Before ACCESS
Under ACCESS
Paid for
Before ACCESS
Activity — visits, calls, and billable services.
Under ACCESS
Clinical outcomes — blood pressure, weight, cholesterol, and related targets.
Reached through
Before ACCESS
The patient-physician relationship only.
Under ACCESS
Direct outreach to beneficiaries, who choose to enroll.
Withings' role
Before ACCESS
Technology vendor to providers.
Under ACCESS
Medicare Part B supplier delivering guideline-directed chronic care at home.
Executive Policy eBook
Companion guide to Episode 12 with Patrick Sheehan — outcomes payment, FDA-cleared RPM, and health system integration.
The Clinical Obligation
The Fiduciary Guardrail
Core Imperative
Mandate
Use data to heal: Failing to mobilize patient records carries direct morbidity and financial costs. Clinicians cannot coordinate what they cannot see across fragmented care boundaries.
Boundary
Protect patient trust: Unsanctioned secondary use or commercial data leakage destroys the public trust upon which voluntary care delivery depends. Without trust, patients withhold vital symptoms.
Governance Domain
Core Evaluation Question
Q1: Clinical Need
Problem Definition
What exact need is this product trying to serve — and do our operational and clinical leaders agree that we actually have this need?
Evaluation Standard
Reject features searching for a problem. If the frontline clinical workflow does not actively demand it, procurement stops immediately.
Q2: Comparative Value
Efficacy & ROI
Will it solve that need measurably better than the way our care teams solve it today?
Evaluation Standard
Software that adds clicks without reducing episode complications, replacing manual labor, or mitigating downside risk is a net negative.
Q3: Data Scope
Data Minimization
What exact data elements does the tool require — and is only that data in scope?
Evaluation Standard
Enforce purpose-bound minimization. Blanket requests for entire patient charts or retrospective enterprise dumps should be rejected.
Q4: Data Retention
Lifecycle Management
What are the retention and deletion policies governing that data once the episode or contract concludes?
Evaluation Standard
Contracts should specify strict timelines and verified certification of data purging upon episode completion or agreement termination.
Q5: Secondary Use
Model Training Covenants
How do we ensure data is not shared downstream or used to train commercial foundation models without explicit authorization?
Evaluation Standard
Standard Business Associate Agreements (BAAs) often do not address generative AI. Express non-training covenants are non-negotiable.
Q6: Model Drift
Oversight & Change Notice
How will our system be notified when the vendor's underlying model or software updates?
Evaluation Standard
SaaS vendors regularly deploy silent model updates. In clinical decision support or triage, silent model drift introduces catastrophic liability.
Q7: Ongoing Auditing
Monitoring & Bias Audits
How will we conduct continuous monitoring, bias audits, and adverse event reporting post-deployment?
Evaluation Standard
Governance does not end at procurement. Metrics for diagnostic accuracy, algorithmic fairness, and clinical impact should be reviewed regularly.
Q8: Cybersecurity Controls
Security Architecture
Are the vendor's cybersecurity controls, certifications, and incident response timelines enterprise-ready?
Evaluation Standard
SOC2 Type II, HITRUST certification, robust encryption at rest and in transit, and immediate breach disclosure obligations are mandatory table stakes.
Executive Policy eBook
Full executive transcript, governance frameworks, and care continuum models in PDF format.
Safety-net hospitals
Larger health systems
Financial cushion
Safety-net hospitals
Thin. Subsidies have not kept pace with labor and supply costs.
Larger health systems
Deeper reserves to absorb early losses.
TEAM risk track
Safety-net hospitals
May elect Track 2 in 2027–2030: 5% stop-gain and 5% stop-loss.
Larger health systems
Typically Track 3 from 2027: 20% stop-gain and 20% stop-loss.
Service overlap
Safety-net hospitals
More often collaborative, so nearby hospitals do not duplicate the same service line.
Larger health systems
More often competitive.
Timeline
Safety-net hospitals
Change has to be incremental, and it has to start now.
Larger health systems
More room to phase infrastructure investment.
Community partners
Safety-net hospitals
High value, and hard to formalize without a shared workflow.
Larger health systems
Often already have more formal referral networks.