AHLA's Speaking of Health Law
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AHLA's Speaking of Health Law
Preparing for ICE Enforcement: What Health Care Providers and Legal Counsel Need to Know
With recent changes to immigration enforcement policies in hospitals and clinics, it’s crucial for health care providers and legal counsel to understand how to respond while protecting patient privacy and meeting their legal and mission-oriented obligations. Shawn Gilman, Vice President & Senior Corporate Counsel, Providence St. Joseph Health, speaks with Joseph Wheeler, Associate, Dinsmore & Shohl LLP, about the impact of these policy changes on health care providers and how legal counsel can advise. They discuss the history of immigration actions in sensitive areas like hospitals and what has recently changed, key legal requirements and best practices that providers must keep in mind when responding to an ICE action, state law considerations, navigating organizational mission and values, and proactive steps legal counsel can take to prepare for future developments. Joseph recently authored an article for AHLA’s Health Law Weekly about this topic. From AHLA’s In-House Counsel Practice Group.
For more information, register for AHLA's upcoming webinar on strategies for increased immigration enforcement activity here.
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Speaker 2:ALA's, popular Health Law Daily email newsletter is now a daily podcast exclusively for a HLA premium members. Get all your health law news from the major media outlets on this new podcast. To subscribe and add this private podcast, feed to your podcast app, go to American health law.org/daily podcast .
Speaker 3:Hi everyone, welcome to the American Health Law Association's, speaking of Health Law podcast. I'm Sean Gilman, chair of the HLAs in-House Practice Group, and Vice President and Senior Corporate Counsel at Providence St . Joseph Health in Seattle, where I oversee our regulatory and antitrust work. I'm excited to interview Joe Wheeler, an associate at Dismore and Shool , and the author of the recent article, preparing for Ice Enforcement Key Considerations For In-House Counsel . Joe wrote this article for the in-house practice group, and it was distributed , uh, about a week ago to , uh, the members of the HLA with recent changes to immigration enforcement policies in hospitals and clinics. It's crucial for in-house counsel to understand how to respond while protecting patient privacy and meeting their legal and mission oriented obligations. Before we begin, please note that the views I express today are my own and not those of my employer, Providence. Any examples I mentioned are purely illustrative and not linked to my work at Providence. This issue has sparked discussions across the industry in the media and online that I and Joe have been tracking closely. The same disclaimer goes for Joe and his clients. Joe, thanks for joining me today and agreeing to this interview. I really appreciate your article. It's full of practical advice, which is crucial for in-house counsel .
Speaker 4:Hi , Sean . Thanks for inviting me. I'm glad to be here and , uh, hopefully this proves useful for someone <laugh> .
Speaker 3:Great. I'm sure it will. Before we dive into today's topic, though, I'd love to hear about your professional journey. How did you get into health law? What drew you to the field and what are your key areas of focus today?
Speaker 4:Yeah, happy to to explain. Um , you know, my name's Joe Wheeler. I'm Densmore show based outta Columbus, Ohio. Um, you know, I I first got into health law when I graduated straight from law school. I got into a legal fellowship, which was a one year position at , um, a, a large health system here in Ohio, Ohio Health Corporation. Um , and I worked for a year in-house , uh, with kind of the support and mentorship of their entire general counsel's office. Um, and it was really an amazing experience. Um , you know, I had direct experience working in house with an experienced team , um, that really allowed me to see how legal advice is actually used and operationalized. Um , rather than just kind of giving advice in a vacuum that, you know, sometimes might happen when you go straight to a firm . Um, you know, throughout law school I had some brief exposure to kind of fraud and abuse law , uh, Medicare regulations, and it just really piqued my interest. Um , and then after that, you know, legal fellowship, I was kind of , um, I was on my way, so to speak. Um, and I've been, you know, a , uh, transactional and regulatory healthcare attorney every since. Um , handling everything from kind of hospital acquisitions down to physician acquisitions , um, dealing with all the kind of regulatory burden that comes with the healthcare industry from fraud and abuse to Medicare regulations to , uh, issues like this, to just kind of , um, organically evolve and , and kind of come nowhere.
Speaker 3:That's great. Thank you, Joe. Turning to your article , um, you offer a number of insights into the changes in ice enforcement policies. Could you give us a big picture overview of the history of immigration actions in sensitive areas like schools, hospitals, and churches to help frame the conversation and then talk about what has changed recently?
Speaker 4:Absolutely. Um, so, you know, the , the , this , um, kind of directive or advice or, you know, they're not executive orders, they're agency memorandums, but they date back really to around, you know, as far back as I saw in 1993, may go back further , um, under INS and going back to then, from 93 until about, you know, 2010, 2011 INS or ICE or Department of Phone security had issued these memorandums kind of piecemeal. And what they, you know , said essentially was that INS or DHS , um, or ICE wouldn't take enforcement actions in areas where they felt it was , um, you know, insensitive. Um, these were places like schools, places like hospitals, churches, synagogues, mosques, other places of worship. Um, and they weren't just limited to places. They were also kind of events or times like funerals or weddings or religious ceremonies. And these memorandums said, you know, we're not going to, you know, we're not gonna arrest anyone. We're not going to interview people at these places or events , um, and we're gonna limit surveillance at these areas. Uh, with the idea being , um, you know, maybe those aren't the most appropriate places to be taking kind of immigration actions. Maybe there's, you know, alternative places where they could be done and still accomplish the same result. Um, then in around 2010, 2011 , um, ICE issued kind of a, a broad memorandum to the agency, kind of wrapping all of those smaller ones up into one memorandum saying that they weren't gonna take , uh, these enforcement actions in sensitive areas. Um, so that was in 2011. Then during under , uh, the Trump administration's first or Trump's president, Trump's first administration, that 2011 memo was largely ignored. Um, it wasn't formally overturned or changed, but it was generally ignored. Um, then following President Trump's first administration, president Biden reissued a memo in 2021, kind of reaffirming his administration's commitment to honoring these, these sensitive areas and kind of prohibiting enforcement or immigration enforcement actions , um, you know, absent exigent circumstances , uh, in these areas. Um, and then as of January 21st, 2025, both the 2011 and the 2021 memo were, were rescinded , um, and a memorandum and an ice memorandum , um, that just came out. And I think, you know, there was a lot of confusion initially, even when I first started looking at this issue. Um, just with the flurry of activity that has come outta the federal government, you know, following President Trump's inauguration , um, you know, these, these are not executive orders, these are ice agency memorandums that are directed at kind of ice agents , um, and then kind of instructing them on how to carry out their objectives, their missions. And so it's really only limited to the ICE department , um, uh, immigration and customs enforcement enforce . I , I think that's important to understand , um, given how much has happened since January 20th. And, you know, the kind of confusion that has has kind of stemmed from that.
Speaker 3:That's great. That's great. Thank you. So it was really just through memorandum, then a rescission of prior , um, guidelines that enforcement agencies or their , uh, personnel were adhering to. And so it's just , uh, it's been a back and forth , it sounds like , um, kind of of longstanding , uh, guidance that , um, providers were relying on and ice agents were using , um, in terms of how to do their job. Is that correct?
Speaker 4:Yeah, yeah, that's correct. Um, and I think that might give some , uh, you know, hospitals and providers , um, I guess a , a bit of a better feeling about the issue. This isn't something that, you know, is just a complete sea change. Uh, rather it's been something that's kind of gone back and forth over the past, at least four administrations.
Speaker 3:Great . What impact have these policy changes had on healthcare providers? In other words, what are you hearing from organizations on the ground or from your clients?
Speaker 4:You know , so far it's, you know , um, it's only been about 20 days, 30 days since , um, the policy changed . But I think the practical effect so far is it's just another kind of , um, key issue or risk that they're trying to address before it happens. Um, I think with this issue in particular , um, you know, if an agent shows up, it's, you know , has the potential to be kind of a, a high stress situation , uh, that you don't really want to get wrong. Even a , a situation that could, you know, cause, you know, you know, end up in, you know, local or national media. And so I, you know, most of the clients I've spoken with so far have been more worried about figuring out how to address it before it comes around , um, which is just, you know, going back to the flurry of federal activity, it , it's one issue out of many , you know , that they're trying to address. Um, so, so far the practical effect is, you know, risk mitigation. Um, the add-on effect, the knock-on effects is, you know, this is one issue out of, you know, 50 that have come up, you know, in the past month or two given the changes. Um , so I think they're, they're struggling to keep up. They're looking for as much help as they can , um, and kind of addressing this issues as they arise before they become a problem. Um, so far , uh, I'm, you know, at least myself, I'm not aware of any kind of , uh, increase or, you know, extra immigration activity being taken at, you know, these sensitive areas yet. Um, I know there's been a lot of media coverage around the issue, but it's kind of a wait and see for now, but I think they're more interested in addressing the risk aspect of it for now.
Speaker 3:Yeah. One of the items that you , um, mentioned in your article are steps , um, that providers might consider taking, and I think a lot of them have is, you know, taking a look at , um, longstanding policies in areas of , um, privacy , um, responding to law enforcement, so interactions with law enforcement or how a provider , um, might handle a subpoena and then crisis communications. Can you talk about that, those , uh, you know , policy reviews a little bit and what the benefit of that would be?
Speaker 4:Yeah, absolutely. Um, you know, the memorandum change that happened was really , um, just limited to immigration and custom enforcement, like I said, but if an ICE agent shows up, that's really no different than another kind of law enforcement officer coming to the hospital or the clinic. And I think most providers are more familiar with that context. Um, you know, you know, having local police in the emergency room fairly common, if not daily occurrence in a lot of hospitals. Um, and so when you're looking at how to address kind of immigration issue in your facility with an ICE agent showing up, it's really no different than kind of general policies and how you respond to subpoenas and warrants and how you address or, you know, work with your local law enforcement or federal law enforcement other than ice. Um, so I think going back and making sure those policies or one up to date , and then two also are consistent with the context of an immigration officer showing up, you know , uh, is, is really worthwhile to do now, you know, before you get into those kind of , um, tense situations.
Speaker 3:Great. Thank you. Um, health law often involves balancing potentially conflicting legal obligations, whether between state and federal laws or treatment and privacy requirements. With these changes in immigration enforcement, what key legal requirements should providers and their counsel keep in mind when responding to ICE at their care location or any , uh, immigration enforcement action?
Speaker 4:Yeah. Um, you know , so when ICE shows up, they are enforcing legal mandates. They , um, are enforcing the law. And I think, you know, most hospitals, most systems or all of 'em , you know, want to comply with law , um, just like every provider does as well. And in this situation, you know, the hospitals also obligated to protect the, you know, the patient's protected health information. Um, the provider or the hospital is really the only one that's kind of in that position to be able to protect their patient's information. And so you have to balance protecting , um, this, you know, health information of your patients , uh, which could include, you know, substance use disorder records under, you know , part two . Um, you know, you gotta , you gotta balance that obligation against assisting , uh, law enforcement and carrying out their obligations to with law. Um, and that can be really difficult to do, especially in a situation where you're, you know , you're kind of doing on the fly a little bit and you're in the , when you got a , you know, a warrant , uh, being served. Um , and it can be really difficult
Speaker 3:As in-house counsel. What immediate steps should I take when I receive a call that ICE is present at one of our locations such as the receptionist desk, er , or at a clinic?
Speaker 4:You know , I really , I think it's really the same steps you take , uh, you know, when any law enforcement officer shows up that's looking to serve, you know, a warrant or they're looking for immediate access to the facility or records or patients or patient family members. Um, you know, I think , I think it's best that the law enforcement officer deals with one person, kind of have a liaison set up to, to kind of work with them and work through it. Um , I think it's best to do it away from , uh, patient care areas , uh, try to avoid impacting, you know, your day-to-day operations and patients to the extent you can. Um, I think it's important to , to remain calm and, you know, keep it a , a civil discussion. Um , you know, I think it's important to explain to your law enforcement partners in the community , um, you know, what decision you're making and you know, why you're arriving at that decision. Um, it's kind of help them understand, because, you know, they're not gonna necessarily understand, you know, the the competing obligations that a hospital or practice has to deal with in , in this situation. Um, and I think you , you know, you offer to be as, provide as much assistance as possible, provide assistance when you can. Um, but, you know, while balancing those kind of competing interests of , um, patient privacy , um, you know, and the obligation to, to comply with law,
Speaker 3:Right ? One of the things that I've heard , um, mentioned is, you know, that providers are in the business or in the trade of providing healthcare and not in the, you know, business of providing , uh, or serving as law enforcement. And so , um, you know, having, I think introducing that kind of concept in the conversation with law enforcement can also be helpful just to make sure, like, you're not, you're not, you know, if you're a hospital administrator for instance, you're not trying to be difficult, but you're trying to , um, comply with, you know, the legal requirements that you are faced with while at the same time meeting your, you know , mission oriented goals of helping all patients and sometimes, you know, legally required goals in terms of like m to LA requirements, while also safeguarding patient privacy, which is important to everyone as well. And , um, you know, it's unfortunate sometimes for a hospital administrator or someone to be put in that position, but I do think it can be helpful in , you know, framing the discussion with law enforcement and then relying on, you know, some of, you know, some hospitals have deep relationships with law enforcement just because of their interactions on a day-to-day basis. Um, you know, re re reacquainting yourself with , um, your local law enforcement can also be helpful, maybe not directly for the ice enforcement, but just, you know, reaching out and , um, maintaining those strong relationships or those good relationships where possible can be positive.
Speaker 4:Yeah, absolutely. I've , and I've heard it phrased a very similar way, which is, you know, hospital and, you know, the police departments are both there to serve the community. Yeah . We just serve the community in a different way, and when we're interacting, we're both interacting with the objective of protecting the community, caring for the community, but we just gotta do it in the way that works for both of us.
Speaker 3:Um, in terms of your, you know , um, just now and also in your article, you recommend designated a liaison as a primary point of contact for , uh, these types of interactions with ICE or other , uh, immigration enforcement actions. What qualities should providers and their council look for in this role, and how should they be? How should these individuals be trained? And also, how might this role differ between a large hospital with dedicated security and experience with law enforcement versus a small hos smaller hospital, or even a clinic that might not have such experience?
Speaker 4:Yeah, I, I, I think, you know, what you're first looking for is someone that's familiar with kind of the rules , uh, that apply here in the law. Um, I think generally , uh, the recommendation would be for someone in the legal department or , um, an executive level or director level or higher , uh, with direct access to council , um, simply because those kind of situations can evolve and develop and you're really gonna need answers kind of fairly quickly. Um, I think you're looking for someone you know that as an executive presence and is capable of, you know, communicating effectively and efficiently with law enforcement. Um, and he was capable of kind of handling those high stress situations because , um, they, they could get tense, you know, so you want someone who, who's capable of doing that , um, you know, in the context of a , a smaller hospital or even a clinic , um, you know , I think if you look at like , um, a rural hospital or a rural clinic , um, you're not really gonna have kind of the full on dedicated security staff. So you're more likely to have kind of administrators , uh, on call or you're gonna have kind of receptionists , uh, in the office. And for them, you know, I , I think it would help to one, give them access to either council directly in the event that there's , um, you know, some event, and that can be through kind of a hotline or, you know, to provide kind of the education upfront where you really kind of guide them and then provide them with kind of executive level assistance , um, you know, through a hotline. Um, I think in those, you know, in a rural setting, you have, you know, smaller communities , um, so your interactions or your relations with law enforcement, I think, although not necessarily are, are gonna be more familiar, although that may not necessarily apply in the instance of ICE kind of showing up. But, you know , uh, I think you still wanna make sure you provide them the training ahead of time and let them know that they need to let the executives know at some point or provide direct , um, you know, a direct line to council to kind of assist them in, in dealing with , uh, ICE showing up.
Speaker 3:Yeah, those , those , those recommendations definitely ring true to me. What I'm hearing about that is helpful , um, is, you know, circulation of telephone numbers of , um, you know, counsel that can be, you know, can, you can reach at any time , um, night or day , um, which <laugh> puts , uh, counsel in an interesting position, <laugh> , it's one that we don't, we don't necessarily love, but , um, but you know, it's really important. And so, you know, we wanna make sure that , um, the, the staff who are gonna be dealing with these , uh, situations feel secure and know that they can pick up the phone and call someone and get ahold of someone quickly. And so including a number of, you know, cell phone numbers of , um, counsel or even outside counsel , if that's what's needed at , you know, given the size of a facility's helpful. And then also another thing that , um, I have heard being helpful is , um, you know, for a larger system or even just smaller system, just, you know, periodic communications about the top this topic, lots of people are thinking about this , um, quite a bit. And I think not hearing from their legal department compliance team or leadership about how are we gonna react to this is , um, a missed opportunity. And , um, so I have seen, you know, and heard of systems setting up , um, periodic calls where , um, a large number of people are invited and they can talk about this issue , um, in a privileged manner, but , um, get answers to questions they have that would also help, you know, float I float issues to the legal team that they might not be readily apparent of. Um, for instance, like the, you know , uh, tailoring your , um, counsel for the hospital environment when as a large health system you're , uh, the number of , um, clinic sites might , um, outweigh the number of hospitals you have by a factor of 100 to one, for instance. So I, I think that , um, what you said brings true to me, at least what I'm hearing as is helpful to those in the field at health systems.
Speaker 4:Absolutely. I , I think sending kind of , um, an organization wide kind of communication, you know, letting them know that it's being the issue being looked at considered and kind of, you know, like you said, giving the opportunity to ask questions is a great idea.
Speaker 3:So state laws and approaches to patient privacy and immigration enforcement can vary widely. Can you describe some of these differences and what health law practitioners should keep in mind as they implement their own strategies?
Speaker 4:Yeah, absolutely. Um, you know, state law can vary wildly, I think with this issue in particular. Um , I think you need to keep an eye on kind of the varying patient protections beyond HIPAA and part two that apply at the state level. Some of those are, you know, gonna be more restrictive than HIPAA and further limit , uh, kind of what you can and can't do. Uh, when it comes to any kind of use of disclosure with law enforcement. Um, there's also varying reporting requirements under state law. Um , and I , I think there's one out of Arizona that may be , uh, being challenged or it's currently pending, but, you know, there may be an obligation to report certain immigration statuses. Um, I don't know how widespread that is. Um, but I do think that's a consideration that that council should keep in mind. And then also, you know, there may be varying , um, criminal rules related to immigration or reporting or refusal to provide , uh, certain information at the state level. And so I think council really needs to kind of keep in , you know, keep in the back of their mind that there is a kind of a broad range of different laws that could apply in this situation, depending on the state or even the locality , um, some of which may not, you know, ordinarily jump to the forefront of their mind.
Speaker 3:Right. Yeah, I agree. Um, I have seen, yeah , in the state, in the privacy realm, there are definitely state law , um, state laws that are more protective of patient privacy and as they , uh, pertain to interactions with law enforcement that would , um, you know , uh, require different approaches than just relying on the general hipaa , um, exceptions to allow for , uh, disclosures to law enforcement. And so , um, I think that , uh, you're absolutely right in that regard, and I think it's honestly important to really talk to someone with expertise at the state, on the state privacy issues. Um, and then also, like you said, in the , uh, immigration front , um, there are various states who have different approaches , uh, to immigration. So for instance, you mentioned the Arizona , uh, uh, requirement , um, to , uh, you know, in some ways participate in immigration or, or let people know if you're aware of something. But we also have, in Texas, there was a law or an executive order that was passed that requires , um, hospitals to report on the cost of providing care to undocumented , um, patients. It doesn't require a disclosure of any PHI, but , um, it does, you know, require , uh, asking patients for their status. Great.
Speaker 4:Yeah , and I, I think it's also important to keep an eye on those, you know, over the next couple years or so. Um, I think those are likely to be fast developing rules or laws. Um , so you , it , you might as to check in on it once or twice, make sure you're up to date .
Speaker 3:Yeah, I definitely think, I mean, you know, right now , um, a number of states are in their legislative session and have , um, legislatures in , in session and , uh, considering new bills. And I think , um, we will see differing bills arise at the state level. Um, some that are supportive of this type of effort from the federal level and others that are taking a more protective approach and , um, seeking to protect their , um, citizens from , um, being , uh, involved in these types of interactions with ICE in the healthcare setting.
Speaker 4:Yeah, absolutely. I , I think it's kind of analogous to the way , um, kind of the reproductive health rules have kind of developed , uh, with HIPAA recently , um, and how different states have kind of taken different approaches to that. Um, some more protective, some not. So , uh, but I think it'll be a very similar kind of , uh, pattern. Great .
Speaker 3:Um, as we know, you know, health systems and providers are committed to serving vulnerable populations, including undocumented individuals. How can legal advisors align their response strategies with the organization's mission and values?
Speaker 4:You know, I think for in-house counsel , I think their organization's values, their mission , um, and their values are , are really gonna guide kind of some of the responses and the policies that develop out of this. Um, I think the way I kind of, you know, view a lot of the responses to law enforcement requests for patient information or access , um, it really kind of falls down into to three different buckets. You know , you've got situations where you must comply, situations where you simply can't due to patient protection , um, laws, and then some are in the middle, in the gray. And I think that's really where the organization's values and their mission and their culture is really gonna kind of drive , um, in-house counsel and just their general response to, to how to deal with this potential issue. Um, and I think it's really important to make sure that those are aligned , um, uh, just to make sure that , uh, you know, patients are being cared for in the way that, you know, the organization , organization intents.
Speaker 3:Great. Yeah. For , um, as in-house counsel , I do think learning those values is really important because it helps you understand how you're to approach your job or at least what , um, you know, the founding , uh, members of, you know, if you're working at a nonprofit , um, what they intend, how they intend to approach , um, these types of issues. Um, and , um, so I think learning them is really important. And then I would also, you know, mention just, you know, working in a , um, collaborative manner with other , uh, functions at the health system or at the provider organization that also , um, you know , uh, influence these kinds of issues. And so that would include , um, the ethics team as well as the compliance team, as well as , and risk for instance, at , um, organization like Providence. Um, but I think you, you find those functions that most health systems and , um, we, you know, we, we work collaboratively with , um, each of them in order to formulate the system approach to these types of issues.
Speaker 4:Absolutely. I think everyone's really gotta be on, on board on how, you know, how the organization's planning to, to deal with the issue. Um , and even add in, you know , security or kind of , um, you ready your , uh, receptionist or , or help desk to make sure they, they're aware of kind of the systems' developed response, why it develops , um, how it's tied to, you know, the culture and mission of the organization. So they really understand kind of why certain decisions are being made to kind of , uh, help them prepare for it as well. Great .
Speaker 3:Thank you. Um, what additional risks or enforcement trends should in-house attorneys and other provider advisors monitor, and are there any proactive steps they can take now to prepare for future developments?
Speaker 4:Um, as far as additional risk and enforcement trends, I think it's too early to say honestly. Um, there's just been , uh, you know, so many policy changes in the past month or so that we really gotta kind of wait and see a little bit. I think we gotta track the issues , uh, address the risk as they're presented, but we can't really, you know, assess 'em , um, just yet. I think we gotta wait a little bit. Um, as far as proactive steps, you know, I think you should take a look at or I think organizations should take a look at kind of what information they're collecting and really ask why. Um, you know, I've seen some instances where immigration status was collected from patients , um, you know, and, and other information that may not be necessary to provide the care the patient requires or the organization even really needs. It's just kind of something that somehow ended up on a form and just never got taken off. Um, so I think, you know, you need to look at what information you're collecting and why , uh, which I think is always on the IT department's, you know, mind. So probably help them out with that. Um, and for now, I think, you know, just gotta pay attention, keep addressing the issues as they come.
Speaker 3:Right. Yeah, I think , um, you know, for anyone , um, you know, practicing in health law , I think, you know, Thea's daily newsletter that comes out every day , um, includes a summary of stories from across , uh, the industry. Um, that right there is just a good , um, first step. If you're doing anything as a health law practitioner , um, you should be, you know, at least scanning that , um, to understand, you know, what's going on, what is my industry facing, what are, what are my clients thinking about , um, perhaps before they get to you with the question.
Speaker 4:Yeah, absolutely. That's a great resource.
Speaker 3:Great . Before we go, what's one piece of advice you'd give to in-house counsel dealing with complex, fast evolving issues like this and how, how can they get in front of it? So you did a great job, right, Joe , this, this stuff came out and you had your article done within, I dunno , five days of it, <laugh> , um, of the announcement , um, and provided great advice , uh, to , um, you know, HLA members. But how , how , how do you do that? And , you know, if you could offer a piece of advice in this space, what would it be?
Speaker 4:Uh, thanks for the compliment, Sean . I , we tried , um, you know, I think for now's counsel , I give two pieces of advice. One is keep in touch , um, with your internal clients, your internal departments. Uh , they are gonna be tracking, you know , what's important within their viewpoint. And I think they have a better chance of kind of spotting some of these quick evolving issues , um, quicker than, you know, the general counsel's office can just because that's the one slice they're looking at. Um , so staying connected with, you know, your internal departments and clients is, is I think one of the big ones. The other one is , um, good relationships with outside counsel . Um , I know in-house counsel , their email boxes are always slant with, you know, emails saying, look what I did here , um, check it out. But just briefly browsing those does kind of keep your ear to the gr or help keep your ear to the ground, so to speak, and, and kind of see these issues pop up and, and develop. So , um, good relationship with inside departments and good relationships with , uh, outside counsel I think are the two ones I'd give, which might be self-serving, but I'm okay with that. <laugh> .
Speaker 3:Yep . No, 100%. I mean, I rely , um, you know , I, I feel , view myself as a very informed practitioner. Um, most of the stuff , um, you know, that I'm gonna become aware of at about the same time that outside counsel is going to be aware, become aware of it. But I do appreciate , um, outside counsel sharing , um, information that they think is relevant to my job with me, even if it is something that I know. I'd rather them take the step of , um, trying to let me know and learning what I, what I, what I might not, what my blind areas might be versus , um, what I'm really , uh, dug into. Um, and so I, I do , um, I agree with that approach and I really do rely on outside counsel , um, as in-house counsel, I'm, you know, jumping from one issue to another repeatedly throughout the day. And , um, the relationships, the special relationships you can build with outside counsel is really important to ensure like, am I in the right space? You know, my gut checks that I need , um, those types of , um, issues. So Totally agree, Joe. Um, and thank you so much for sharing your insights and practical advice with us today. I also want to extend my thanks to the American Health Law Association for providing this platform for such important discussions. Uh, to our listeners, if you're interested in getting involved in the HLA, whether by writing, presenting, or contributing in other ways to educate your colleagues, I encourage you to reach out to the HLA practice group leaders , uh, your participation and contributions are vital to our community. Thanks for tuning in, and we'll see you next time on the HLA speaking of Health Law podcast.
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