CRUSH, AI, and the Future of Healthcare Compliance

In this episode of Compliance Conversations, CJ Wolf sits down with Lisa Taylor, Chief Compliance Officer at Health & Hospital Corporation of Marion County, to unpack a new federal initiative that compliance leaders should not ignore: CRUSH, or Comprehensive Regulations to Uncover Suspicious Healthcare. Lisa explains what the request for information means, why it matters, and how organizations should think about fraud, waste, abuse, AI, billing complexity, and regulatory engagement moving forward.

This conversation comes at an important time. The federal government is signaling where it may go next on oversight, payment integrity, and program enforcement. And while requests for information do not create binding requirements on their own, they often offer an early look at the priorities that may shape future regulation. That is exactly why this discussion matters for compliance officers, auditors, revenue integrity teams, and healthcare leaders now.

Why This Topic Matters Right Now

Lisa makes a practical point early in the conversation: RFIs and proposed rules are one of the best ways to understand what the government is thinking before formal action happens. In the case of CRUSH, the government is asking for feedback on how to better identify suspicious activity, improve oversight, and strengthen efforts around fraud, waste, and abuse.

That may sound familiar, because fraud, waste, and abuse have always been central enforcement priorities. But this initiative reflects a broader shift toward using more data, more automation, and potentially more AI in how oversight is carried out. Lisa notes that the questions raised in the RFI touch on licensing, billing, data analytics, durable medical equipment, laboratories, and the role of AI in healthcare operations and monitoring.

For compliance teams, this is not just a policy conversation. It is an operational one. The real issue is not whether organizations support rooting out fraud. Of course they do. The issue is how oversight gets designed, where the burden falls, and whether legitimate providers are given a fair and workable environment in which to document, bill, and care for patients.

Key Takeaways from the Episode

One of the biggest takeaways from the episode is that CRUSH is a signal, not just a slogan. Lisa explains that the RFI gives the healthcare industry a chance to provide feedback before more concrete action is taken. That means organizations that want to influence policy should pay attention now, not later. The government may publish themes from public comments and use them to shape future regulatory direction.

Another major theme is the growing role of AI and data analytics. Lisa notes that the government is clearly interested in how these tools can be used to identify suspicious billing patterns and improve efficiency. But she also warns against extreme reactions inside organizations. Compliance leaders should neither panic about AI nor ignore it. Instead, they should occupy the middle ground: understand where AI already exists in the organization, assess the risks, and create structure around its governance and use.

The episode also highlights an important tension for providers. Lisa makes the case that most healthcare organizations are not trying to commit fraud. More often, they are navigating an extremely complex billing and coding system where errors, ambiguities, and documentation gaps can create risk even when care is appropriate. In that environment, additional scrutiny can place real strain on hospitals and health systems, especially those already serving complex or vulnerable populations.

CJ and Lisa also discuss the pressure that payer denials, downcoding, and administrative burdens can place on provider organizations. Lisa argues that if the goal is truly to improve integrity in the system, policymakers should also pay attention to practices that increase friction and cost for legitimate providers trying to get paid correctly for care delivered. That is a meaningful point for compliance teams because it broadens the conversation from pure enforcement to system design.

Another strong point in the conversation is the importance of distinguishing true bad actors from organizations doing their best in a highly regulated environment. Lisa supports strong action against labs, pharmacies, DME entities, and providers engaged in actual fraud. But she also emphasizes that large systems should not become easy targets simply because they are visible, complex, or more likely to produce recoverable dollars through audits.

The episode also offers a useful leadership reminder: compliance officers should not treat government activity as something distant. Lisa encourages listeners to stay connected by signing up for CMS and OIG updates, engaging in professional organizations, and building peer connections with other compliance professionals. She also suggests that providers invite policymakers and regulators into real healthcare environments to better understand what billing, documentation, and patient care actually look like day to day.

Practical Steps Teams Can Take Now

Organizations do not need to wait for CRUSH to become formal rulemaking before taking action. There are several practical steps compliance and audit teams can begin now.

Start by monitoring the issue directly. Review the RFI, track commentary, and watch for follow-up publications in the months ahead. Lisa notes that after comment periods close, the government may take 60 to 180 days to publish responses or indicate next steps. That makes this a good time to assign ownership for monitoring developments.

Next, assess where your organization may already be exposed in the areas the government is highlighting. That may include billing workflows, provider licensing controls, DME or lab-related services, data analytics practices, or AI-enabled tools that affect documentation, coding, payment, or oversight. Even if your organization is not directly implicated in these categories, they provide a useful lens for risk assessment.

It is also worth reviewing your organization’s AI governance posture. If AI tools are already being used for documentation support, workflow automation, denials management, or coding-related processes, compliance should be part of that conversation. Lisa’s advice is clear: do not overreact, but do not sit back either. Governance, visibility, and cross-functional discussion matter now.

Finally, remember that engagement is part of compliance leadership. This episode is a reminder that regulatory developments do not only happen to organizations. They are shaped, at least in part, by organizations that choose to participate. For some teams, that may mean responding to an RFI. For others, it may mean educating leadership, preparing operational teams, or opening dialogue with policymakers and industry groups.

The bigger message from this conversation is simple: compliance programs should pay attention when the government shows its thinking. CRUSH may still be in the information-gathering stage, but the issues behind it are already here. AI is here. Data-driven oversight is here. Billing complexity is here. The question is whether organizations are preparing in a way that is informed, realistic, and strong enough to keep pace.

PS – If you’re watching the video version, we had a few technical difficulties with the video freezing in certain spots, but no issues with the audio.

Resources:

• June 6, 2025 Presidential Memorandum - https://www.whitehouse.gov/presidential-actions/2025/06/eliminating-waste-fraud-and-abuse-in-medicaid/

• Request for Information for CRUSH - https://www.federalregister.gov/documents/2026/02/27/2026-03968/request-for-information-rfi-related-to-comprehensive-regulations-to-uncover-suspicious-healthcare

Episode Chapters & Transcript

0:00 Welcome to Compliance Conversations

0:23 Meet Lisa Taylor and her compliance background

2:58 What CRUSH stands for and why it matters

4:10 Why RFIs matter in healthcare compliance

5:55 Key dates and timing for the CRUSH RFI

8:12 What the government is looking for with CRUSH

9:48 AI, billing, DME, labs, and data analytics in focus

10:27 Fraud, waste, and abuse across administrations

12:22 How compliance leaders should think about AI

15:30 What CRUSH could mean for organizations and compliance programs

16:47 The provider burden of denials, downcoding, and appeals

19:08 Why billing complexity remains a core compliance challenge

20:53 Defining true bad actors vs. burdening legitimate providers

21:01 Potential downstream impact on vulnerable populations and safety-net systems

25:48 Why most organizations are trying to do the right thing

29:41 Why compliance officers need to engage with policymakers

32:33 Final advice for compliance leaders staying ahead of change

34:19 Closing thoughts

0:05
Hello everybody.

0:05
Welcome to another episode of Compliance Conversations.

0:10
I'm CJ Wolf with Healthicity, and we got a cool topic again today.

0:15
And we got a cool person too, Lisa Taylor.

0:18
Welcome to the show, Lisa.

0:20
Hi, CJ, Thank you for having me.

0:23
Absolutely.

0:23
We're so excited for the expertise and experience that you have and are willing to share.

0:30
But before we get to our topic, we'd love to hear a little bit about yourself.

0:33
Sure.

0:34
So I don't know that I would necessarily call myself an expert.

0:40
I would say that I have been doing this for 25 years.

0:43
But it's one of those things where you learn something new every day.

0:48
And sometimes it it catches you off guard.

0:50
So definitely want to say that to the audience that it's always good to listen to these kinds of podcasts because there's always something new popping up.

0:59
So right now I'm the chief compliance officer at Health and Hospital Corporation of Marion County.

1:06
And for those listeners that don't know where that is, that's actually in Indianapolis, IN.

1:11
And we're a unique system.

1:13
So we have a hospital, Eskenazi Hospital, we have the Marion County Public Health Department, we represent Indianapolis EMS, so all of the EMS providers in the area.

1:30
And we also own a little over, I think 80 at this point, maybe a little over 70 at this point, long term care facilities throughout the state of Indiana.

1:43
So yeah, we are, we're very unique.

1:46
We like to call ourselves unique, but very unique.

1:49
And so we're very much there for all of the individuals that live in and around Marion County.

1:56
And so really happy to be there.

1:59
Started there last year.

2:02
And before that, I had spent some time in Pediatrics.

2:05
So with both Cincinnati and Dallas Children's was the chief compliance officer for almost 10 years for UC Health in Cincinnati, which is a large academic medical system.

2:18
And I, I'm just, you know, I've, I've got a lot of different backgrounds, but one of my backgrounds is I spent about 7 years at Toyota Motor engineering and manufacturing for North America.

2:30
So took a detour and have a lot of lean thinking in my background.

2:35
So you'll, you'll hear some of that come out in the podcast today.

2:40
I love it.

2:40
I love it.

2:41
One of the hats that I wear has to do with patient safety and quality improvement.

2:46
And you know, a lot of those principles come from other industries like like Toyota and and others.

2:54
So good, good things to learn.

2:57
Thank you again for for being here.

2:58
We're going to talk about we're going to talk about crush.

3:01
We know that that Valentine's Day is past.

3:04
We're recording here about a month past Valentine's Day, but we're going to talk about a crush CRUSH and I'm going to let you tell us what that means 1st and maybe just a high level overview and, and we'll kind of get into it from there.

3:21
Well, I'm going to be facetious here, but if you've been a compliance officer for at least a month, you love when the government utilizes acronyms because there's a lot of them.

3:33
They sometimes are hard to remember, but crush is the comprehensive regulations to uncover suspicious healthcare.

3:44
So essentially about, oh, a few weeks ago, the government issued a request for information about Crush.

3:56
So essentially it's asking us as professionals in the healthcare arena to review this request for information and provide feedback to the government.

4:10
Yes.

4:10
So these RFIS as, as, as they're called, it's our opportunity to to share some feedback, right?

4:17
And a lot of us kind of complain a little bit, but here's, you know, they usually ask for feedback or ideas beforehand.

4:25
Not always, but this is a chance, absolutely.

4:28
So if you ever, I always advise any and all compliance officers, privacy officers, anybody kind of in this space, if you're a biller coder, always be on the lookout for requests for information.

4:43
Or another great government acronym is an NPRM, which is a notice of proposed rulemaking, as most of us know, because that's our opportunity to respond back to the government when they are proposing rules or when they're asking for information.

5:00
And what this always tells us is it gives us a little peek behind the curtain as to where the government may go.

5:08
And it's always really good at understanding kind of what the government's thinking and where they might Dr.

5:16
new regulation, new legislation.

5:19
So it's really our opportunity to be heard.

5:23
Yeah, absolutely.

5:24
And, and, and then, you know, they digest and we hope they digest our feedback and maybe rethink things that usually comment back in the things that I've read.

5:36
So they do seem somewhat thoughtful.

5:39
And, and then we we might get some regulations out of all this.

5:43
So, so before we get too much into what HHS is looking for, what about some dates?

5:50
Like if people have, what are the important dates we should know about with this request for information?

5:55
Yeah.

5:56
So the important dates are it was published on February 27th.

6:00
And in the RFI it says the government is giving us 30 days to respond back.

6:06
So if you're interested in responding back, that's going to kind of be tight to the publication of this podcast.

6:13
But, you know, it gives you a few days to kind of look at it if you want to comment.

6:19
Great.

6:20
Usually when I do comment back or when I put together some thoughts, I always run it past my, my legal and my marketing and communications group and, and certainly the president and the board chair just so they know kind of what I'm saying.

6:37
But it is our opportunity to feedback to the government anything that we would like them to know.

6:43
So they do really, they do really listen.

6:45
And after we respond, then we need to give them some time.

6:50
But what we should be looking for after that, and sometimes it's pretty quick and other times they may have shelved it.

6:59
So we just have to watch for what comes out.

7:01
But you're exactly right.

7:04
What happens is, is after they collect all of those comments, they actually go back and they publish them.

7:12
So they say, you know, we asked this, you commented that, and so just know that your commentary may be published.

7:21
They also will sometimes do, it's not necessarily every single individual comment, but if they get comments that are comments that can be kind of grouped together, they certainly will do that as well.

7:36
They will say many of you commented on and then they will give their their thoughts back to that.

7:42
So certainly be looking, I would say 60 to 180 days out after this potentially that's kind of when they come out to what the responses are and what the government is thinking.

7:56
Yeah.

7:57
So it sounds very similar to like a a final rule, a proposed rule, a final rule, you know, for like the physician fee schedule or for the inpatient prospective payment system where there's kind of the back and forth and all that good stuff.

8:09
Absolutely.

8:10
Right.

8:12
Yeah.

8:12
So what are they looking for?

8:14
So what what is what is this whole initiative about and, and why?

8:18
Yeah, what are they looking for first of all?

8:21
Sure.

8:21
So I think the reason why they made it crush is because there was a directive from President Trump and that actually came out earlier in the year.

8:34
And so he wants to crush Medicare and Medicaid fraud and it waste and abuse.

8:41
We know that this has always been a a big subject for the government because when they go after bad actors and when they go after fraud, waste and abuse, they're able to collect quite a bit of money back into the system.

8:57
And so they're all about are we paying for what we should be paying for within healthcare?

9:05
And So what we're seeing in this is, you know, the government asking about things like licensing and licensing the appropriate individuals.

9:17
How do they make sure that they do that?

9:20
They want to make sure that they're getting rid of and they're identifying unscrupulous individuals early and often.

9:28
They're asking about billing and some data analytics pieces and what should they be looking for in terms of utilizing data analytics.

9:39
And again, this is always this always excites me for my my lean thinking, but how are we going to get more effective and efficient in billing?

9:48
They are asking about along those lines, AI and what kind of AI is out there and are we utilizing any AI?

9:59
They really hone in for those of you that are listening, they really hone in on durable medical equipment and also laboratories.

10:09
And so if you're a part of either of those types of institutions or if you have those within your four walls, it's something to to be paying attention to as well.

10:22
So they're looking to crush broad waste and abuse what always.

10:27
So I've been doing this almost 30 years now, you know, seen transitions through different administrations, you know, from both sides of the aisle.

10:37
And it, oh, it's always makes me laugh that, that oh, you're the first one.

10:45
Both parties have been doing it for 30 years.

10:48
Because who doesn't want to get rid of fraud, waste, abuse, right?

10:52
So like, regardless of your political leanings, none of us want money wasted, right?

10:57
We want money used on, you know, people that we love and we want the best use of those dollars.

11:05
We don't want fraudsters, you know, out there.

11:09
But with something that you mentioned really rang true to me.

11:12
When you, when they invest a lot of money, they usually get a big return.

11:16
I was reading the OIGS report a couple months ago and for every dollar the OIG invests, they get $11.00 back.

11:27
That was a great return on investment.

11:29
Like you and I would we would, we would love our retirements to be that good.

11:35
Like, yes, give us that.

11:38
Yeah.

11:38
How do I, how do I buy stock in HHSOIG?

11:42
That's exactly right.

11:45
Yeah.

11:45
So I, I think it is a winning message.

11:48
And again, I'm not getting political.

11:50
It's just it, it's always, I think an important message.

11:54
And I also think, you know, as an individual citizen, I, I want the fraudsters gone so that the legitimate providers can, can provide and thrive.

12:09
And so hopefully that's what will happen.

12:11
We'll, we'll, we'll wait and see.

12:14
The other thing you mentioned is AI, and I think that's going to be a big, a big deal.

12:22
Clients that are using it or want to use it in ways that make me question if that's proper right You, it's almost like this battle of AI.

12:33
You know, you want the payer to pay for something.

12:35
So we're going to use our AI to beef up the medical record so that your AI can check it and make sure that you pay us.

12:42
And it's just kind of funny.

12:44
But so some of those things that you said really ring true to me.

12:49
Yeah.

12:49
I mean, I do think that having done this for a long time and in house, I've never been with an organization that sets out to commit fraud, waste or abuse.

13:01
I mean, what I would say is, and, and probably what the vast majority of your listeners know is that billing and coding, especially within Healthcare is very complex and it's more of an art than it is a science.

13:16
And so it really, I, I've never been with an entity that kind of sets out to, you know, commit major fraud, waste and abuse.

13:25
I think what we need is, you know, definitely a more fair system where it's definitely a, you know, we are providing the care and treatment now how do you want us to document it?

13:37
And you do want us to get better at documentation.

13:42
We want to get better at documentation and that's what we utilize to bill and code.

13:47
And so, you know, things like ambient listening systems, I think what those are going to do is those are going to allow us to get better at our documentation.

13:58
And so you may see billing and coding go up for certain providers, meaning they are billing and coding at a higher level than what they've done in the past.

14:10
And that's because they're utilizing these tools and these systems to do it the right way.

14:15
And so, you know, I, I think that's really gonna impact us.

14:21
And what I've been saying about AI and, and have been going around and, and presenting on AI here recently is that, you know, as a chief compliance officer, what I advise others is I, I see people that are on the end of freaking out about it.

14:39
And then I see people on the end of not paying attention to it.

14:42
And I feel like as chief compliance officers, we got to be right there in the sweet spot of the middle, which is we really need to care about AI.

14:51
We need to understand it's probably in our organization already.

14:55
We can't sit back and do nothing about it.

14:58
But we can be, you know, within our organizations, starting this conversation if we haven't yet, and talking about what are we gonna put together as a structure for managing the AI that is in our organization right now?

15:14
Such, such great, great comments.

15:19
This is a great conversation.

15:21
We're going to take a quick break, everyone.

15:30
Welcome back from the break, everybody.

15:32
Lisa has been sharing with us some of the, the concepts from Crush, the RFI for Crush and we, we've been talking about a lot of things.

15:41
So you're, you know, you're involved in the compliance profession.

15:45
What do you think this means for organizations and compliance programs?

15:52
Well, I really think we knew this was coming last year.

15:57
And the reason why I say that is because Kim Brandt, who I know we, we all see her on the speaker circuit.

16:07
She works at CMS now with Doctor Oz.

16:11
She gave a talk last year at the HCC as Compliance Institute, and she said, you know, we as CMS want to begin utilizing amazing, you know, AI and systems to stop false or fraudulent payments at the door.

16:30
And so we kind of knew this was coming.

16:32
Here's the issue that it really presents is that, you know, from a, let's just speak from a hospital perspective and I'm, I'm speaking obviously from working for a county organization.

16:47
You know, we treat the sickest of the sick and we treat anyone regardless of their payer source.

16:54
And so it's hard on organizations like ours because what we're seeing is that there are some payers out there who are denying just outright or who are automatically down coding by one level or automatically doing things.

17:12
And So what happens is and and I'm not going to get political either, I'm just trying to say what what's really happening in house, what's happening.

17:22
Yeah.

17:22
What's happening is, is that the hospitals who we aren't swimming in money, let's be honest, it's the insurance companies, they're swimming in money.

17:32
We are not swimming in money.

17:34
And so the insurance companies when they just auto deny or when they auto down code or when they do these kinds of things, that means that we need to expend more money either purchasing AI options, hiring more people to go through these denials, sending more appeals in.

17:56
And all it does is cause more frustration for not only the hospitals, but also the patients that we care and treat.

18:04
And you know, already it's taking quite a bit of time to adjudicate billing as it is just depending on the payer source and and what type of you know, what, what type of bill you are dropping.

18:20
And so, you know, I have concern that this is yet another, you know, this is yet another an imposition isn't really the word.

18:32
But I think you get what I'm saying is that it's just something else that that these non profit organizations and and that's who I'm worried about, really have to expend a ton of money just even trying to figure out how do we get paid and how do we get paid correctly.

18:53
And so I do think at the end of the day that, you know, if, if this is my dream, my dream would be that we would see more of a simplified billing system.

19:08
It's quite complex right now.

19:10
That's why it's so, you know, confusing to everyone.

19:13
And and that's why it could be argued more than one way.

19:17
And to, you know, not only simplify that, but also put some of the onus on, you know, fighting these things or adjudicating these back on the insurers because, you know, to auto deny or to auto down code or to do some of these things.

19:39
It's not fighting fraud necessarily.

19:41
I mean, a lot of us are, you know, just doing the best we can day-to-day to drop the bills for the patients we've seen.

19:52
Yeah, Now that's such a good, that's such a good point.

19:55
You know, I great point.

19:56
And I wonder if if that should be a comment of, hey, when you're doing this crushing, maybe you should be crushing unfair practices from payers as well.

20:07
And I'm not trying to get on one side or the other, but I hear what you're saying is that, you know, just denying things for really no reason.

20:19
It puts a burden on people and it's so expensive.

20:21
And, and sometimes I think providers are probably just thinking, is that worth our fight?

20:26
Do we have enough money, time and energy to fight that issue?

20:31
You know, you get nickeled and dimed to death, you know, maybe you're going to fight the bigger ones, but you know, it's hard.

20:37
So I, I totally hear what you're saying.

20:39
You know, I've worked in house for large health systems as well.

20:42
And it's a, it's a tough place to be.

20:45
And, and unfortunately, these types of, you know, crushing of a fraud, waste and abuse often lands on providers.

20:53
Yeah, I, I will tell you what I can kind of foresee if I have my, my magic 8 ball in front of me.

21:01
I kind of foresee some, some implications for other laws and regs and some implications for, you know, our most vulnerable populations of people, which are, you know, gonna be individuals who, you know, don't have a payer source or they don't know where to go.

21:24
I could see implications of maybe not necessarily EMTALA, but when I've worked in, you know, academic medicine and, and I'm back in academic medicine now, what I found, what I find is people get confused about IMTALA and you have these hospitals as well that want to, you get individuals in the hospitals that want to kind of dump on the, you know, AM CS or the, you know, safety net hospitals that are in their area because they think the safety Nets get all of this money to treat all of these people.

22:03
But I gotta be honest, there's no amount of money that you could give an AMC to treat all these people.

22:12
And that's what really shows up in, you know, our annual report to the government and in our taxes and those kinds of things.

22:21
And so, you know, I think the government should look at those kinds of things as well is what are, you know, that we have disproportionate share payments and those kinds of things.

22:31
But but what really are the numbers that we're reporting?

22:35
And, you know, those are those are accurate numbers.

22:38
And so, you know, I do think that, you know, if America's really gonna be the place to be for healthcare, and I am a true believer that it is.

22:51
I've always used the resources in every place I've ever worked, the physicians, the leaders, they are people that are there and are providing incredible healthcare and incredible research and they're doing things to really combat, you know, big expensive payments is, you know, we've we've got to get our arms around some of these things.

23:17
We also have to do some grass roots things, which is why I'm so excited to be with an organization like HHC because we have things like food pantries that we, you know, partner with and it, you know, it starts with what do you put in your body?

23:34
What do you eat?

23:35
Providing education to people.

23:38
All of those things really need to be on on the cutting edge of, and it sounds so simple, but they need to be a part of how we care and treat for people.

23:53
Yeah, I think you're so right.

23:57
You know, and this may be taking us a little off, off on a tangent, but I think about, you know, like diabetes, for example, it's a preventable diabetes type, type 2 diabetes is preventable.

24:11
And if you look at just the incidents in the United States alone, it's going up.

24:15
And that doesn't have to do with our healthcare system.

24:18
That has to do with things that you were talking about.

24:20
What are you putting into your body?

24:23
You know, people say we spend all this money on healthcare, but we're not healthy.

24:27
Well, the healthcare system doesn't make a person healthy.

24:30
Behaviors make a person healthy.

24:32
So, you know, so I, I totally agree with you.

24:35
It's like where, where should we put incentives and, and, and, and, you know, motivations to kind of help, you know, the long term, you know, life of this healthcare system because we're just spending too much money.

24:51
It's, it's not sustainable.

24:54
Exactly right.

24:54
And we've got the best doctors.

24:56
I'm I'm convinced that we've got the best doctors, the best facilities.

25:01
We do incredible research, you know, we, we are a country that has, you know, great water supply and, and all of those things that go into it.

25:14
And, you know, when you look around sometimes our most, you know, some of our communities can't get access to fresh fruit and vegetables and they can't, you know, they just, it's easier and it's cheaper to buy, you know, a sugary cereal off the off the shelf than it is to, you know, really eat wholesome fruit, fruits and vegetables that are, are potentially available to them, but that are more expensive.

25:42
And so it's looking at these kinds of things that I think would be very helpful to us.

25:48
I also think that the government needs to know, getting back to crush again, that vast majority of us are just trying to do a good job.

25:59
If we have bad actors within our four walls, it doesn't usually take very long for us to identify those and part ways.

26:10
You know, I and, and I back the government wholeheartedly 100% on, you know, these labs and pharmacies and DME and providers who are seeing patients and not really treating patients, if you know what I mean, which really gets down to the fraud piece.

26:31
I, I am wholeheartedly engaged with that.

26:36
I just think that understanding by them, and I'm sure they do, but understanding that, you know, we're, we're one of the highest regulated areas in the country.

26:48
So that makes it kind of hard for us to do our jobs.

26:52
It's not that those regulations, regulations aren't warranted and it's not that some of them aren't very good.

26:58
A lot of them are.

27:01
But I think it's, you know, trying to figure out how do you utilize that AI to be more effective and efficient, not only on our side, but also on the government and payer side so that we all get a win win out of this.

27:17
But I, I will tell you that it, it sometimes is a bit disheartening when you are a taxpayer, when you are an individual who pays into this insurance game and you see where the CE OS and people who work for insurance are getting millions of dollars in bonuses a year and are being paid out.

27:39
And I'm not saying not good for them, I guess good for them.

27:43
But it's also a then we need to make sure that we are also paying for and not denying care that is valid, that is documented appropriately, and that is due and payable to those individuals who have treated the patients that you insure.

28:01
Yeah.

28:02
You know, as you were talking, it made me think about, you know, I read all these OIG audits of, you know, 'cause they're doing data analysis and, and usually they, you know, they're usually really good in their data analysis and they, they find bad actors 'cause they have the entirety of the data of the entire country to, to mine.

28:21
But there was one that I was reading it had to do with, you know, they had on their work plan dermatology and modifier 25 with an E&M on the same day.

28:31
And, you know, they said, oh, they're more than half of dermatologists do it.

28:35
And then they got in there and they audited and their results were like, most of these are right.

28:41
And so it's like, right.

28:43
So it's like I, I I want whatever the result of this is, I'd love for it to like show that those who are doing their right and, you know, go after the true bad actors.

28:59
It would be the would be the would be my comment to the government of define what a a bad actor is and really go after them first, then see what else there is right.

29:12
Don't, don't be, you know, don't be taking a pound of flesh out of large organizations just so that you can say you've got some money back into the public coffers, right?

29:23
So my, my feedback would be, you know, let's really on this initiative, let's see if we can truly, truly, truly just get the fraudsters right anyway.

29:33
Well, what I, what I have seen with this, with this government right now is a really good step.

29:41
And here's something that I would also encourage compliance officers to encourage within their organizations is, you know, this, this is a political issue.

29:52
It just is.

29:53
It's always gonna be, healthcare's always gonna be.

29:55
So if you're a compliance officer and you don't wanna be in politics, you might be in the wrong profession 'cause you're gonna see it throughout your career.

30:04
But what I always advise and what I would love to invite is that, you know, at HCCA last year, the government did sit down with a group of chief compliance officers and talked about things, talked about issues.

30:21
What I would like to invite is for anybody listening to this podcast that is in government, go get yourself invited to tour a hospital to, you know, sit down and talk to providers.

30:37
Sit down and talk to compliance officers.

30:39
Ask them what a day in a in the life looks like.

30:43
Ask them, you know, where are the issues when you bill?

30:49
You know, modifiers is one, right?

30:51
There's a ton of them out there.

30:53
Modifiers are always dicey.

30:56
But it's you know, it's site of service.

30:59
It's you know, you make one little change in Epic and that might throw off the system to start billing something incorrectly.

31:08
And you don't know until you catch it weeks later.

31:11
And then you're like, oh, we gotta pay all these back.

31:13
So, you know, for any kind of individual that is in politics that has impact on healthcare, invite them out, show them around, show them what you do, show them how you are impacting lives, caring for the sickest of the sick, seeing patients, getting them in.

31:32
You know, what is your throughput?

31:34
Why is it hard to have, you know, quick or slow throughput those kinds of things?

31:41
Because, you know, in their defense, some of these folks that that write the laws are doing what they can with our feedback, but they haven't worked in these situations before.

31:52
Some of them have, but, you know, to to show them and to to do a go and see.

31:59
That's, it's part of the Toyota way that's innating me now is, you know, invite them in, do a go and see, show them what it's really like.

32:08
And then, you know, I think some of that will transition into or translate into some really good feedback to the government about what we do and how we do it.

32:22
Yeah.

32:22
Great comments, Lisa.

32:23
You know, I feel like I can talk all day about this, but we are running out of time.

32:28
Any last minute thoughts or, or comments before we before we close?

32:33
I think I would just say, you know, as a chief compliance officer, I can, I can definitely feel some of the pressure, definitely feel some of the stress that that the rest of you feel that are listening to this.

32:51
What I always advise people is keep watch.

32:55
You can sign up for a lot of different things online that are free.

33:00
You know, go to CMS website, go to the OIG website, sign up for their listservs, you know, get involved in professional organizations.

33:10
If you think you're alone, look for compliance officers in your area that you can connect with or people online through LinkedIn that you can connect with.

33:20
There's a huge community of us.

33:23
There's many of us that are, that are more than willing to, to be helpful.

33:27
And I think when you're in this profession for long enough, you, the, the stress and the pressure gets a little different.

33:37
It's, it's one of those, you know, you do the best you can.

33:42
And so to get you kind of in the, that middle ground where you're like, I'm not gonna fix this overnight and I'm gonna do what I can and we're gonna show, you know, that we're really achieving great things over time.

33:57
I think that's what you should shoot for with your compliance program.

34:00
So just like this request for information, you don't have to answer every request for information.

34:06
You don't have to answer every notice of proposed rulemaking.

34:09
But when you feel driven to or when your organization feels driven to, you should take the opportunity to do that.

34:19
Yeah, such great advice.

34:22
Lisa, thank you so much for spending time and your and sharing your expertise with us today.

34:29
Absolutely happy to.

34:30
Thanks so much, CJI.

34:31
Appreciate it.

34:34
Absolutely.

34:34
And to our listeners, as always, if you know of a guest like Lisa that would make a great guest, please let us know.

34:41
And if there are topics that are of particular interest to you, please let us know.

34:45
Until next time, everyone, take care.

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