes of care , um, those that have successfully taken risk . If they can do that well, then this is a good model for them. Um, and I think there's also a hope and expectation that over time this will also help, help deliver care in a more efficient way, and also help folks stay healthier if they're able to access this sort of robust suite of services, but they don't have to go to the hospital to do it. Um, I will caveat, I guess that, that even with a good why, it is also important to consider whether care at home is a right , is the right fit for your organization. Um, you talked right a little bit about the energy behind it. It's super exciting, you know, it's sort of a new care delivery model. There's a lot of good reasons that folks are looking to get into it, but I also think it's important to think about the scalability of it. And so if you're a hospital, for example, is your patient population the type of patient population that would avail itself of a hospital at home program? These are usually voluntary programs. Do you have the right patient population? You know, if you're a trauma center and you're seeing really sick, you know, trauma patients, it may not be the right fit for you as a community hospital where, you know, you may be treating patients who come in with the same conditions repeatedly, this might be a great option for you. Um, it also depends on other things like proximity to emergency services. And so care at home may not be safely administered if folks are not able to ask emergency response providers fast enough. And so that's something to keep in mind too. Um, so I think even when the y is exciting and, and the the new delivery model is exciting, it's important to think about whether it's scalable for you and your organization and whether you have the right patient population and the right demographics to really, to really support it. Um, anything, Ryan, you think I, I missed on the why other things that, that folks are thinking about as they get into this?
Speaker 4:No, I just, I, I think that, you know, from thinking about the patient experience and thinking about the clinical outcomes, we are, we are starting to get, I think for the first time good clinical data out of the hospital at home experiment during the covid, you know, the Covid pandemic. And it , it's, it's largely looking positive. I mean, the, the surveys that they have been done, the studies that have been done for hospital at home patients, you know, during covid demonstrated really good numbers for mortality for hospital admissions back, you know, back to the inpatient setting as opposed to remaining at home. Um, a very low number of sort of unexpected deaths. All of , almost all of which in the case here, as you might expect, were due to, you know, extreme covid complications. And, you know , the hospital at home model continues to remain, I think, popular with patients. I think that, you know, people would rather recover in their La-Z-Boy , uh, than in a then in a hospital bed <laugh> . And so I think, you know , I think the challenge not to, not to get too far into the next topic, which is gonna be about the future of this, but I think part of the challenge is as people become more comfortable with this, is as we think about expanding this, like, do we get to maintain that level of success , uh, clinically , um, for our , for our faults going forward? And I think that's probably like the right transition to what we're gonna talk about next, which is really just where is this going? You know, we , we talked about a little bit about the legislative progress at the federal level. We've talked a little bit about what states are doing, you know, in and out here. But, you know, let's, let's assume for the sake of discussion that we get five more years at least, that the, you know , the house bill passes, it goes through the Senate, it gets signed. Um, where do you see this going? What's happening next? Hope ?
Speaker 3:Yeah, I mean, I think five more years would be great. Um, I think, you know, we will hopefully see with five more years or with more time on the program, at least on the , the Medicare side , um, states continue to evolve and, and get more comfortable with the program. I think a lot of states have taken a bit of a wait and see approach, you know, so they're , they're waiting to see how this evolves. They're waiting to see what Medicare does. Um, I think we're still gonna see different states do this differently. So it may be in some states like Massachusetts , um, that folks are all in to hospital at home, and it's a pretty , pretty easy entry into the system, and folks have the opportunity to explore it, really develop that data and show that the outcomes are good. I think other states, certainly California as an example, they're just gonna be slower to adopt. And I think more time will help, but we're gonna likely see , um, a bit of a patchwork quote . So I think different states are gonna have different versions of the program, different providers are gonna avail themselves of it. Um, and one of the things that we might see is , um, instead of sort of uniform widespread adoption of a traditional hospital at home program, more of , uh, the development of programs that fit into certain categories. So again, you know, maybe the hospitals with significant inpatient capacity challenges and high ed volumes, they might be the ones to explore providing an acute care at home model. I think we will see likely some of these specialized programs that, for the particular patient populations that either demand it, that, you know, have started to get care at home and they realize they'd much rather be at home , um, or the patients that are vulnerable and can't , uh, you know, the risk of being in the hospital maybe outweighs the benefit of the intervention that they need, especially when that intervention can be provided at home. So again, things like oncology patients, pediatric patients, maybe geriatric patients, you know, there's still gonna be exclusion criteria. So ICU patients, psychiatric patients, you know, there's large categories of patients who I think are still gonna receive services in the hospital. So inpatient surgeries are still gonna happen in the , in the inpatient setting. But I think, you know, the entire healthcare system is really evaluating how to provide the right care in the right setting and how to get paid properly for it, and how to manage the associated resources. And I think the care at home model is really just another piece of that larger puzzle. So I'm excited to see how it, how it evolves. Curious as you, as you look into the crystal ball, what, what you're seeing?
Speaker 4:Yeah, I I think the same, the same thing in terms of the state implementation. If you're thinking about kind of the non-traditional approach to this from the building, the ground up for this, I think the same way that you described, you know, states wrestling with how to allow their hospitals to expand these programs, implement these programs, you're gonna see the same challenges, you know, building these things from the ground up , uh, where you're gonna just, you're gonna have a states that some, some states will figure out how to do it really well. Maybe they create a new license type, maybe they create, you know, a , a different category of a home health , something , uh, to have it fit. And you have, you know, to your point about like North Carolina Medicaid earlier, you have states that start and stop, but are thoughtful about it and think about implementation and figure out the right way , uh, to do it and to pay for it and to let everybody have access to it. If you'll indulge. Just a little bit of editorializing. I think the other future issue for me is really how this impacts equity in our healthcare system. And I, I don't think this is far less a crystal ball prediction than it is more like a plea <laugh> for, you know, let's, let's be thoughtful and careful about how we do this, because you can envision, I think at least two, two potential futures here. One where hospital at home, healthcare at home is implemented in a way that everybody has access to it, and the patients who need it and can get it and can get the right care in the right setting are available, and it's available to them, and they have access to it regardless of, of who their source of healthcare coverage coverages. And there's, there's another possibility, a , a , a darker path that I don't really wanna dwell on, where, you know, one of these alternatives is used as a way , um, you know, maybe we never figure out how to pay for it , uh, for most of our, you know, for Medicare fee for service and for Medicaid fee for service . And so it's a whole, you know, whole segment of the population doesn't have access to it, or the alternative is we figure out a way and all of a sudden everybody who's covered by those payers is, is on held at home and it doesn't work the way it's supposed to, where the resources aren't there and then the support's not there the way it's supposed to be. So on the one hand, you know, so excited by the energy and the development and the possibility by the technological change that has made a lot of these new programs possible. And on the other hand, I would , you know, I think there's a responsibility as we go forward, we think about implementing these things. You know, I know that every provider has the best of intentions for, for thinking about how to care for their patients and provide the best care. And , and it's broader than any single provider. It's really about a systemic , uh, problem to solve a , a challenge to solve for , uh, you know, our healthcare system as a whole, but we gotta use this responsibly. We gotta , we look to the future as we look to the development of these programs. We've gotta put in place , uh, you know, a mechanism to make sure that it works, right, that it fits everything. And that, as you say, as as you said multiple times throughout this, we get right care in the right setting for everybody involved .
Speaker 3:Absolutely. I think, I think the point on equity is really important. Um, and it's certainly part of a , a broader discussion about healthcare access and equity more generally. Um, but there is something to be said about treading carefully here and, and taking the energy, but also moving forward cautiously and, and responsibly because it is a new, you know, enhanced care delivery model. And, and I think there's a lot of learnings to be done. So exciting to see where it all goes .
Speaker 2:Thank you for listening. If you enjoyed this episode, be sure to subscribe to a HLA speaking of health law wherever you get your podcasts. To learn more about a HLA and the educational resources available to the health law community, visit American health law.org.