Keeping Your Occ Med Marketing Compliant in 2023 and Beyond

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In the ever-evolving landscape of healthcare marketing, it is crucial for occupational medicine providers to stay informed and compliant with regulations. With the rapid changes in laws and guidelines from various governing bodies, it can be challenging to navigate the complex world of healthcare marketing. In this blog post, we will discuss the key compliance issues that occupational medicine providers need to be aware of and provide recommendations on how to ensure marketing efforts remain compliant in 2023 and beyond.

Section 1: The Changing Healthcare Marketing Landscape
The healthcare marketing landscape has undergone significant changes in recent years, driven by the evolving regulations and guidelines set by organizations such as the Health and Human Services (HHS) and the Federal Trade Commission (FTC). In addition, various state laws have added another layer of complexity for healthcare marketers to navigate. It is essential for occupational medicine providers to keep up with these changes to avoid potential legal repercussions and protect patient privacy.

Section 2: The Implications of HIPAA and the HHS Bulletin
HIPAA (Health Insurance Portability and Accountability Act) is a critical regulation that protects patient privacy and governs how healthcare providers handle patient information. In recent years, the HHS issued a bulletin that reclassified certain types of data as Protected Health Information (PHI), limiting the tools and tactics that can be used for marketing purposes. Occupational medicine providers must be aware of these changes and ensure compliance to avoid any violations.

Section 3: The Role of the FTC in Healthcare Marketing Compliance
The FTC has also made significant strides in regulating healthcare marketing practices, particularly regarding the sharing of data with third-party entities. Occupational medicine providers need to be cautious when exchanging information with external organizations, as the FTC requires business associate agreements to be in place. Failure to adhere to these guidelines can lead to legal consequences and harm a provider’s reputation.

Section 4: Navigating State Laws on Privacy and Compliance
In recent years, numerous states have enacted privacy laws that impact healthcare marketing practices. These laws range from basic data protection practices to more specific requirements for healthcare data. Occupational medicine providers must be aware of the laws in the states they operate in and ensure compliance to stay ahead of potential legal issues.

Section 5: Steps for Ensuring Compliance in Occupational Medicine Marketing

  1. Conduct a comprehensive audit: Occupational medicine providers should assess their digital ecosystem, including website tracking tools, analytics software, and third-party plugins. Identifying all technologies and tools utilized is the first step in understanding potential compliance risks.
  2. Prioritize compliance risks: After the audit, providers should prioritize technologies and tools that pose the highest compliance risks. These are the areas that need immediate attention and remediation to ensure compliance.
  3. Implement HIPAA-compliant analytics tools: For providers who rely on analytics for marketing insights, it is crucial to switch to tools that sign Business Associate Agreements (BAAs) and commit to proper data handling according to HIPAA regulations.
  4. Review email marketing practices: Occupational medicine providers should review their email marketing strategies, ensuring that patient data is protected and that all communication remains compliant with HIPAA and state laws.
  5. Stay informed about changing regulations: Healthcare marketing regulations are constantly evolving. Providers should subscribe to newsletters or notifications from reputable sources to stay updated on the latest changes in regulations, guidelines, and best practices.

In the face of changing regulations and guidelines, occupational medicine providers must prioritize compliance in their marketing efforts. By staying informed, conducting regular audits, and implementing necessary changes, providers can maintain the privacy of patient information and protect themselves from legal consequences. As the healthcare marketing landscape continues to evolve, it is crucial to remain vigilant and adapt to these changes to ensure marketing efforts are effective, ethical, and compliant in 2023 and beyond.


Transcript

Larry Earl, MD: Good morning. Good afternoon, everyone. Dr. Larry Earl here with NAOHP Town Hall. Welcome to Keeping Your Occmed Marketing Compliant in 23 and Beyond with our guest today, Jenny Bristow of Hedy and Hopp. Welcome, Jenny. 

Jenny Bristow: Thanks for having me. 

Larry Earl, MD: Hedy and Hopp is a full-service and fully healthcare marketing agency that is a leader in privacy forward marketing programs.

Jenny is a frequent speaker about how developments with HHS and FTC, not to mention state laws, have changed the healthcare marketing landscape. We’re also joined by Ira Pasternak of WebForDoctors, who will be assisting us with moderation today. Hey, Ira. Nice to have you here.

And before we get started with all that, just a little bit of housekeeping, we’d like to give a shout out to our sponsors today, TrestleTree, WebForDoctors, NetHealth, and Abbott, our premier sponsors.

Thank you all for supporting NAOHP. And our NAOHP moment today comes from One of our comprehensive resource manuals in the chapter on developing a comprehensive on site clinic where Donna Lee Gardner discusses regulatory compliance. She says by assisting employers with regulatory compliance, providers develop a better understanding of their clients needs and create a desirable team atmosphere.

This approach often leads to the provision of other services outside regulatory compliance and therefore more business. And how do we get more business? Well, we do that through our marketing efforts, but we don’t often talk about compliance in our marketing. So if you don’t have a marketing provider that is guiding you and assisting you in this area, pay attention because you’re going to learn about that today.

So with that, I am going to turn this over to Ira and Jenny to lead our discussion. 

Ira Pasternack: Ira take it away. All right. Thank you, Larry. So before we jump into today’s questions officially I wanted to give Jenny a quick chance to introduce herself and tell us a little bit about the focus of Hedy and Hopp.

As many of, you know, My company is a marketing agency, but Jenny works with on a different level than we do, both with regard to a lot of these compliance issues and size of organizations. And so Jenny, tell us a little bit about what you do with Hedy and Hopp. 

Jenny Bristow: Yeah, of course.

First, I’m so honored to be on today. I really appreciate the opportunity. I’ve been the owner of Hedy and Hop. I was the founder eight years ago. Hedy and Hopp, the name comes from Hedy Lamarr and Grace Hopper. It’s a nod to the two women that made the internet what it is today, kind of giving that recognition and acknowledgment back to them.

But we are a full-service healthcare marketing agency. So we do everything from analytics and dashboarding, Annual strategic planning, go-to-market strategies, and then full-service implementation. So thinking about paid media campaigns, website design and development, email marketing, et cetera. We do all of that.

We work with systems nationwide and providers regional. Hospital groups and then single-location hospitals. But we typically do work with larger groups. And so with larger groups come more complex compliance issues because there are more hands involved in the marketing work. So we have always been a HIPAA-aware organization trying to identify potential compliance concerns and fixing them with our clients before it became an issue, but there have been a lot of fundamental things that we’re going to talk about today that have made us really lean into it and become experts in our space.

Ira Pasternack: Thank you, Jenny. So speaking of kind of some of those changes, it’s we’re coming up on, I think, about it’s about it’s about a week from the anniversary of the big HHS bulletin that kind of changed some things in the marketing world. So can you tell us a little bit about how that bulletin from last December as well as any related changes have affected privacy and security this past year?

Jenny Bristow: Yeah, it’s been a whirlwind. The minute we think things are calming down and we know a path forward, something else changes. So there’s three key things that we have to think about as health care marketers. The first is the bulletin by HHS, Health and Human Services, related to HIPAA and specifically the marketing.

For our services as a provider, so they reclassified things like IP address and device I. D. And to P. H. I. And really began limiting the kinds of tools that we could use and the marketing tactics we could use to fundamentally market our services. A lot of the things people use, such as Google Analytics, are no longer compliant out of the box.

And there are no ways to make it compliant. You can’t just turn off IP capturing and all of a sudden think you’re safe. You’re not the other thing that the second thing that happened was FTC began going after groups for selling data. Now, these groups are not actually selling data, but legally, it’s So that’s a very important piece of consideration because they were exchanging information for information.

So by having a third party tracking pixel such as Facebook or Google on their website, they were sharing that data with Google in exchange for receiving conversion information. That’s a big no, no. So groups like Better Health were fined over 8 million and it was promoted or advertised that they were selling consumer data and they weren’t.

Instead, it was consideration. They were exchanging information. For conversion information. The third thing that’s come on the radar in the last year is state laws. So there are now over a dozen states that have privacy laws in place ranging from very basic and things that we’re already really doing as far as a fundamental best practice all the way up to some states now have opt in.

Instead of opt out requirements. So think about what’s happening in Europe with GDPR. Some states are now requiring that as well as some things that are specific around health care data. So now we have information coming from all of these disparate groups and things are changing monthly. So it’s being it’s really a unique time to be a health care marketer.

Ira Pasternack: So yeah, you just gave me a little bit of a break. PTSD flashback. I’m sorry. It is. I’ve dealt with over the last year and as I’ve been kind of kind of keeping up with these and of course, that’s how I found you in the first place. Just a note. I put in the chat here. The HHS bulletin from last year.

1st of last year, as well as an article from last March, I believe from the FTC regarding specifically the meta pixel, which is probably the or possibly the, the biggest most severe problem. So I want to talk a little bit about that. But I guess just to make sure we didn’t miss anything, you kind of covered the you’ve touched on these first three questions already here as far as how some some HIPAA changes based on the HHS bulletin and some of the the how that’s evolved into the FTC getting involved. As well as some state laws, but can you go a little bit more into detail about maybe with the FTC specifically, why or in what circumstances healthcare organizations need to be concerned, not just about HIPAA compliance, but also FTC 

Jenny Bristow: compliance.

Yeah, so 

Larry Earl, MD: a question about that too, because you mentioned, I think that it was not necessarily. Individually identified PHI that was shared, right? This is, this was aggregate data and that was still scrutinized. 

Jenny Bristow: Well, it’s still individually shared because the pixels on the websites allow those organisms entities to 

Larry Earl, MD: be tracked.

Okay. 

Jenny Bristow: Okay. I got it at the individual level. So the FTC a few months ago actually joined forces with health and human services and sent out “nasty-gram” letters to 130 systems across the country that said, Hey, you need to worry about HIPAA compliance, but you also need to be thinking about this FTC privacy and we’re now joining forces.

So you need to be especially aware that this is a big enough issue that these Entities are chatting with each other and making sure that we’re aligned. So the FTC does not want you to share information with third parties. And the kicker is they specifically said that they did not like how people do not have this disclosure on their website, that they’re sharing information in this way, but they say, even if you put it in your privacy policy, you still can’t do it because no normal consumer would be okay with that.

Is the summary of what they said. So simply saying in your privacy policy in your website that you’re going to be sharing information in this way does not allow you to continue with these behaviors. So in general, you need to make sure that you’re not sharing part. sharing information with third parties where there is not a business associate agreement in place.

Ira Pasternack: And part of that is that just putting something in your privacy policy at this point, those policies are so dense that that is a very specific thing that you can’t just bury in a policy. It really needs to be an opt in thing, not a just an informed. Informational thing 

Jenny Bristow: and well, even then it can’t even be opt in.

Like, they’re just saying, don’t do this practice at all. Full stop, you know, like, if you don’t have a business associates agreement in place with these organizations, do not share information with them at all. 

Ira Pasternack: Right. Okay. Yep. Yeah. I was in my head. I was shifting to kind of what we can do kind of with the information on our 

Jenny Bristow: own end that you do do.

Yes, you’re correct on that. Yeah. 

Larry Earl, MD: Jenny, can you talk about the fact that many people who visit a provider’s website are not patients? They don’t have a, they don’t have a physician-patient relationship established. How does that play into 

Jenny Bristow: this? So it’s really interesting in the bulletin put out by health and human services.

They specifically say that this pertains to past, present and future. Future healthcare. So even if you have not received care from an organization, for example, I live in St. Louis, Missouri. I’m on hospital websites across the country on a daily basis, either because they’re my client, I want them to be my client, they’ve reached out with a question, et cetera.

I will never receive care from somebody in New Jersey. It doesn’t matter. If there’s a potential for future care, then my information needs to be treated as PHI. Interesting. And that is mindboggling. That is a fundamental shift from what we’ve done before. And that’s one of the one of the key language things that’s making it very difficult for people to wrap their heads around this new world of marketing data.

Ira Pasternack: So that I think feeds into the next question of well, and we I guess we can maybe come back to how some of the state laws may be complicating things even more, but let’s jump into the question for about how hospitals or other large organizations should address these changes and maybe talk a little bit about the debate or fight going on right now between the American Hospital Association and the Office of Civil Rights.

Yeah. Yeah. And sort of the contrary, the different perspectives on this and how that’s shaping 

Jenny Bristow: up. Yeah, I’m happy to. So the number one thing groups of any size need to do is they need to do an audit to understand what exists in your digital ecosystem and what tools and tactics you’re using. So what are you doing that is collecting?

Sorry, accessing, collecting and storing or sharing user information, and that could be anything from having YouTube embedded on your website to show a video because YouTube secretly collecting IP addresses on the back end that could be Facebook advertising that you’re doing, and maybe you’re doing a remarketing campaign, everything that you’re doing.

As far as digital tactics, you need to do an audit List all of them out and then understand how it’s collecting and storing information. This is really important because whenever we go in and do audits. We usually find 20 to 30 percent of our total findings, our technologies and tools that the head marketer at this organization didn’t even know they were using because an old agency partner may have hard coded something on their website.

A former employee may have implemented a form tool for the forms on the website that nobody knew who developed it or where it lived. So you may think. That you understand everything that’s going on, but you really need to get all hands on deck within your entire marketing and I. T. Teams and do a comprehensive audit.

Many groups have opted to bring in third parties view it more as a forensic audit. And so that’s what we do for large groups is go in and really comb through all of the code and make sure they fully understand what’s happening. But this is definitely a process you can and should begin internally, even if you choose not to bring in a partner.

Once you have that information that you need to prioritize it, And figure out what technology is most likely to result in a class action lawsuit, right? What are things that are going to really, like, put us out there as a group that is easy for folks to go after from a litigation perspective and immediately remove those tools.

There are a couple of different pathways of different marketing technologies and tools that have surfaced in the last year that allow you to keep doing the things that you want to do. But in a HIPAA compliant way, but you can’t move on to that until you know how your house is built right now, you know, you can’t do an addition to your house until you understand how your foundation is built.

So that’s the 1st step that you need to do. 

Ira Pasternack: Okay, and yeah, I don’t want to get too overly technical with this audience, but those steps that you can take that Jenny mentioned, there are some. Unfortunately, rather expensive. So these are currently only going to make sense if you’re a hospital and spending tens, if not hundreds of thousands of dollars on your marketing to begin with to justify the basically the layer that you can put between yourself and the Facebooks of the world.

And that if you create this layer in the, in the appropriate way, you can still leverage some of those Advertising tools. It’s just gotten a lot more expensive to do so. 

Jenny Bristow: Yeah, so there’s really three different pathways. You can switch the analytics tool you’re using completely. There are tools that are willing to sign a business associates agreement and really promise to hold your data safe and secure.

And then there’s the other two options or think of them as like a cloud that sits on top of your website and it filters out all of that information that is deemed scary or no longer compliant before it gets to those third party tools. A CDP customer data platform. pretty expensive still. But if you want to do some sophisticated marketing thinking like segmentation or personalization, that could be great for you because you’ll leverage it.

Otherwise, there’s something as simple as server side Google Tag Manager, relatively inexpensive to set up. We do it all day for people, relatively low annual costs, and it’s kind of the easy button to be able to continue doing even using Google Analytics. It will just go through that cloud to kind of parse out all the Noncompliant data, but you can continue on operations as normal.

Ira Pasternack: So when you’re with as your, I guess, sort of a four point question, 4. 5 here. Yeah, we’re talking about kind of the hospital for a larger organization that that within that has an occupational medicine department. Yep. Does the department need to do anything or do they just sort of depend on their hospital legal compliance or marketing departments to kind of figure this out and tell them what to do?

And kind of a related question here that came in in the chat is that we only market through constant contact and only to employer contacts. Not to the patient. So this is a case where a question tools, an email marketing tool just to communicate with the corporate accounts, not with the actual patients or exchanging, assuming they’re not exchanging patient data in any way that I would imagine you would agree is pretty safe, but then you can easily get into a gray area as you are thinking about the other things that that hospital department 

Jenny Bristow: might need to do.

You’re totally right. So a couple of things. First, if you are a department within a larger entity, do not assume they have it covered. They don’t have it covered. I’ll tell you with 99 percent certainty, we’re still talking to some of the largest systems across the country. They don’t have it covered.

Everybody’s still figuring this out. So I recommend being a leader within your entity and your organization. Begin Facilitating this conversation and asking what tools are we using? What are we doing within as an organization to stay up to date with all of these compliance issues? It’s not that you have to take on the burden of managing it and you know, owning the transfer to a more compliant ecosystem. But you need to have that conversation. Otherwise you are proactively choosing to be in the dark about it because I assure you your organization does not have it covered. Everybody is still confused about this. I mean, Ira, you can attest at the big health care conferences this fall. My group spoke at all of them.

We were standing room only people lined up around because people now are problem aware, but they’re not solution aware. They don’t know what to do to fix it yet. Yeah. And it’s relatively straightforward and simple, but they’re still fighting with their legal and compliance teams to implement changes.

And so that was the, the chatter at all of these healthcare conferences is what in the world is everybody doing to get there? I will say for groups and more of a, we think of it as like a B2B space. So Joanne, for your example, the constant contact, constant contact. for a B to B marketing play. If you look at just that in a silo, you’re fine.

But you have to zoom out and take a bigger picture. Maybe you’re only marketing to employer contacts. But is there information on your website where actual patients can go to learn more about your group? If so, you still have to view it as though you’re marketing to patients. Even if you’re marketing activities and dollars aren’t focused on that.

If you have information communicating to patients, on your site that they can access and find and engage with, then you need to still pay attention to all of these rules. 

Larry Earl, MD: You know, I also think about once the, once you become engaged with those employers, particularly, you know, go back to the NAOHP moment that we had earlier regarding onsite clinics, right?

If you’re, if you’re working with companies in an onsite clinic, you may well be communicating with patients in some form. At that clinic, who are going to your website for services, maybe it’s for you know, disease management or whatever you’re doing on the onsite clinic could be a number of different types of of services you’re providing there.

And yeah, you may have some communications directly with patients once you get to that level. 

Ira Pasternack: Yeah, my perspective on that. Since it’s where we spend a lot of our time is that you have the website, you’re going to always have patients going there. No matter what. There’s just no medical website, no matter how B to B.

It is that some patients are going to land there. I mean, and sure, you could come up with some random management company example, possibly or something like that. But that’s pretty rare. Yeah. When you’re talking about activities that you’re doing within your email marketing or within your CRM, you still have to make sure that those activities are compliant, but I think that it’s a lot easier to segment properly and you have a lot more flexibility with communicating directly one on one or in properly segmented groups when it comes to what you can do again via email or in a CRM.

Jenny Bristow: One thing I’d love to hop back on is question number three, because we didn’t, there’s so much more with state laws that we haven’t touched on yet. And this is where even B2B communications, state laws are really focused heavily on consent management. So, for example, you know, when you go to a website and that banner pops up, do you accept all cookies, accept some, accept none?

That flows through and is fully fully needs to be adhered to for B2B marketing purposes. State laws are more around just company and consumer communication. So whoever is buying or communicating with you, it doesn’t have to be the patient. And so. There are over a dozen state laws, and I think there’s six or seven that are coming online again are coming online in 2024.

So it’s constantly changing. So pay attention to your individual state and all of the surrounding states. If people travel to see you to pay attention to what you have to adhere to. I will say one tool that I absolutely love and we are not affiliates of them in any way. I just really admire the work they’re doing in the space.

It’s called Osano. They are a consent management platform that allows you to install their tool on your site, and then you can pick what you want people to consent to or not. So it really manages all of that cookie consent in a really streamlined way, and they have an amazing weekly newsletter.

I think it’s called the Privacy Insider you can sign up to, and it keeps you up to date on new state laws. As well as there are a couple of things, a couple of people pushing for national privacy laws, which we anticipate happening in the next two to three years. That will then make all most of the state laws a moot point.

But between now and then, we have to pay attention to them. So even if you’re just a B2B marketer, make sure that you’re paying attention. And I don’t mean just I love B2B marketing, but if you focus only on B2B marketing, that’s still an area you have to pay attention to. Right? 

Ira Pasternack: So again, that that’s where even if it’s not HIPAA, it might be the FTC or it might be state laws that are all involved with this and just to reinforce a point from kind of the, the previous session we had where we were, where we had an IT professional on talking about some overlapping issues on her podcast, she likes to say that, patient privacy is part of patient care. It is. And I may not that may not be the exact quote that they use, but ultimately that’s part of the caring and the empathy that we should have for patients is caring about their privacy to begin before they’re even a 

Jenny Bristow: person.

So one thing that you brought up, Ira, that I didn’t really touch on is the lawsuit. So American Hospital Association is suing Health and Human Services and the Office of Civil Rights saying that that bulletin was overreaching and they do not believe that hospital systems and providers should have to comply with the guidelines put forth in it.

It is Ridiculous. I actually filmed a podcast that was an open letter to American Hospital Association, basically saying shame on you because they need to be viewing patients as their number one priority. Yeah, you’re, you’re speaking on behalf of the hospitals, but this is an easy fix. There are technologies and procedures you can put in place to better protect patient information.

This is something we should have been doing years ago. After attendee list. I have my team go, there’s a website called built with dot com, enter the website URL, and it tells you all of the tools or most of the tools they’re running on their website, including third party pixels. This is how all the class actions are happening.

A very well known cancer provide services provider had a TikTok pixel on their home page and throughout their website. So that means if my child. Or somebody in my family has cancer and I’m going to find a specialist. TikTok knows that I’m trying to find a specialist, right? That is not okay. And so, yeah, maybe their bulletin was a little aggressive.

I don’t think they fully understand the technology and how it functions based off the language that they use. All of it across the board, whether it’s health and human services, FTC, or state laws, language is murky because people who legislate do not know how marketing and technology work. But the intent, I believe, is still in the best interest of the patient.

So the thing that we’ve been telling folks, whenever they come to us for a consultation or just to ask questions is, hey, will you be fined next month for doing these things? Maybe not. If you’re a smaller group, are you going to receive a multimillion-dollar fine in March? Maybe not, but do you want to have as part of your brand core values that you put patient privacy first, and that’s something that you hang your hat on?

It probably is. So even if you don’t think that you’re likely to be fined immediately, these are all things that you need to be moving towards as best practices, just because it’s in the best interest of your patients. 

Ira Pasternack: So it’s just another way of expressing that you do care about your patients. That’s a great way of putting it.

Patient is still 

Larry Earl, MD: job one, right? Exactly. Patient 

Ira Pasternack: is still job one. Yeah. All right, we only have a couple of minutes here. But do you have any and I kind of mentioned that if you’re a smaller practice, you probably aren’t going to be on anyone’s radar immediately. That said, what are some, what are the most important couple of things you would do if you were a small practice?

Beyond maybe going to built with dot com and seeing what you’re using now and making sure that you do have have done on some level that audit of knowing what technologies you’re using. What would you do next? 

Jenny Bristow: So if you’re a small group that does not have the budget or the interest in really doing lots of marketing initiatives that are patient or even B to B forward.

Maybe you have a business development team that has a lot of activities, but maybe you’re not. Spending lots of money online and digital advertising. My recommendation is to do two things, remove Google analytics and any analytics tools from your website. Completely, completely. If you’re not going to invest in a tracking correctly, certainly don’t invest by leaving it there and doing it incorrectly, because if you’re not spending lots of money on advertising, it’s not really giving you valuable information anyway, anyway, knowing the number of people that go to your website

Come on, that’s not changing what you’re doing on a day to day basis. So if you’re not going to implement it correctly, remove it. The other thing I’d say is in general, if you are going to continue doing marketing, you can still do Google and Facebook marketing. You can, but what you cannot do is two things.

Remarketing. So remarketing is a fun tactic where if somebody comes to your website, does not engage with whatever it is, schedule an appointment, whatever, and then leaves, you can serve them ads. Stop doing that immediately because in order to do remarketing, you’re having to tell that platform that that individual came to your website.

So stop doing remarketing and also stop doing something called lookalike audiences. That’s where the platform like meta says, Oh, this is the kind of person going to Jenny’s provider website. I’m going to serve her up more of these people in order for them to do that. They have to know who your customers are.

So those are the three things I’d stop doing immediately. And you’re going to remove a large percentage of your risk just by doing that. 

Ira Pasternack: And yeah, and with those lookalike Facebook to get rid of those, you basically just don’t need the meta pixel. Even if, even if you’re doing some kind of analytics, the Metapixel, there’s pretty much no reason any healthcare practice who Should have that should happen at this point.

Jenny Bristow: 

All third-party pixels should be deleted. And I’m sorry, let me finish one more thing, Larry. There have been a couple of groups we’ve done audits for, where their marketing teams or agencies have actually uploaded current customer lists to Facebook, so Facebook could target look alike similar audiences.

If you have ever had a pixel on your website, or if you’ve ever done this, go into the settings and delete that. From Facebook immediately, delete it from the meta advertising platform. So that way it’s gone. 

Larry Earl, MD: Yeah, I was just going to say, it doesn’t seem like even a BAA with any of those companies would override that type of activity, right?

Yeah, it doesn’t, it doesn’t even it doesn’t even help there. Well, we are at the half hour. What a fascinating discussion. Yeah. 

Ira Pasternack: Could be fun. Yeah, 

Larry Earl, MD: I want, I want to thank Jenny and Ira for this really interesting discussion. We can go on for several more hours, but we’re at time. So thanks to Jenny Bristow of Hedy and Hopp for a very interesting discussion.

And of course, the recording of this session will be posted later today. Thanks again, Ira, for helping moderate today. And again. Thanks to our sponsors for supporting NAOHP, TrestleTree, WebForDoctors, NetHealth, and Abbott. And we wish you all a very merry holiday season and a happy new year. This is one of our last episodes.

This might be our last town hall. Maybe we have one more, but, I think it’s the 

Ira Pasternack: last town hall, but we have a webinar on 

Larry Earl, MD: Yeah, we have a webinar, that’s right, 

Ira Pasternack: coming up. Thursday, setting up your Occ Med marketing and business development for 2024 coming up on Thursday. 

Larry Earl, MD: Absolutely. So we will see you there.

Thanks again, everyone. Have a great rest of your week. 

Jenny Bristow: Thank you.

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