Telemedicine Talks

#88 - California’s New Telehealth Rules: CPOM, PE Deals & Compliance Reality with Shayln Watkins

Episode Summary

In this episode of Telemedicine Talks, hosts Dr. Leo Damasco and Phoebe Gutierrez sit down with Shaylin Watkins as they unpack California’s newly finalized transaction-reporting regulations, the tightening corporate practice of medicine (CPOM) landscape, private equity scrutiny, and the operational compliance gap that is about to hit digital-health and telemedicine companies hard.

Episode Notes

Is California About To Block Your Next Investment and Shut Down Your Telemedicine Company?

Hosts Dr. Leo Damasco and Phoebe Gutierrez welcome Shayln Watkins, as they dig into California’s newly released implementing regulations from the Office of Health Care Affordability (effective mid-September), the 90 day pre transaction notice requirement for deals over $25 million, the 10 year look back for serial transactions, and how these rules intersect with California’s recent CPOM statute and ongoing AG enforcement.

Shayln and the hosts explain the difference between statutes and regulations, why private equity investment in healthcare is under the microscope, and why most telemedicine and digital health startups still lack real compliance operations. They discuss the practical fallout for cash pay wellness, GLP-1, and peptide models; the dangers of “my lawyer cleared it”; and the critical roles of physician owners, medical directors, and inhouse compliance teams.

Top 3 Takeaways:

 

About the Show:


Telemedicine Talks explores the evolving world of digital health, helping physicians navigate new opportunities, regulatory challenges, and career transitions in telemedicine

About the Guest:

Shayln Watkins is Senior Counsel at Holland & Knight LLP. She advises physicians, medical groups, digital health companies, telehealth platforms, wellness and aesthetics clinics, and behavioral health providers on healthcare regulatory compliance, corporate practice of medicine, Stark and anti kickback matters, California privacy law, fraud and abuse, and the evolving framework for virtual and AI driven care. She is licensed in Alabama, California, New York, Ohio, and Texas and is a member of the American Health Lawyers Association.

Connect with Shayln Watkins:
Email :
shayln.watkins@hklaw.com

About the Hosts:

Dr. Leo Damasco – Pediatrician and emergency medicine doctor turned telemedicine advocate, helping physicians transition to digital health.

Phoebe Gutierrez – Former state regulator turned telehealth executive, specializing in compliance and sustainable virtual care models.  

Connect with Phoebe Gutierrez:   
https://www.linkedIn.com/in/pkgutierrez/
  
phoebe@telemedicinetalks.com 
(
mailto:phoebe@telemedicinetalks.com)


 

Episode Transcription

 

 [00:00:00] Hey, welcome back everybody to Telemedicine Talks. It's nice to have you here. As always, we have your host, Phoebe Gutierrez, and myself, Leo Damasco, and I'm excited to introduce our host today Shaylin Watkins. She's a senior counsel at Holland & Knight LLP, one of the nation's leading law firms, where she focuses on healthcare regulatory compliance, digital health, telehealth, innovative medicine including aesthetics and wellness, HIPAA and privacy, and healthcare transactions.

She's based in Southern California, and she advises a wide range of clients, including physicians, medical groups, digital health companies, telehealth platforms, wellness and aesthetics clinic, and behavioral health providers across the country. Her practice covers corporate practice medicine compliance, Stark Law and anti-kickback matters, California Medical Information Act, healthcare fraud and abuse, and the evolving regulatory framework shaping virtual and AI-driven care delivery.

She is also a member of the American Health Lawyers Association, and is a published author on topics including HIPAA [00:01:00] rule changes, private equity in medicine, and California CPOM compliance. She graduated from the University of Alabama School of Law, and is licensed Alabama, California, New York, Ohio, and Texas.

So Shaylin, welcome. Thank you for, hanging out with us today. 

No, thanks for having me. I'm really excited to talk to you. 

Well, Me and Shaylin geek out over this stuff, so I'm, again, one-excited to have an episode where it's something I understand versus, the doctor speak that we always have to deal with.

 So, everybody knows we talk about it, right? We kinda talk about, the episode before we actually record the episode, and honestly, y'all were geeking out about this lawyer stuff . But, it was interesting, 'cause, you know, this is up and coming.

Definitely relatable to what's going on today, what we're doing, what I'm doing, and I didn't know you did aesthetics too. I need to talk to you about that. Anywho, as an aside. But no, I'm definitely excited about this episode, 'cause yeah, there's a lot of things up and coming that we need to know about.[00:02:00] 

So Yeah. go for it. 

Well, and I think you have to have people in the room too, right? Because you can have an idea, the doctor has no idea how to make the idea work, and then I have no idea how to practice medicine. So, like between the three of us, we can make a good idea, because after I give the idea some legal constraints, then you need like a Phoebe to be like, "And this is how you make those words make sense to everybody else."

Oh, absolutely. That's key. Yeah. Yeah. Phoebe runs the show. 

Oh, gosh. Well, no, I think it's interesting and I think it's a great time to have Shailen on the podcast. Specifically, you know, we got in contact mainly around all the, I mean, I wanna call it like an evolution in California.

I've said it multiple times that California's always the state that leads the way. And it takes regulators about three years to figure out how the hell they want to enforce a lot of these rules that they're technically like putting in law. And California, I think, almost like to the [00:03:00] day, it's been three years of really saying, "No, we've kind of figured out how we're gonna start enforcing this."

And Shailen and I started talking about some of the litigation lawsuits that were, coming out in California. And so today we wanna focus a little bit on, you know, some of the emerging things that are, you know, happening in the regulatory space that are not yet finalized, but are gonna be finalized really soon, and are actually gonna be impacting just about every single telemedicine company that operates in all 50 states.

 also I think it's importantfor our listeners to understand the regulatory process, because a lot of people don't pay attention to it until it's too late, and I think that we're gonna have a lot of startups struggling here in the next year to keep their doors open and stay afloat if they're not paying attention to some of this stuff.

So Shaylin, I know that you have been tracking some of the newest, you know, kinds of things specifically in, California, but maybe give us a [00:04:00] rundown of kinda like what you're seeing and hearing from startups as well as, the regulatory landscape. 

Yeah. When I talk to digital health and telemedicine startups, most of the time the client is really just thinking about how to make their really good idea work for everyone.

And they're like: "If I have a constraint in a specific state, you can just let me know." That's like, the chillest conversation you can ever have. That's how it starts, and then it's like: "I'm sorry, you've been doing what? And you're in California?" That's always my response. And so I think part of the understanding of like the underlying regulatory landscape is really the fact that like most people don't realize that regulations are coming into effect, that there's something happening behind the scenes, and regulations and statutes, What's the difference, Shaylin? You know, what do I actually have to do? Specifically for these 50-state telemedicine companies, a lot of them are either [00:05:00] already being acquired by private equity or they're in the process of getting themselves there. And a lot of states, including the federal government, have really come out considering like, what in the world is this private equity investment in healthcare?

We don't love it. And because of that, you see the federal government's acting in its own way. It's starting to come up with some, its guideposts and guidelines, but then each state is also singularly attacking it. In California, as you noted, Phoebe is leading the way here. There's two like big frames of reference.

Everybody kind of talks about the corporate practice of medicine, which you and I have been geeking ab- out about, but then there's also individual states that have been having these pre-transaction notification laws. in California most recently not only did it have some statutes that were finalized and signed by the governor and went into effectiveness at the beginning of this year, but then now the implementing [00:06:00] regulations for the Office of Healthcare Affordability and Accountability have finally come out as of literally last Friday, September 12th.

 or September 11th. so it's kind of like this boom that's occurring where all these new things exist. No one really knows what they mean. I think one thing that would be really interesting for listeners is to kind of first talk about what it means for a regulation to come into existence, because I think there's also the catch-up period that operators need to be thinking about what really matters to the founders.

And then we can just kind of talk a little bit more about the specific regs and what they mean. 

Yeah. No, I think that's a really important point. I don't think too many people understand the whole process. I heard a lot of, Leo, in our circle when the DEA regulations, you know, were proposed finally, a lot of people in our circle are like, "This is never gonna happen."

And I'm like Once it's in [00:07:00] draft, usually they might strike a couple things and re-jig a couple things, but for the most part, in about a year, 18 months, that is gonna be signed into law, and then you really don't have much that you can do there. Yeah. And so when I was a regulator, we would dread, they're called final rules, and they're usually these, I don't know, 1,000 to 3,000-page documents that basically lay out all these new rules and regulations that the states actually have to comply with.

And so it starts at the federal government, they go down to states. States get to take that, and you go, "What are the policies that we're gonna put into place?" And my brain was always like, "How am I gonna enforce these policies? I have to demonstrate to the federal government that I am overseeing you guys and making sure you're doing what you're supposed to do, so I also need in place to track and monitor and ensure," and that's where, like, the policy folks would come in, and that was kind of my big thing is I oversaw that and the corrective action process for all the people who didn't [00:08:00] wanna listen to the policies.

And 99% of the time, the first year they didn't. and there's not a lot of wiggle room when something is set into law. And so California's coming out and saying, "Here's how we're going to be structuring these programs, these rules," and on the back end, the regulators are actively figuring out how, and I think this is where it kind of has, like, a interesting convergence.

 with some of the DEA stuff, of, the telemedicine registration that doesn't exist today, that I'm, like praying happens because We need to have, a full list of who are all these telemedicine companies. But there's this interesting convergence of you're going to have a lot of digital health companies that are so used to this, like, Wild West really start to feel some pain what a traditional health plan or a traditional insurer or payer or, provider network had to comply with even in the cash pay side 

Yeah, 100%.

On the big scheme of things, [00:09:00] like a law, that's where you have the lobbying efforts, right? Before, when a legislature introduces something and they're like, "This is what we wanna get done," that's when you see the lobbyists all getting behind things and say, "No, we don't want this," or, "Yes, we do want this." but the second that the president or the governor signs a law and it's now the law of the land, then that's when you wait for the entity that's been delegated the authority, he or whatever regulator, comes up with its rules for how to implement that law.

So just as you kind of mentioned with the FDA and the DEA stuff that's kind of been happening, right? We've been looking at these like temporary rules for DEA telemedicine flexibility for the last five years. Every year at the end of the year, it's like, okay, we're gonna get it extended again 

And it's because the truth of the matter is like the DEA hasn't really figured out how they're going to implement the current standing law. And that's because everybody was operating on a COVID-19 structure. No one expected us to [00:10:00] get six years down the road where, you know, we'd be asking about long-term ability to prescribe controlled substances.

and we didn't realize that, creating access to healthcare was going to become something that everybody wanted. We all wanted an app on our phone, whether we were gonna be getting insurance pay or cash pay, right? It's so much easier to know your doctor can come to you from the comfort of your bedroom if you really needed them to.

And the law is trying to catch up, and regulators have all been sitting in those same seats for quite some time, just like legislatures do. and so with California specifically, the new, transaction reporting law is kind of this underlying theme of how can we make sure that when private equity has infused or is wanting to infuse cash into one of these companies, how can we make sure that they're not overly burdening or overly saturating the market?

 we [00:11:00] wanna still ensure that doctors or who are, is providing care. I think that's really what California's trying to say, which is why it's so analogous to the CPOM stuff that we've been talking about. and CPOM, if anybody has missed it, is the corporate practice of medicine. I think when you read what's been happening with all of California's CPOM litigation and just even the, statute going into effect at the beginning of the year, that really actually codified CPOM it seems like we're deciding, "Hey, if nobody else is gonna come up with a framework, we're gonna come up with a framework, and the framework's gonna be this is all the things that you have to do in order to own the business, and this is what you can and can't agree to do with your MSO," on the, lawmaker side.

And then on the regulator side, it's gonna be like, "And then if you want to invest in these companies, we wanna make sure you're above board. So you're gonna have to, if you're putting, you know, over 25 mil into a company, that's such a big transaction that the state wants to review it. [00:12:00] They wanna see what do these documents actually look like."

So there's now like it's a new 90-day notice period. That's really important for investors, because they like to see those deals close fast, right? And so knowing that you have 90 days before a deal could even close, assuming that the regulator doesn't even wanna do its cost market impact review, that substantially lengthens deal times and that can be really important for these companies.

Some of these telemedicine companies are, like, desperate for that infusion of cash too. So it's really about kind of understanding how quickly you need to get in and start having that conversation because the deal might take longer than it has in the past, specifically in a market like California, which is always one of the more profitable markets for these businesses too.

So, I think that's one of the big high points of the new rules. And there's also a 10-year look-back for serial transactions, which I think is gonna be [00:13:00] really interesting. I think for investors just understanding that, like, if you're going to be a frequent investor in these companies, you need to know that now California's gonna have, like, this database that has all your information in it, and they're gonna be seeing who's always investing, 

And I'm not an antitrust lawyer. I will never pretend to be an antitrust lawyer. But there's also, like, a public policy understanding of not wanting one kind of group of folks to own all of healthcare, right? We wanna make sure everybody has access, that there's no, control of the market that would be unjust or unfair to the citizens of the state.

And so- When you kind of just, like, look at all of that all together, what does that really mean for our clients? Is always, like, the next question. And I think with the wave of how, telemedicine is now being used for things like wellness you know, GLP-1s, peptides, like these are more unregulated markets or very under-regulated markets where new regulations are going to be [00:14:00] coming into play.

It's happening almost 100% via telemedicine. And so, okay, we can prepare ourselves. We now know a deal might take 90 days, but if more regulations are possibly coming, if the FDA is working on, you know, understanding these peptides, maybe it's time to stop and think about it, right? What does this really mean for our business model?

How can we scale? Second, are we gonna have to actually, like, prescribe the peptides now? So now we need to think about clinical questions that the doctors need to be answering. What does that assessment look like? what am I actually confirming to understand if this is actually something that is necessary for the patient?

Those are kind of the big-scale things that I think are gonna come now that we're seeing regulation happen in this area. 

Yeah. And to your point, I think one of the things that gives me heartburn, and again, it's only because I've been on the other side and I've done all these things, is you're working also with regulators who are, in startup world we always say, like, you're [00:15:00] building the plane as you're flying it.

Like, they are going to be building the plane as they're flying it. So for the first few kind of like submissions and, they call it a corrective action or, they're gonna kick it back to you of like, "You have this discrepancy," or this issue or this thing's wrong. I mean, you're basically going through pretty in-depth, audit and, 

you don't know what you don't know until you're there. And so to me the important part is making sure that, companies are thinking about these things in the right way. 

Yeah. 

99% of companies that I have either worked with or engaged with in some way, shape, or form never have a compliance team, and this is what, a compliance team does, right?

 I think a lot of times they'll assume it's the lawyer doing it, and it's like, oh, no, no. Like, the lawyer's gonna you know, just tell you- ... what the rules are. Like, you kind of need somebody to take that and go do it. So that's one thing that I've seen consistently. And then to my point is I really have this theory that it's like everything's gonna all hit at once, and you're gonna have startups really that are gonna be blocked [00:16:00] from getting investments, that are gonna be blocked from even practicing because they can't pass the telemedicine registration to continue to prescribe controlled substances if that's on their market.

And they're going to be thinking that things are kind of operating historically how they were maybe in the peptide or the wellness space, which we know kind of has a spotlight on it. I don't know, Shaylin, I know this is a little bit off topic, but I dove really deep into, the Eli Lilly lawsuits that just, happened and it was like one of the people that were named in the lawsuits was, like, a local med spa for me.

Like, 20 minutes from my house. They're a four-location med spa in California. They're not, like, rolling in the dough. They're not, like, some, multi-state thing. They're a four-location med spa in Sacramento. And so to me it's like, if you think that you're protected because you're small or don't have a ton of, memberships really doesn't matter anymore because it's not being targeted based on that.

It really is, if you're just out there. So [00:17:00] compliance is going to be really, really, really important, especially now that, again, there's this spotlight from outside or just companies from a, litigation standpoint, but then also, with all the new rules, regulations, and processes that are gonna be put in place.

Yeah. I think you hit the nail on the head on two things, and the first being that, who you are doesn't really matter, and there's threefold reason here, right? Like, so one thing we haven't talked in depth about, but I know you did a really good article on, was that Carbon Health settlement.

That's a telemedicine company, okay? So we know for a fact telemedicine is something the AG is looking at here in California and corporate practice and medicine matters even if you're telemed. but at the same time, there was a dental settlement like literally the month, before with physical locations.

So the AG's looking at, a physical location. Even if you're sitting in the middle of bankruptcy and you're not that loaded, we learn in those two settlements that the government will still care, right? there's still also, like, the Art Center Holdings case that [00:18:00] kind of started all of this, which was also a small physical location in Southern California.

And then on the flip side of it, competitors bringing actions because they want to have their own piece of the market is kind of what you're talking about in the litigation, right? Yeah. Like, even in the CPOM litigation in other states, like in Oregon, there's already a private right of action as part of Oregon CPOM structure.

So technically, like, if a doctor was not necessarily happy about what was happening, he could tell on himself now and probably get, closer to the resolution that they want to unwind some of these agreements. So I think we have, this big world of anything is possible, which is why you could come up with your doomsday theory that everything will stop for some people, right?

Like, there are multiple pathways for all of these companies because we've been reacting to life after COVID, and, COVID's over now. we can't even pretend that it's here and impacting our [00:19:00] communities in the same way anymore, and I think, the laws and the courts are all reacting to that.

And then I think the second piece is like my least favorite part about what you said. And it's my favorite part about what you said in the way that you said it, but my least favorite part in reality, and it's that people say all the time, like, "My lawyer cleared it." And it's like, "No. No, I did not." In fact, like we're trained as lawyers to never tell you like, "This is your exact course of action."

 we're trained to give you all the risk and say, "You can make your business decision now. This is what will happen here. This is what could happen there." And whenever a client says, "Oh yeah, it's okay because your firm already cleared it," and I was like, "I can guarantee you we have not cleared anything.

That's not our job. My job is to give you an analysis of your situation to tell you what pathways going forward should look like, and then you still have to operationalize every single one of those plans." So for example, if I tell you, "We're dealing with a privacy issue, you need to [00:20:00] have a notice of privacy practices," I can even draft the privacy practices for you, right?

 but I'm not the one who's putting it up on your website, and I'm not the one checking it every single year to make sure that it is, up to date and that it is compliant with any new changes that have come out. And so there's an operations gap that I think needs to be filled nationwide.

People did a great job of reacting to COVID and creating these companies, but now as the regulations are starting to realize all the failures that could occur, we need to be thinking about how to actually implement every single one of these regulations, whether they're already final or whether we know they're coming about.

Yeah. completely agree. And I think even to take it, like, a step further, a law firm also isn't going to dig in and go, "Do you have pixels on your website? And are you tracking patient journeys?" to me Half of what I always say to people is like, "Just [00:21:00] please take all the policies that you have," and if you wanna throw it in ChatGPT, be like, "What are the things I need to comply with?"

And build me a checklist. And go do a readiness assessment, because I've seen so many startups, "I'm compliant," because they have a terms on their website or a privacy policy, or they have corporate practice of medicine, they have their whole, set of contracts that I, give, validity to their friendly PCMSO structure, but then you realize they haven't talked to their physician owner in a year and a half, and they have all these clinicians that they've hired from their operations team who has no idea how to vet a clinical staff.

And they have contracts that were never submitted to state boards for collaborations, and so they think they're practicing legally, but they're not. There's so much nuance to it all that's why, to me, it's really important to make sure that it's not just the, paper side, but actually you can demonstrate and show at the very least, a good [00:22:00] faith effort and some sort of due diligence that you're attempting it.

You know, I always joke, when I wasn't the nicest regulator, right? Like, I would be really nice, like, my first warning, maybe my second warning. The third one,I'd be like, "Slap you with a sanction. You don't wanna listen to me, fine." But there gets to be a certain point where, I was a lot more lenient to the ones that at least like, okay, you're trying.

You're trying to comply. I get it, the rules are hard. Regulators don't know how it happens, like, boots on the ground. They don't understand how telemedicine works, right? so to them it's gonna be also a learning curve of, probably people like me having to go back to these states and go, "Actually I need you to change your policy because of X, Y, and Z reason," and really having to, like, fight and argue with them to try to get some sort of flexibility.

But it'll be really interesting, at least from my perspective, to see this sounds horrible, but I'm just gonna say it, like, the first couple, startups to get in trouble, right? Like, Shaylyn that's usually on our side. we're always looking at, who's getting investigated, where are the lawsuits?

'Cause that kind of [00:23:00] guides us on, okay, this is really what they're looking at and how they're enforcing it. So it's gonna be kinda interesting to see in a kinda sad way. 

Yeah. That's kind of where we are in California. I don't know what it's gonna look like in the other states, but seeing those settlements definitely has given us the kick that we needed.

I actually have a question for Leo. I wondered, listening to us nerd out about these regulations, like- From the doctor's point of view, what does that sound like? Like, does it sound overwhelming or, what would keep you up at night about this stuff? 

So, I was thinking what you were talking about.

And, just the regular boots on ground doctor, right? this is beyond the screen, right? This is behind the curtain, right? And a lot of times the regular clinician that is doing the clicks and, prescribing just takes it for granted, most of us trust the company and say, "Hey, okay, they got their stuff together in the background.

And you know what? If they say it, it's good." And we've talked about this a lot on this podcast is, this is why we like talking about it, is to [00:24:00] educate the doctors to say, "Hey, that's not the case a lot of times. Most of the times that's not the case. And you should be educated about these things because, well, hey, you need to ask these questions.

And because bottom line it's gonna get back to you. It's always your license is on the line." Now, especially when you're now, looking into the med director, even the PC owner role, right? This is where I think the rubber meets the road a little bit harder, right?

And this is where the whole, blank slate trust into the MSO that you're partnering with as, let's say, a physician PC owner, where you do have to take a step back and actually, look at it at a different lens at this lens that we're talking about. Hey, do you have a regulatory team?

How is this gonna affect me, right? did we follow the rules? So forth and so on. And the whole piece about just the whole, you know, a lot of these telemedicine companies don't have a compliance team. I've seen that, right? It's like, "Hey, our lawyer said it was okay. It should be good.

We should be good," right? but no that's not the case, right? So it's a little scary. but not necessarily scary, right? [00:25:00] I don't wanna say scary to, shoo people away. I think it's important to have physician leaders at the top of the rung here in these companies.

You just need to, right? this is kind of where we got lost in the brick and mortar space. So this is our chance to take medicine back. However, we need to do our due diligence and educate ourselves and, listen to these and listen, to, regulators, to the lawyers to truly understand what questions to ask, right?

 What you don't know, you don't know, right? You don't know what to ask. So, just really just gaining the tools to, go forward and be an educated physician in this space

I think like our nuts and bolts to end this conversation really are like one, selfishly, right?

You need competent counsel. ... I'm an operations type counsel. I don't just do the deal for you. I work with you to keep yourself streamlined and understand compliance obligations. You need someone who's gonna create a bespoke strategy for you, who understands your company and what you're actually [00:26:00] trying to do.

A lot of these companies use like, you know, the lawyers who have those off-the-shelf policies, and because- Mm-hmm ... the regulations are actively changing, you can't really rely on that anymore. I think number two, you need a compliance operations team in-house. Yep. that's where you need the Phoebe of it all, right?

Like, somebody who's gonna make whatever I said make sense, three, you need to feel like you are empowered to advocate for yourself as the physician owner or the medical director to, like, really confirm that the company has everything in line. And then four, you need to still have somebody who's behind the scenes watching as these changes are happening.

For what I do in my practice, I try to get on these podcasts so I can keep people abreast of what's going on. I try to write articles just so that people have the information somewhere out there in front of them. I think if you're doing those four things, you're less likely to get yourself in a lot of trouble, because that means there's at least four different people of some sort looking out for your interests, one of them [00:27:00] including you.

and I think, to Phoebe's point too, if you do meet that end or you do, have some sort of action against you, at least you can show that, hey, you know, I've been trying. it's more of just an ignorance versus a purposeful just, don't wanna do it, right?

Yeah. So I think there's a little bit more flexibility behind that too. 

Yeah. Well, and to just to add to that too, I think one of the things, and this might just be, like, me 'cause I'm a crazy person and I feel like I know too much, and Leo, you get this, like, doing things the right way, the compliant way, actually takes less time than doing it completely wrong.

I mean, Leo, as we were building up our process of how to structure our things and how to make the operations run smoothly, I mean, it was like if we skipped steps, like both you and I are like, "We can't sleep at night." Like, oh my gosh, Yeah ... so to me it's, really taking the time to go slow to go fast, in my opinion, is like really make sure that you've built the right infrastructure.

And then from a physician's perspective, which I sound like a total, beating a [00:28:00] dead horse on this 'cause I say it every episode, but, if you are a physician owner or a medical director or a supervisor and you cannot say what you are doing for those companies or for those providers that you're supposed to be partnering with- then like you're probably not doing what you're supposed to be doing.

Like if it truly is this, "Oh, it's passive income," none of what Leo, is passive, right? Yeah. Says like the bags under your eyes. I saw the email- ... you sent me at 4:00 in the morning, by the way. But you know what I mean. Like none of it really is passive. And so from a physician's perspective, take a minute and be like, "Wait, hold on.

As the owner, I'm supposed to be making sure that, all clinical hires are vetted and they have licenses," right? From short term. Or, even some of the new stuff of like tracking some of these regulations and making sure they have the right people,

but to compound that fact too though is you're right, you know.

It's not passive, but you can make it easier for yourself, right? You can make it kind of passive. you need the flow and the processes to do [00:29:00] that , right? And we found ourselves, if we didn't do it properly the first time, always rewinding.

 just ended up costing us more money, more time, right? And it's just not worth it, right? An ounce of prevention is worth, two pounds, or whatever that saying is. I don't know. I hate my sayings. Butyeah, exactly the point. it's worth your time upfront. It may be a little bit more painful upfront, and yes, a little bit more money upfront, but it's gonna save you a whole lot on the back end, 'cause then when you can just cruise and just, you know, go through the operations and go through the flow, it's a lot easier that way.

Yeah. Thank you again, Shalen, for coming, and this was great. I love when I get to talk on the episodes 'cause usually I'm the quiet one. Any just like last tips that you just wanna share with kind of our listeners? 

No, I think we talked about our top four, and I think the goal here is so that you can have those nights with sleep, right?

 everybody in the end wants a patient that's happy and that's healthy. And in order to get there and get to that end [00:30:00] goal, everybody also needs to sleep and to feel like they haven't done anything wrong. You don't want doctors afraid to do their job. So, I think that's always, like if we keep the end user in mind, it really helps all of us get what we need to get done.

And I do that in my daily practice too. 

 

thank you again for coming. And if anybody's looking for an amazing, firm or lawyer who really understands digital health, and I'm gonna just like double tap on if you're national and you have a lawyer who's in like really understands Texas, like stop.

You need to find somebody who understands California and build around California, 'cause it's gonna make it a lot easier. So we'll definitely share your contact information in our speaker notes so people could reach out. Please reach out to Shaylin if you do not have a lawyer or you're working with like somebody who really understands not healthcare.

Well, do you have a contact they could reach out that you'd say right now? 

Like my email? 

Yeah. So it's [00:31:00] shaylin.watkins@hklaw.com. Perfect. Shaylin's spelled fun. It's S-H-A-Y-L-I-N. That's the fun 

part. Got it. Well, no, this has been great. This is awesome. Very eye-opening. Hey, thank you everybody for joining telemedicine talks and, we'll see you again next time.