Why It Matters
Most regulatory rollouts fail the same way: leadership updates the policy, IT changes a system field, and everyone assumes the work is done. Then go-live hits. Staff give patients inconsistent answers, workflows break in places no one mapped, and the cleanup starts downstream.
In Amanda Hines' experience leading Patient Financial Services at Essentia Health through Minnesota's 2023 and 2024 regulatory changes - where federal rules, state statutes, Minnesota Attorney General requirements, and 501(r) obligations layered on top of each other - a new rule is not a policy update: “ "That's not, it's not like a little project, right? That's like a actual change management effort."
Her sharpest warning to operators:
"If we underestimate the training and communication items that are required to go along with that, that's kind of where I think some organizations might get yourself in a pickle."
Key Takeaways
1. Treat regulation as change management, not a policy update.
A new rule affects workflows, systems, scripts, statements, staff roles, and patient communications. Writing a policy alone does not touch any of those.
2. Start with interpretation.
Regulatory language is open to interpretation. Convene legal and compliance to define what is actually changing and who is affected before designing workflows.
3. Map operational effects across the cycle.
Ask: What does staff need to do differently? Which workflows have to change? What communication has to go out to patients? What does the policy need to reflect? What systems need updates?
4. Bring the right people to the table early.
Revenue cycle partners, compliance, legal, and IT should be engaged from interpretation forward, not brought in after decisions are made.
5. Explain the why, not just the what.
A common mistake Amanda names: leaders sit in a "think tank," solve the problem, then hand staff a new process without explaining the reasoning. Staff need to understand what is changing and why before go-live.
6. Define post-go-live metrics.
Decide up front how you will know the change is working. Without measurement, you cannot confirm the interpretation held up in production.
7. Collaborate with peer health systems.
Comparing interpretations with other providers in your market moves you faster and creates stronger defensibility when multiple organizations converge on similar approaches.
An Implementation Blueprint
Here's what the sequence looks like in practice, drawn from Amanda's Minnesota experience:
Phase 1: Interpretation
Owners: Legal, compliance, revenue cycle leadership.
Deliverable: An interpretation memo that names what is changing, who it impacts, and where the language is ambiguous.
Phase 2: Impact Mapping
Owners: Revenue cycle leadership with department leads from patient access, billing, PFS, and IT.
Deliverable: An impacted-role matrix and a workflow map covering system changes, staff behavior changes, patient-facing communications, and policy updates.
Phase 3: Cross-Functional Design
Owners: Revenue cycle partners, compliance, legal, IT.
Deliverable: Updated scripts, statements, letters, escalation paths, and system configurations.
Phase 4: Training and Communication
Owners: Training leads and department managers.
Deliverable: Role-specific training that explains both the change and the why, delivered before go-live.
Phase 5: Post-Go-Live Measurement
Owners: Revenue cycle leadership with compliance.
Deliverable: Defined metrics that confirm the change is working in production.
Peer Collaboration (Parallel Track)
Owners: Revenue cycle and compliance leadership.
Deliverable: A working group with peer health systems to compare interpretations and pain points.
On Peer Collaboration
Amanda described initial hesitation about reaching out to competing health systems, then finding that most were willing to engage: "Collaboration to me doesn't mean giving away your, you know, competitive secrets or anything like that. It just means solving and sharing those operational problems a little bit better."
The operational benefit was speed. The strategic benefit was defensibility. In her words: "If you've got five organizations that are all struggling with the same problem, and we have the same interpretation of what this regulation needs to be, so we're all going to adopt this similar process, that creates a stronger case for everybody to use that process."
In Practice: GetixHealth Guidance
In our experience working with providers on regulatory implementation, the organizations that struggle most are the ones that treat the policy document and a system field update as the deliverable. The invisible work - retraining staff, rewriting scripts, redesigning statements, updating escalation paths, coordinating across departments - is what determines whether the change actually holds in production.
Two practical recommendations we'd add to Amanda's sequence:
- Inventory patient-facing artifacts early. Statements, letters, scripts, financial counseling talk tracks, registration prompts, and denial communications should all be reviewed against the new interpretation before workflows are locked.
- Form the peer working group before you finalize your interpretation. Comparing notes after implementation limits collaboration to comparing outcomes, not shaping approach.