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Welcome to this week in Health IT News, where we look at as many stories as we can in 23 minutes or less that's going to impact Health it. My name is Bill Russell Healthcare, CIO, coach and creator of this Week in Health. It a set of podcast videos and collaboration events. I. Designed to develop the next generation of health IT leaders.

It's Tuesday News Day, and there is a ton to talk about. We normally take the top 10 stories, break 'em down, I give you my take on it, and we go on to the next week. But today we're gonna look at one topic and one topic only. And that is Judy Faulkner, CEO of Epic, uh, her letter, uh, to the, uh, healthcare CEOs and presidents and the subsequent response to that letter.

So, should be interesting. Uh, buckle up. Here we go. This episode is sponsored by Health Lyrics. I coach healthcare leaders on all things health. It Coaching was instrumental in my success and it is the focus of my work at Health Lyrics. I've coached CEOs of health systems, uh, CIOs, startups, CTOs, you name it.

CEO is urging hospital customers to oppose rules that would make it easier to share medical information. CNBC. Think about that title alone. Epic, CEO. oppose rules to make it easier to share medical information. , I mean, it's sort of frames it in. The title itself doesn't, it sort of gets you going and uh, and there was a significant response to that.

And then there's some subsequent stories. We're gonna take a look at Twitter as well. Um. So, uh, you know, what did the letter say? What was the, what was in the letter that triggered such an interesting emotional and visceral response? Uh, here it is. Here's the letter. It's pretty, uh, pretty straightforward subject.

Your help needed on OC interoperability rules. Dear CEO slash President, O C's proposed rule would negatively, negatively affect patients and healthcare organizations. HHS needs to hear from you so they understand. That you, how you feel on these issues and that it is important. There's very little time left.

We are concerned that healthcare costs will rise, that care will suffer, and that patients and their family members will lose control of their confidential health information. Please review the attached information and if you agree with these concerns, join other healthcare CEOs and signing the attached letter to HHS Secretary Alex Azar, and a copy to director of domestic policy.

With other health systems and was developed years before meaningful use required interoperability, epic interoperates with thousands of third party products and apps. Let's prevent the unintended consequences of this rule and make sure that the final rule is a good one that is modified to help not harm healthcare organizations and patients ONC may finalize the rule in the first week of February, so we must get the message to them right away.

Thanks for your help in this very important matter. . Okay. . That's the letter. Let's take a look at the twi, the Twitter response real quick. Uh, and, and, and I'm, I'm, to be honest with you, I'm just pulling people that, you know, not just run in the mill. I'm pulling some, uh, pretty credible people here. So, Daniel Craft MD been on the show before, uh, singularity University.

Has two words for this letter. Epic Fail. John Chamberlain, board Chair for Citizen Health. Epic, CEO. Judy Faulkner says that patient privacy will be negatively impacted. Oh, really? Like it's not already. What is Epic's annual revenue from selling de-identified patient data? Not sure about this one. Not sure that's the direction I would've gone with that one, John, but, uh, to be honest with you,

Uh, you know, they're worried about patient data. I would've gone in the direction of number of reaches you go in this direction, and I, I'm not sure this direction's accurate. Uh, in, in, in, uh, the book, um, our Bodies Are Data. Adam Tanner actually interviewed Judy Faulkner, and this is what was said. This is like two years ago.

By contrast, Judy Faulkner, the founder of Epic. Which does not share data. Said she was uneasy about the commercial use of her anonymized information. I would feel fairly uncomfortable about that. Faulkner does believe that scientists should have access to anonymized data to advance medi medicine without patient consent.

But if the data are used for sales and marketing, she thinks patients should be able to call the shots personal. Personally, if there is for legitimate research, purs purposes, I would like to see all data accessible. She said anything other than that I think is fine if the patient has a say over it. Um.

You know, so I'm not sure that Epic is making a ton of money. I mean, it's private company, so we don't know, uh, I don't think they are making a ton of money from selling de-identified data. I, again, I could be wrong on that. I know that Cosmos was designed to pull all that data together for research purposes.

I'm not sure, uh, the flow of money in that whole transaction. I could do a little research and get back on that, but, . Uh, again, not the direction I've gone, I've, I would've gone in the brief direction, not in the, uh, selling of data. I'm not sure that's accurate. Uh, but I do share it to give you an idea of just the, it, it, it was a, this was a dog whistle.

It seems, uh, seems like he's just pulling that out. Matthew Holt Health 2.0 fame says this. Judy is genuinely earnestly worried about data being resold. I heard her directly tell Kaiser Permanente that HealthVault would sell their data and should not be trusted if she is, if , if she was merely self-protecting.

Why would she release such a dumb letter? And uh, I, you know, I think that's fascinating that he said dumb letter. Um, and I think Matt would want me to share the next section where he describes why he thinks it's a dumb letter. Uh, I call this a dumb letter because it's a rear guard action, which, uh, wouldn't actually impact her business.

Epic has an API app store, you fire APIs and patient third party access. Two data was freely available, uh, it would still come from the Epic platform and they'd still make money. Uh, so a couple things. First, first quote, I absolutely agree with, I actually sat at a table where Judy was making this case pretty passionately, and I believe she really, truly does care about patient privacy and, uh, that would not be out of character.

Uh, to believe that the, um, uh, although I do understand the other people who believe that they're, you know, just creating a deeper and wider moat, uh, around their Epic platform so that they keep the competition out. I understand how you can get there. Uh, the second thing, uh, I'm, I'm, you know, I think if I read the intention of the ONC, um.

Proposal and the rules, it is that Epic would not make money from access to that data. So there I'm I again, I'm not sure that I agree with the second one because I think the intention is for data to be accessible via a fire, API. And freely accessible to developers to make that, make that happen. Uh, Greg Matthews, founder and principal of Health Quant, uh, the thing I've never understood is why hospitals keep buying Epic.

Everyone knows that their entire business is built to hoard and control data. Are the hospitals more complicit in this than we, uh, then we seem to be willing to admit. Again, just giving you public sentiment on this Bray Patrick Lake, director of Strategic Partner Partnerships with Evidation. If you don't know who they are, this is what the statement says.

Our mission is to empower everyone to participate in better health outcomes. So this is a patient advocate group. Uh, please keep us updated on the hospitals that support Epic's position. Patients deserve to know. Patients deserve to know. Interesting sounds like, uh, they're willing to hold. The health system leader accountable who signed this, uh, on the healthcare blog, grace, uh, cor Cono, PhD.

Uh, another patient advocate wrote this letter to Ms. Judy Faulkner and Mr. Tommy Thompson. And I apologize, I'm just reading a lot of stuff 'cause there's just an awful lot of stuff that, that got released. Uh, and so this is a patient advocate that was wondering if her work was worth it. And I'm gonna skip a bunch and just get to I think the meat of it.

So after 20 years of advocacy work, when I closed my eyes and . Reflect, I cannot unsee and unhear what I've seen. The people that have died horrible deaths because of cancer with not a spot of dignity left the parents who fought tirelessly to find hope for a cure or a gift of more time with their dying child.

The people who have watched as their parents and grandparents died sometimes slowly unfathomable deaths from their heart failure, dementia, cancer, diabetes, and other comorbidities. And I have to note that this. This is literally the title for this is, um, you know, a, a, a letter or Yeah, a letter to Ms.

Faulkner and Mr. Tommy Thompson. Okay. So it's directly to them. The people who struggle with their own cancer diagnosis while caring for their aging sick parents and their also disabled and medically complex children. The people who were. Disabled who have not, who have been denied critical care that they needed the people living with chronic illnesses.

Uh, the tears streamed down my face as I recall the hundreds of thousands of pleas I've been faced with over the last 20 years. Please, stories, cries, uh, for help that break one's soul and leave you gutted. There is a common denominator here. These people could not get access to their information they needed for the next step in their or their loved one's care information.

They needed to schedule a second and third opinion appointment to organize a tumor board to consider clinical trials, to ask the right questions, to pick the right doctor or hospital to. Fight an insurance denial to do a peer-to-peer or expedited care, needed themselves to make informal decisions about an upcoming surgery or procedure to prevent medical error from happening.

To fight an exorbitant medical bill to understand their diagnosis. And treatment enough to know it wasn't too early for palliative care, to know that it was time for hospice to know that it was time for hospice. This is what information blocking looks like. Boots on the ground, then it goes on. Thank you for Ms.

Judy Faulkner. Thank you, Ms. Judy Faulkner, CEO of Epic for your recent letter. Urging some of that biggest hospital CEOs and presidents to oppose the proposed rules to improve interoperability and grant patient access to their information. You have made it crystal clear that you are not aligned with the real world unmet needs and barriers patients and care partners face daily.

Thank you for helping me refocus. Thank you for helping me answer the question and address the self-imposed imposter syndrome that can momentarily cloud one's perception. The answer is it's all worth. It says a patient advocate. Wow. Uh, following up from that Amy Gleason calling on all patient advocates.

Anyone interested in signing a patient caregiver letter to count, count, uh, counter the epic letter. I would like to have one. That is only patients, caregivers to tell our side of the story. Okay. So that's just overwhelmingly the response. Uh, , you know, one last tweet here. This is from a physician who's been on the show who I greatly respect, uh, Lee Milligan, um, and, uh, at Asante Health, he stood, stood in the gap.

A lot of stuff going in that direction. And he says it's important to read the proposed legislation before lambasting the obvious target of Epic, CEO, Judy Faulkner, uh, Chrissy, far protecting patient. PHI is not tertiary construct, but a legal and moral obligation. Interoperability requires universal standards and agreement on usage, and I think it's important here because I, I agree with Lee here, and he stood in the gap.

And, you know, again, I, I think it's important to understand the, the what CMS is proposing. So that's where we're gonna go next, and that's what we're gonna dive into. What a potential limitation of what they're proposing for right now. And then, you know, determine what the right approach is to actually going about this.

'cause um, you know, he, he's not wrong and they're definitely not wrong. We need to get the patient . The data that they need to be empowered in a digital economy where they can make decisions, they can engage people to help them in their care. Uh, and, and so that's, that sort of frames up the two sides of it.

Uh, we also did a whole episode on interoperability. You can check that out as well. Uh, here's what administrators Cima Verma said in this, uh, in this, uh, frequently, uh, asked questions type thing, far too long, electronic health information that's been stuck in silos and inaccessible for healthcare consumers said CMS administrators, seima Verma.

Our proposals help break down existing barriers to important data exchanges needed to empower patients by giving them access to their health data. Touching all aspects of healthcare from patients to providers, to payers and researchers. Our work leverages identified technology and standards to spark new opportunities for industry and researchers while improving healthcare quality for all Americans.

We ask that members of the healthcare system join forces to provide patients with safe, secure access to the control over their healthcare data. Okay, here are the proposed changes. Number one, patient access through APIs, applica, which are application pro programming interfaces. This is how innovators and Silicon Valley types get access to the patient data, uh, health information exchange and care coordination across payers.

Um, so they start to include payers in this whole mix, which is an important data set that in some cases goes untapped. Uh, at, at least you don't bring these two together very easily. Uh, API access to publish provider data, uh, provider directory data. Again, another important data set care coordination through Trusted Exchange Framework.

Improving the dual eligible experience by increasing frequency of federal, state data exchanges, uh, public reporting and prevention of information blocking provider digital contact information. Revisions to conditions of participation for hospitals and critical access hospitals and advancing interoperability in innovation models.

Okay. Uh, you can review these things on the CMS site, or you can listen to the whole podcast episode I did on interoperability last year. I go into this in some detail. Um. You know, the question isn't really what both sides are trying to position themselves as advocates for the patient. We, um, you know, both want to say, look, we want that information to be shared.

We want empowered, digitally empowered patients. That's absolutely what we want. The question comes down to how, um, and if you were to pull people in healthcare today and say, what is epic? You, you should try this sometime. What is epic strategy? For interoperability, most would say to you, epic strategy for interoperability is to have everybody on Epic.

If you, you know, go into a market and you say, well, we wanna make, you know, Cerner and Epic talk together, they'll say, well, the easiest way to do that is to replace Cerner. Or, you know, we want this to work. Well get them on Connect or, um, community connect. I mean, so you get the, the picture that most people would say.

That's what it feels like is their strategy. So, you know, how is, how is uh, what, what Epic is doing with Apple Orchard different from say, apple and their, you know, 'cause Apple has an API interface and they have an app store. That's what App Orchard was really set up to do to promote interoperability. Um, you know, again, what's interesting is both sides would agree that these APIs and app stores is a great approach.

Uh, to empowering the developer community. However, you know, one side really charges a tax while the other really doesn't want any tax to be charged for that data. And oddly enough, the one that does not wanna charge a tax for their access to the health data is the federal government. So, very interesting.

I'm very happy with the changes, said Rick Freeman, CEO of Interop. Whose complaint earlier this year about exorbitant prices for participation in vendor app stores as reported by Politico, may have helped spur the action. Freeman noted at the time that the Family Planning Questionnaire app he developed for HHS Office of Population Health could have cost him up to $750,000 to run on Epic or Cerner for a year.

Epic will charge lower fees for most of the 350 companies that participate in the app development program. Said App Orchard Director Brett GaN. It will enable early stage startups to enroll in the program with access to Epic's public API documentation and sandboxes $400 per year until the apps are ready to be commercially used.

Alright? So all those things are very welcome changes, right? So, . Uh, we reduced the tax for, uh, developers to get access to the data, and we also, uh, reduced the, the bar for entry. So you had a lot of org, a lot of, uh, startups that were, didn't have a huge revenue stream that were trying to develop new apps and they could not pay whatever the fees were that, uh, epic was going to charge them.

And they created a, uh, much easier barrier of entry this a hundred dollars per year until they're ready to be commercial. So is that the only tax? Well, it, it turns out there, there's a, there's a lot of challenges with having a, uh, company run. App store, right? We see this with Apple from time to time and you know, they changed their terms or, or YouTube, you know, they changed their terms and now all of a sudden the YouTube developers or the people who create content have to scramble or the, uh, you know, apple will change their fees and all of a sudden these, uh, developers have to pay more.

Uh, now Apple's smart enough and Google sometimes is smart enough, uh, to be consumer focused. And 'cause they're consumer focused, they do what's in the best interest of the consumer and that's . Really what, uh, what these EHR providers are trying to portray here, that they're doing what's in the best interest of the consumers.

However, you just, you have to look a little more closely. So, uh, you know, it turns out there isn't much in the way of negotiation on the terms and conditions, which, uh, you know, which. Also puts something on top of the developers. There's also, uh, challenges with how intellectual property is handled through a lot of these app stores.

And, you know, the developers have to weigh being a part of these app stores because they're giving away some access to their intellectual property. Um, and when you think about it, there, there is no other choice. We could say that, Hey, these developers don't have to do this. No, they do. If they wanna play in this, they have to, if, if they, they have to get access to the data and they have to get back into the workflow.

if they have to get access to the data and back in the workflow, there's only one path to do that. You have to go through the EHR provider because that's what the health systems have put in place as the interface to get to the doctors and an interface to get to the, to the data. So they have to go through that, and it creates a situation like we had back in the day and back in the day.

Um, this is gonna date me a little bit. But there used to be this old shading that, uh, MSDOS isn't done until Lotus won't run. So Lotus was the predominant spreadsheet back in the day. And, uh, Microsoft had, you know, they were trying to really push Excel and they had sort of these two platforms and they would, as the saying goes, MSDOS wasn't finished until Lotus was broken.

So they would roll out Msdos, which ran every computer. Known to man. And so if you were running Lotus, whatever version you had stopped working and Lotus would have to sprint and scramble to rewrite the code, uh, to get it to work. So they were constantly patching. Well over time Microsoft hobbled Lotus so much that many of our listeners have never even heard of Lotus, right?

So there is that sort of concern. Of having a, a, uh, privately owned gateway to health information that, uh, no, that you hear, uh, you hear, uh, patient advocates complaining about, and you hear, uh, you hear developers complaining about if you talk to 'em enough. So with some prompting from Big Tech, let's be honest here.

The federal government has been prompted from big tech, you know, the, uh, the apples, the Amazons, the Googles of the world, and Microsofts to say, Hey, if we free up this health data, we could do some things with it, which is kind of ironic and interesting. Um. , but the ONC is proposing a plan to, to free the data from its silos and to share that data through a set of APIs and, and security.

And, um, and hopefully what will happen is you'll have the, uh, innovation really to explode in a lot of different ways to make new ways of. Uh, receiving care and delivering care possible. So no taxation, just looking out for the best interest of the patient. Um, you know, what's wrong with that? What could possibly go wrong?

And this Amy, uh, leopard. Bradley Arant Bolt and Cummings. I covered this also when it came out. Uh, you know, talks about some of the unintended consequences and, you know, I'll, I'll spare you the, the long version of the story. Uh, but essentially what it is, is, um, the, uh, the verbiage was really unclear in the 21st Century Cures Act.

And because it, it was unclear the, uh, burden went to the health systems to deny access to certain data. Right? And so if they were gonna deny access to certain data, they would have to, they would have to document that and to present a case as to why they were blocking that data. And, uh, and there could be some really good reasons for blocking that data.

I know what you're thinking. Healthcare IT news. Aren't they owned by hims? And doesn't Epic have the largest booth in every year at himss? Um, sure. But let's, let's consider another scenario and I'll create this one. And I have no money coming to me from, from Epic. So, uh, let's assume, I was gonna say a nation state, but nation state doesn't make sense here.

Let's assume a crime family. 'cause crime families, . Are in the cybersecurity, uh, hacking business, right? So let's assume crime family wants to write an app that provides significant value to the healthcare community. Um, and they put it out on the iOS app store or Google Play, and my parents download the app of this nefarious actor, okay?

They receive real value in some way because these crime families aren't stupid. They know. In order for people to download their app, in order for millions of people to download their app, they have to provide some value. So they hire some people who write a really good app. I don't care what it does, it does something really cool that other apps don't do or don't do as well.

So my parents download it. The crime family, of course, has access to. Access to all sorts of information that will make it easier for 'em to steal their identity or utilize it for whatever purpose they want. Okay? So that's a very real possibility unless we close those gaps and make the rule crystal clear as to, um, you know, how people get certified to access that data, what data they actually have access to, how often that has to be audited.

Uh, you know, all those things need to be put in place. So, you know, and when you prompt e even advocates of the federal plan, they say that there's some details left to work out. So what am I saying? Um, you know, am I saying we need to have a trusted gatekeeper, uh, for that information and that gatekeeper needs to be the EHR provider?

Uh, not necessarily, to be honest with you. Uh, I'm, I'm saying we need to define the problem that we want to solve. And solve for that problem. You know, the government's vision is, um, empowered to inform patients with choice, a free market economy. In healthcare, a digitally empowered patient has access to, uh, the medical record and can share it with whomever they choose.

Uh, they can choose to, uh, get the record and, uh, you know. They can have it looked at by their PCP or they can have it looked at, quite frankly, by the, the person next door they could put it up on their Apple TV and have somebody look at it and go, Hey, you know, I know somebody else with that. Um, that's really the nature of empowerment.

It's up to the consumer to determine who looks at it and is believed. You know that if every patient have has access to their own record, uh, you know it's gonna create this market . Of vendors who will be willing to step in and provide second opinions and care navigation and digital solutions, uh, around the medical record.

Um, those can be big players like Google, Amazon, and Apple, but it could also be small players so that, you know, the epic vision is really empowered and forward and protected patients. Right? And the key that they're trying to drive home right now is, uh, the protection. Uh, you know, does come with cost. You know, you have to have somebody that really caress about the, the patient and the privacy of their data, which in this case is the EHR provider.

But it comes at a cost and you have to trust the protector, first of all. Uh, and somebody has to pay the toll 'cause there's a cost to keeping these things going. Um, the benefits is that you live in a walled garden and you have access to, well-orchestrated care experiences with the highest quality possible, right?

We want those things. So you have these two competing things, and to a certain extent, I'm torn, uh, in that, um, you know, I do not want my parents' data. I, I, I'm, I'm scared for my parents to have access to their data. I know the number of phone calls they get a day being asked for their social security number and those kind of things.

This is a very real threat that needs to be addressed in the rules that CMS is Provo, uh, proposing here. Uh, on the other hand, uh, I don't want people to not have access to their complete longitudinal patient record when they need it most, right? And so since I'm torn, . I'm gonna tell both sides here. I'm gonna, actually, I'm gonna go in three directions here.

I'm gonna talk about what the health system should do. I'm gonna talk about what ethics should do, and I'm gonna talk about what the, um, uh, what the government should do. And you may or may not like this, but it, 'cause I'm gonna really, I'm, I'm, I'm gonna act as an arms dealer here and provide both sides with, with a, a direction they should really take this.

So the first thing is for the health systems. This is a heavyweight fight. This is Ali Frazier. Sorry I'm dating myself again. Um. , there are gonna be punches thrown that would fell the normal average man, I wouldn't get in the middle of this one. Uh, you know, it's an election year. The optics on this are horrible.

Uh, yes, it protects the patients, but, uh, you know, neither side has made their case to the American people. Uh, this will become a political issue. Trust me, this will become a political issue. Uh, Judy has all but assured with this letter in an election year. This will become a political issue. Um, and it, it's really unclear how this is gonna play out.

But, um, if it's like other issues that are playing out in the, in, in our, in our country right now, it'll be split like 50 50. And if it's split 50 50, that means 50% of your consumers are gonna be happy you took your side. If 50% are gonna be unhappy, you took your side. Um. So I I, my recommendation, if I were talking to my CEO, who's saying, should I sign this letter?

My recommendation would be no. Uh, just stay out of the fight. So let's talk, let's talk about, uh, epic and Judy. You know, there's, there's, uh, I'm gonna give three problems that they have and a proposed strategy around it. So the three problems are, the timing is awful. This is an election year. It's just an awful time to be bringing this up.

You just made it an election issue. If, if it's handled in a, a certain way, um, the strategy is Ill-advised. I, as I, I shared right after UGM, that the, uh, you, you shouldn't pick the government as your adversary . It's just a bad strategy. And, uh, the second, uh, the third thing is you haven't built a complete coalition at this point.

Um, you haven't won the hearts and minds of the American people. They have no, when I say community C, they have no idea. When I say care everywhere, they have no idea what these things are or what they do for them. So you haven't built a complete coalition. Health systems might understand what we're talking about in that case, but patients do not.

So, you know, if, if, if Judy were listening to the podcast, she would know I strongly recommended that. Um, I. You know, companies that pick fights with the US government do not fare very well. Uh, she can watch, um, in the mind of Bill Gates, I think it's called in the mind of Bill Gates or the Mind of Bill Gates, the Netflix special.

And actually I highly recommend it. It's really fascinating, uh, the transformation he's made and it really covers the work at the Bill and Melinda Gates Foundation, uh, documentary on Netflix. Um, . You know, in, in addition to the companies, the, the business leaders don't fare really well in these bouts either with the federal government, it takes up a lot of time, energy, uh, it's, it SAPs you because it plays out differently than you think.

The soundbites that are, are taken are a lot of times taken outta context. Um, you know, so a, again, I would not have recommended picking this fight, but cat's outta the bag, you pick the fight, so. Um, you know, this is really gonna play out in two camps. First camp is, it's the right thing to do to protect the patient, right?

So it's altruistic, but let's make sure at all costs protect the patient. And then the other is, this is an epic moat strategy. So self-serving monopolistic and the two camps will sort of form around this. Uh, so if you wanna win on the hill, what you have to do is provide cover for elected officials. You have to create a narrative that the American people.

Are behind. And right now no one owns this narrative at the patient level. They just don't, most patients have, have no idea this fight is even going on yet. And but once they do, they'll have to decide based on the information that's in front of them, and nobody has made this case to the patient and to the American people.

My recommendation to Epic is a massive targeted marketing campaign in partnership with your . Uh, with your clients, right? So go into those major markets with your health systems, even joint marketing dollars, and start telling your story and, uh, you know, why is Epic's plan better for patients? Uh, you know, my mom texted me last night.

I wish I had this text. My mom tested, texted me last night, Hey, it turns out I can go anywhere in the country with my patient record. She's a patient at, uh. At a health system that's an epic health system, and she goes, it turns out I can go anywhere in the country and my medical record follows. Follows me.

Right. So that's the narrative that she's heard and that's the kind of thing that you need to happen, uh, exponentially. You need everybody's mom texting them saying, Hey, I can now go anywhere with this record. Now, I didn't have the heart to tell my mom it's not true. Um, she can go anywhere that has epic.

So when she goes to Florida for vacation, she's gonna have to find an epic shop to go visit as opposed to wherever the ambulance happened to take her anyway. Um. Which isn't entirely true with the Care Everywhere platform. You get a one time use, but you can't bring that data down. Anyway, long story, I'm getting into the weeds, so that's what Epic should do.

My recommendation, massive targeted marketing campaign across the us You have to, you have to win this narrative government. This is for Secretary Azar, Sima, Verma and Company. Uh, you have to fix the perceived security and privacy. Questions that people are having around this. Uh, this is far and away the most popular approach to solving.

This is what you are proposing. This is, uh, easy to understand, easy to get out there, and easy narrative to win. But you have to, you have to plug that gap. So start there. Number two, you have to seize the high ground that was just gifted to you by Judy. Judy picked a bad year to do this. Um. She picked a bad enemy to fight in the federal government.

A lot of money, a lot of lawyers, bad enemy to fight. So seize the high ground. And you know, there's, there's, um, so seize the high ground is the second thing. The third thing is, uh, and this is like just a last ditch effort, and I'm not even sure I, I like even saying this, but consider trust busting.

Seriously trespassing the EHR providers for the good of the patient. From this perspective, I would split them at the point that makes them incentive to love interoperability. So you take Epic's business of the EHR and you split that from any ancillary applications that use that data. So Cosmos now becomes a separate company and App Orchard becomes a separate company and whatever.

So, uh, anything that Epic's thinking of doing on top of that data has to become a separate company. Same thing with Cerner, separate company. Um, so, you know, healthy intent separate company so that they are incented and anytime they give access to Healthy Intent or, or Cosmos or anybody else, they have to provide those same set of APIs to every organization in the country.

Right. So that's where I would split them. I would split them at the point. That makes them incented to love interoperability, and to build out the connections that the community would benefit from. Um.

So why, why this strategy? You know, the first thing is you're not gonna look good if you don't protect my parents. And I can't support you if you're not gonna protect my parents, uh, in their health record, let alone my kids in their health record. Uh, number two, um, same message I just gave . Epic and Judy, which is, uh, if you're taking the message to the patients, you have to win the hearts and minds of the people.

Um, and if you do, you win the war. Whoever wins the hearts and minds of the people who frames this debate with the people wins. Uh. And, you know, you have a very populous president who somehow connects with, uh, tons of people through Twitter. And, uh, you know, I would take advantage of everything, every aspect you have.

'cause you're not gonna do some massive marketing campaign in every city. But you do have, you do have the bully pulpit on this one. So, uh, you know. . Gain the messaging high ground. And then the last thing is, again, I hate the concept of trust Bussing, uh, but there comes a time where you have to use every tool in your bag to protect, uh, the health of the American people.

And if you firmly believe, which I've heard SEMA Verma now speak in public, I. Uh, many times and, and several times, I've, I've sat pretty close in the front row and I believe she firmly believes this, um, that this data siloing is hurting patients and holding progress back. Uh, then you have to consider every tool in your bag.

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