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AHLA's Speaking of Health Law
The Evolving Role of the Chief Compliance Officer
Tom O’Neil, Managing Director, BRG, and Jim Hearty, Chief Compliance Officer, DaVita Inc., discuss the various dimensions of the Chief Compliance Officer’s role. They cover issues related to strategic enablement, organizational values and culture, and working with the legal department and the board of directors. Tom and Jim spoke about this topic at AHLA’s 2024 Fraud and Compliance Forum in Baltimore, MD. Sponsored by BRG.
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Speaker 3:Hi, Jim, good to see you, and thanks for joining us today.
Speaker 4:Hey, Tom. Thank you. Good to see you and, and , uh, good to be here.
Speaker 3:So, last fall, you and I got together in Baltimore at the A HLA Fraud and Compliance Forum, and we did a deep dive in a lot of the dimensions of the role of the Chief compliance officer today in the field of healthcare , both as the source of truth and as the strategic partner , uh, to the leadership team, and also to the board of directors. I wanted to build on that conversation if we could, and this time, perhaps focus a little bit more on the strategic dimension of your job, and then later, if we have time, perhaps we can go back and talk about , uh, uh, other aspects of your role and, and how to fulfill stakeholder expectations. Does that work? Yeah,
Speaker 4:That sounds good, though . Look forward to it. Terrific.
Speaker 3:So, one of the things that fascinates me about your journey at DaVita , uh, is that when I got to know DaVita as a Baltimore resident, I always associated the company with being an iconic dialysis provider. And as you and I have gotten to know each other professionally over the years, it's at least my perception that the company has embraced a much more holistic view from a strategic perspective of the care that it provides to patients, really as a global kidney care organization. And I was wondering if you could just set the table by talking about that a little bit.
Speaker 4:Yeah. Um, so I think you're right about that. We , we have been on a journey to be , um, first global. I think back when we first met , uh, DeVito was just embarking on our global journey. We're now in 15 countries, and so we've continued to grow internationally, which has been a , a really interesting and fulfilling part of the, part of the business and the trajectory. And the other place is really a , a focus on , um, value-based care, and also , uh, being able to provide really a full continuum of kidney care for our patients and really being a kidney care organization, not a dialysis organization. So that's been where much of the focus has been on. And then in that space , um, it's really been on being able to provide patient-centered care and , uh, value-based care has really , um, in the last several years and, and a lot having to do with some government programs and government sponsored programs has really scaled in a value-based care space in kidney care. Uh, and so that has been another kind of interesting and dynamic area that we've spent a ton of time , uh, focused on and, and really trying to , um, increase and improve our capabilities in that space to serve our patients.
Speaker 3:So, Jim, what accelerated , um, Davida's strategic , uh, trajectory?
Speaker 4:You know, I think it's been a recognition that that's, that's been there for a long time, but a rec recognition of the gaps that exist in the healthcare delivery system and trying to reduce those gaps that we have from the fragmented healthcare system and have more holistic care for patients. And , and in DaVita space , uh, you know, kidney care patients are complex patients that are vulnerable and have a lot of comorbid conditions. And so trying to bring more holistic care delivery for those patients , um, is a really worthy goal for both DaVita and for other folks , um, in the healthcare system, including the government and payers. And to give you a sense from a, from a , a metrics perspective , um, and first, let me just explain what, what, what I mean by a value-based care program. So, a value-based care program for us provides holistic care services , um, to the patient trying to have, trying to help manage the patient's entire care journey , um, that's focused on their personalized needs. And then in those situations, we take, we, meaning DaVita as a provider, take full risk for the patients and the cost of their care. And so, to give you a sense , um, the , uh, DaVita currently provides, has 80,000 patients that partic participate in a value-based care program. And that accounts for about $5 billion of risk healthcare risk under management today. Um, that is, that represents about 40% of DaVita's patients that participate in some kind of value-based care arrangement. And so it has grown a lot, as you said , um, from back when we first met, you know , 10 years ago or so. Hmm .
Speaker 3:So clearly providing , um, greater access to holistic care. But it sounds like one of your , um, strategic pillars is also to drive better outcomes within the system.
Speaker 4:Yeah, I think, I think the two things that, that at least I think about in that space is one, is the goal of having greater collaboration between the different players in the system. And so that is for us , um, with nephrologists, with other , um, providers and, and physicians, specialty physicians, and with , um, healthcare systems that will reduce the total cost of care for the system and then improve the quality of care for our patients. And those are really the twin goals I think that exists there.
Speaker 3:And I have to believe that the ramifications of that strategy have been pretty profound for you and your team.
Speaker 4:Yeah, it has. And, and I think for the entire organization. So it starts there, and I think that , that , one of the things that I've noticed is really the organization and, and , um, the, our, our clinical teams and our business teams really being more nimble and focused on innovation and then finding ways to continuously improve. And so there's a lot of things where it's using technology to enable healthcare delivery using technology and data to get quicker feedback on what's working, what's not working , uh, piloting different models of care and delivery systems as a way to, to , um, innovate and find better ways to deliver care. And then for me and my team, it is then making sure that we are plugged in upstream and early, working with the business to be number one, understanding what the business is trying to do. And then number two, providing guidance and collaboration early in the process.
Speaker 3:And , and one of the things that I've long believed is that the role of the chief compliance officer is very much at the same stature or , um, on par with the chief financial officer and the chief legal officer. And certainly listening to , um, you describe the strategic trajectory that DaVita has been on, I would assume that kind of tripartite collaboration has been pretty important for your colleagues on the executive leadership team.
Speaker 4:Yeah, for sure. And , uh, the one that I would add there, it is really being plugged in closely with the business. And so for us in our integrated kidney care side of the business , um, where they are doing a lot of the innovation and the ideation, it's being plugged in closely with them early on, and then also close with our legal partners , um, and evaluating, you know, trying to understand what they're doing first, evaluating what kinds of, what , what are the regulatory requirements in those areas, and then working with the business to design controls , um, to mitigate risks in that space.
Speaker 3:And again, without delving into anything , um, confidential or proprietary or privileged, what have been some of the greatest , um, internal and external challenges as you've embarked on that journey?
Speaker 4:Yeah, I think, I think one of the things that's been a a real challenge is just you're going into areas of uncertainty. So, and , and , and new areas , um, of new business areas that are something that were new to us and our team, and frankly, to the entire company. An example of that is , um, in integrated kidney care, we have risk adjusted coding mm-hmm <affirmative> . And of course that has been an area that's existed in other, other businesses for quite some time, but was new to our business. And so both, you know, kind of understanding that business, working, working with our business leaders , um, to implement systems, to be able to do that effectively and to do it appropriately has been an important thing that we've done. And then also learning , um, uh, new risk areas. And so for instance, there's new safe harbors that exist in value-based care, where the government has created safe harbors to encourage , um, providers to embark on and invest in value-based care. And so those are new, new safe harbors, new regulations that we're trying to interpret and understand that there isn't precedent for. And then , uh, consulting with outside experts to make sure that we understand them and have, have a , a good understanding of them. So those are a couple of the areas I think that have been , um, challenging and also interesting.
Speaker 3:It sounds like it's, on the one hand , um, a bit uncomfortable as the spectrum of risk broadens and they're less well known . But has it also provided sort of a strategic impetus or north star for your team in being mission driven ?
Speaker 4:Yeah, for sure. Uh , I think the entire organizations are even coming out, you know, moving outside the compliance department has been very exciting, excited about delivering holistic care to patients and then trying to reduce barriers , um, for patients and actually improve the care that they're receiving. And so that, that's been, I think, exciting for the entire organization. And then , uh, for my team, I think that's also been exciting is, is to be part of that effort and those goals to deliver that kind of care and really change the healthcare system for the better and change it for the better for our patients, has been something that, that I think , um, the entire company and my team in particular have really rallied, rallied around and been excited about.
Speaker 3:And recognizing that this is occurring in some different way across the spectrum of healthcare delivery. Do you have any thoughts or pearls of wisdom that you'd share with other chief compliance officers or even chief legal officers who are finding themselves in the same position?
Speaker 4:Yeah, I think there's maybe three things that I'd say on that. One is , is , um, number one, you really, it is really critical to have a capable team and a capable staff because in order for us to be able to effectively advise the business in kind of dynamic areas like this, my staff needs to be viewed as credible by their business partners to be effective collaborators. Um, and so that's really an important piece of them being brought in early. My team being brought in early , um, to help problem solve with the business has been, has been critical to them being seen as, as really effective partners to the business. Um , the second is, is having a culture that even if you don't know exactly what the answer is, culturally, our business leaders are committed to doing the right thing. So even if you don't know what the right answer is, the fact that they're bringing in legal and bringing in compliance early in a collaborative way of trying to get to the right answer, even if it's slowing them down at times and creating frustration, that that culture of doing the right thing becomes really imperative and kind of dynamic times in new areas. And then the , um, I guess the third one I would say is be involved early. Um, it's important for me and my team to be adaptable and open-minded, and then also to acknowledge when we don't know the answer and to seek guidance and, and do research and get external help to make sure we're advising the business the right way. Tom, what , what is , um, it actually makes me think of you've been involved in, in companies that have also gone through dynamic times and challenges as a general counsel and chief compliance officer. Anything that you would add to that list?
Speaker 3:Yeah, and I, I think culture at the end of the day ends up being a bedrock of much of what we're talking about. The interesting thing for me is compliance officers are often recruited or appointed under very different circumstances. So when I was the chief , um, the general counsel , I should say, of WellCare and then later the vice chairman, that was obviously a well storied crisis, if you will, in the sense that the company was trying to address a lot of external scrutiny effectively while ensuring that it was in a position to emerge from that storm in a , in a healthy state ready to serve , uh, program beneficiaries. The journey at Cigna was different. It was the story of creating , um, a global healthcare services organization that had deep history in, in commercial insurance , uh, and was really transforming itself into a true healthcare organization. So it , it does, I I always bring up strategy because from my perspective , the confluence of strategy and culture end up defining the journey , uh, in many respects. And I'm curious, Jim, what role do you and your team play , uh, vis-a-vis nurturing the culture at DaVita ?
Speaker 4:Yeah, I think , um, I think it's hugely important. I think the more time I've been in the role, the more appreciation I've had for that. And frankly, the more that I, I really try to invest in figuring out ways to , um, strengthen the culture and ensure the culture remains robust. One of the things that over time I've definitely recognized is you can never take it for granted. The culture's constantly changing between turnover and staff, what we were just talking about, new business lines and business opportunities , um, uh, integration of new businesses. There's all of those dynamics , um, that are changing. Covid, of course, that was a example that really put strain on a culture. Um, staffing challenges in the field with caregivers has put a strain on the culture. There's all kinds of things like that are constantly dealing with, and so you can't take it for granted. And so I think one of the most important things, and maybe one of the more obvious things is linking to the company's values. And so at DaVita , um, culture is very important at DaVita , not just in compliance, but all the way across the organization as we try to link to that. And so just a couple of examples is at DaVita , one of our mantras is that you , we are a community first and a company second. And so that is a nice linkage for, for compliance and ethics and doing the right thing and making sure that , um, being a community first, that we're developing high trust with our, with our employees, with our patients, with our key stakeholders. Um, and then the other thing is, is very prominent at DaVita are , are our core values. And so we have seven core values that we talk about a lot at DaVita , across, across all kinds of different aspects of the organization. And two of those I really try to link to our compliance program with, and that is integrity and accountability. And so we kind of grab onto those, those other, those core values that, that are so bedrock really in our culture here, and then anchor to those things , uh, when we talk about compliance and ethics and doing the right thing. The the one, I guess one other thing I would say too , Tom, on this one is really wanna support , um, the business leaders because it's important for them to talk about culture. And so providing them information where they can clearly articulate the importance of compliance and the importance of ethics, that they personally believe that. And then for them to say that frequently in different settings, and not just through words, but also through their actions, actually demonstrating that commitment , um, is important. So I think all of those things are, are really ways that, that you can try to keep a really strong and healthy culture of compliance in the organization.
Speaker 3:And as you dramatically expand the portfolio of services offered to patients, and obviously the co company ideally will grow , uh, as a result of those initiatives, how do you keep your hand on the organizational pulse, if you will, to, to feel comfortable that all those things you're doing are actually resonating and taking root?
Speaker 4:Yeah, I think one of the things that, that we started doing a couple of years ago that's been really useful is we have an employee engagement survey that, that we administer to all of our employees twice a year. And then it is a poll survey that we have, and we've included compliance questions on that survey. And what's nice about it is it , it's, it's an internal survey tool that we get really good granular insights and can analyze that data by, by role, by , um, by , uh, geography under different leaders , um, by how long that the employee has been an employee. You can slice and dice the information a lot of different ways and then action that information and try to create greater visibility to the business leaders and greater accountability to them to action where there are opportunities or there's been changes because the longer we've been doing that right now, we can see trending and see where things have improved or things haven't improved or have gone down, and then action those directly. So I think that's, that's been a really good tool for us is , is we also do, you know, kind of a broader deeper dive on , um, ethics and compliance culture, but this kind of more of a pulse snapshot that we get on a regular basis has been a really strong tool. And then the other thing I'd say too, on from a , from a , uh, efficiency perspective as we grow to kind of get to that point, is really looking to try to use technology to create more automations , uh, and have greater automations and spend less of my team's time on manual , um, manual tasks that we can automate.
Speaker 3:Have you guys embarked on inorganic growth, meaning mergers and acquisitions or tuck-ins, those type of transactions?
Speaker 4:Yeah, I think in, in my time here, there's been, on the domestic side of the business, there's been smaller , um, acquisitions, but there still has been some acquisitions in the domestic side. Um, on the international side. On the other hand , um, almost all of our growth internationally has been through acquisitions.
Speaker 3:And how do you guys think about , um, the integration process after those deals close?
Speaker 4:Yeah. Um, so first I , when I think about integration, I really do think it starts in diligence. And so in order to be able to, to put together a strong integration plan, you kind of want to know what you're dealing with. And I think diligence, if you're involved in compliance, being involved in diligence on the front end, you have a better sense of what you're dealing with when you're getting to the integration , um, stage. And so you can have a, a more targeted, focused and prioritized integration plan. And then also even understand, you know, depending on the , um, the acquisition, sometimes you're acquiring compliance staff and of course business leaders to varying degrees, and then having a sense of kind of what the culture is , um, and the , um, uh, the talent level there is and the buy-in to compliance from some of those legacy , legacy employees is an important piece of kind of understanding what you need to do from a winning the hearts and minds , um, af post-integration. Um, and then the other thing too is it's not all, there's things we can learn too. I mean, sometimes the, when you look at the , um, the acquired business, there's things that they're doing really well, we wanna learn from those and their processes and their, the technology that they're using too, and see if we can get better that way.
Speaker 3:Very helpful, and certainly, at least for me, fa fascinating. Um, how do you guys think, my last question for this section of our discussion is how do you guys think about scalability and sustainability when you look at the program at the end of every year and start to design your work plan , um, for the next year or so?
Speaker 4:Yeah. Um, well, what , I'll start with team again. You know, none of it. Um, we , you know , we can't do anything that we do from a compliance program perspective without a strong team. So we do spend a lot of time on talent planning , um, growth , uh, thinking about succession , um, looking at , uh, do we have , um, areas where there are , uh, staff on my team that would benefit from learning a different area than they're currently in to kind of broaden their experience and also also makes the department stronger that way. Um, we have been on a journey, I think like many compliance programs , um, to use technology and data more effectively as part of our program to create greater efficiencies, to be able to be more targeted in where we spend our, our efforts and to , um, to also hopefully be more proactive in what we're doing. So I think those would be a couple ways. And then I think the one, the , the topic we just talked about, actually, I probably , maybe I should have started with that one, and that is culture. I mean, the culture and having that strong culture is critical to sustainability.
Speaker 3:You know, we've spent a lot of time, certainly over the last few decades discussing the importance of distinguishing between the role of the chief legal officer and the chief compliance officer, as well as the chief financial officer. And suffice it to say, I, I believe that's a very valid distinction and ought not be blurred. On the other hand, as I listen to you and reflect on the journey that you've been through, it strikes me that quite apart from the separation and acknowledging the different roles, effective c collaboration is mission critical. And particularly given some of the initiatives you've described, I'm very interested to hear about how you collaborate with your general counselor , chief legal officer, and more importantly than you two are as leaders, how do the teams work together in an optimal way?
Speaker 4:Yeah, it's, it's a really important relationship for us is our relationship with the, with the legal department. And so , um, we, we try to stay in very close contact with the legal department. Of course, we seek legal guidance from them regularly, and then we're also partnering , um, with them and aligning as much as possible and providing guidance to the, the business. So the business doesn't feel either whipsaw by guidance coming from the compliance department and the legal department differently or at different times. And so we try to coordinate that guidance to the business. And then , um, and then for like myself and the general counsel, we stay close , closely connected, and then demonstrate , um, partnerships for the rest of our team that they see the fact that we partner closely and collaborate closely. And then I think that does, that does , uh, set a good example for the rest of the team. And I think it's a very , uh, very strong and collaborative relationship that we have with the legal department.
Speaker 3:And undoubtedly there are times when , uh, each of you and your respective teams see the world through different classes , and that requires some form of communication , um, and discussion, I would assume.
Speaker 4:Yeah, I think one of the things by staying closely coordinated is , um, being aware of when we have different perspectives on a particular topic , um, and , uh, then sharing those perspectives. And we obviously reconciling them as much as we can , um, you know, before the business, you know, hears different perspectives from the respective departments first. But then at times, you're right, that there's, that we will have a different perspective than the legal department and then just sharing that in a clear , uh, direct way , um, with the business as we work through different challenges and problem solve together. And Tom, you know, one of the things now is we've worked together for years , um, that I think has , is been so interesting is the different seats that you've sat in in the course of your career. So interested in, you know, as I talk, as you hear me talk about some of the perspectives from a chief compliance officer, you've worn that hat , um, you've worn the hat of the, of the general counsel , um, that we were just talking about those relationships. And then of course , um, as a, as a board member and a committee chair in your roles with oversight and governance, I'd be interested to hear, you know, what are some of the things that you've seen and kind of how your perspectives have have changed on that as you've moved into the seat as a board member and looking down, looking back at the organization and the role of the Chief compliance officer in compliance programs and what makes them effective?
Speaker 3:It's a great question, and my perspective for sure has changed materially. I think as a threshold matter, when you're in the C-suite, particularly in the chief compliance officer role versus the general counsel , uh, and depending on the realities of the organization, crisis management can become psychologically addictive. Um, and that happens to many compliance teams , um, usually not , uh, at , at their fault, but they embark on a series of crisis management exercises . And before you know it, the definition of success becomes a very myopic one where people are high fiving each other that they put out a fire before it took down, you know, a national park. And at what I think is different now about all that from the boardroom perspective is all of that is for naught if you're not building a sustainable, strategically driven program like the one that you've described. And certainly that's the kind of , um, commitment that as a board member, I expect from the compliance leader and from the team. And that is to say, a longer view with really effective near term management and direction. And that's when you really do start to add the value that we've been talking about during this conversation, at least in my view.
Speaker 4:And , and how do you , um, how do you assess that as a board member and you're working with the chief compliance officer, how are you staying on top of that and assessing that long-term view and as opposed to a incident or crisis management?
Speaker 3:It's a great question. Uh , I have two vantage points because I usually chair the committee , um, to which the board has delegated primary oversight responsibility for the program. So I'm fortunate to be able to have a one-on-one dialogue with the chief compliance officer, and that's something that I place a tremendous value on , um, not for me to tell them what to do, because it's important to stay in your lane as a board member, but as a strategic partner in certain respects. So that dialogue is important to me, but also the reporting that occurs. And for me, there's the reporting about what happened in a given quarter, and I think that's historically been the focal point when people think of governance and oversight coming into a management compliance committee meeting or a board compliance committee meeting and providing a bevy of slides and data that show what happened during the past quarter, perhaps a one year report on compliance and training or the disclosure program and the like. But I push the teams with which I work to present a forward looking view as well. What are the key initiatives you hope to achieve in the upcoming quarter, and where do you wanna be a year from now in the team development, the , um, leveraging technology to take you to take us as an organization to a different place, and then obviously the, the resources that you need to get the job done. The reason I opened Jim with an observation about crisis management is it's very easy in our field for crisis management to drive all that we do. Uh, and that's often not within our control, but one of the things that does not resonate with me as a board member are resource decisions long-term based on near term crises. And by , by that I mean just throwing bodies without more at problems that need more holistic solutions. You know, there's a benefit to a corrective action plan, but the long-term benefit of a corrective action plan is systemic improvement, not just addressing the near term problems. So that's really important to me. And look, it is a journey and , um, I feel like a good board member as well as a vigilant and, and collaborative board can be immeasurably helpful to somebody in your role in that regard.
Speaker 4:Yeah, that's great. And, and how, if, if , um, for a chief compliance officer like me or or anybody else out there, what advice would you give us on how to build a successful relationship with our board and our committee chairs?
Speaker 3:First and foremost, for me it's candor and transparency. I think the two go hand in hand . Um, and that you , you can't force trust on one another, you have to build it bit by bit. And so knowing that when I turn the light off at night, the chief compliance officer is comfortable letting me know on behalf of the board committee not just unilaterally, that something has come up that we ought to know about. So near term reporting with exercising the right pragmatic judgment is very helpful. If there's a data matter, nobody would expect you to have all of the information about an incident and its ramifications. But the fact that it occurred is likely sufficient enough to let not just the, the audit committee chair or the compliance committee chair, but obviously other board members know as well. If you come to believe that there is a potential overpayment, for example, of significance in a program, the committee chair that oversees the program ought to have a near term notification, you know, as those facts begin to crystallize sooner rather than later. But that's just near term , um, near term relationship building and, and earning the confidence of the board and, and the folks who have the leadership position. For me, it's all about looking at, for example, the work plan that you generate. How incisive is it? Or is it just a series of tactical initiatives that are being treated like a checklist? Those are the kinds of leadership attributes that earn my confidence, certainly when I'm sitting in the board chair.
Speaker 4:Do you have a view on , um, the, the board chair's role in , um, either selection of a chief compliance officer or evaluating the performance of a chief compliance officer?
Speaker 3:Yeah, those are really important questions. I'll take the recruitment first. Uh , again, I don't know that there's a best practice, it's just a matter of judgment for me. But the way I typically handle it is, you know me well enough to know that I have a strong point of view that the compliance officer ought to report to the CEO , uh, therefore , um, the CEO and the ELT and that the CHRO ought to drive that search process. I think it's very helpful to ensure that the board committee's views on the attributes that ought to be prioritized in the search, be factored in , um, before the team goes to market. And as the process evolves and the candidates are assessed , uh, I do like to be involved when the finalists are being considered. I don't insist on it. I wait for the management team to ask , uh, me to get involved, but I, I think it's helpful when the list is down to say two or three and the management team is torn or wants ratification to spend time with each of them to ensure that they understand the big picture. Uh, and and you also, the board work that I currently do is by definition much more episodic than what you're doing right now. I mean, it is inappropriate for us to try to be part of the company's affairs five to six days a week the way you work, and I know you well enough to know it's more like six or seven. So we have a different prism, you know, how well will this person , um, lead within, within the, the lane at the company, but also create reporting mechanisms and systems that enable the board to engage in effective oversight. And that's not as easy to measure, frankly, for the management team when they assess the candidate. So that's really how I like to tackle it. And I do so at the invitation of, of the leadership team.
Speaker 4:Mm-hmm <affirmative> . Yeah, no , I think it's interesting. I think your comments that , what it makes me think about is , um, your involvement in engagement with the compliance officer , um, I'm sure create , um, greater support and that compliance officer feels greater support from you and then from the board generally, and also , uh, greater independence, I think, in their function by having that support from the, from the board. So I think those are, those are great comments.
Speaker 3:That's certainly the , the end game or the vision. I will say, as a caveat, when I talk to the compliance officer , uh, if I join a new board, I do emphasize that the dialogue that we have, whatever the cadence may be, is not a lobbying exercise. And by that I mean you have your own stasis at the management team level. You have fiscal responsibilities just like everyone else. You do have to be a source of truth. But the purpose of engagement with a committee chair on behalf of the board or the committee is not merely merely the lobby for more resources and gr and disproportionate budget allocations. I , I really expect the compliance officer to present evidence-based, fact-driven analysis for those kinds of initiatives so that they're well-founded , uh, and, and sustainable long-term . And knock on wood, I've been very fortunate to work with compliance officers who do exactly that.
Speaker 4:Yeah. Well, that's great. Um, appreciate those insights that you have a unique , uh, you're , you have a unique experience and that's , uh, really great to hear.
Speaker 3:So this has been terrific. I , it is been great to catch up with you as always. And I would ask, you know, to put on your calendar next October, if you can come back to Baltimore to get together. I know that there will be a 2025 conference up here and I'd love to see you up here then, and I'm sure the folks at A HLA would as well.
Speaker 4:That sounds great. I will look forward to seeing you there.
Speaker 3:Have a great day.
Speaker 4:Okay, thanks Tom.
Speaker 2:Thank you for listening. If you enjoyed this episode, be sure to subscribe to ALA's speaking of health law, wherever you get your podcasts. To learn more about ah a and the educational resources available to the health law community, visit American health law.org.