Thursday, November 5, 2026

Healthcare Has a Strange Business Model: We Pay People to Fix Mistakes We Pay Software to Create

Why the Next Breakthrough in Medical Billing May Have Nothing to Do With Billing



“For too long, fee-for-service payment has rewarded volume over value.” — Dr. Mehmet Oz, CMS Administrator

 

The Healthcare Industry Has Perfected an Expensive Art: Fixing Problems It Could Have Prevented

Imagine running a restaurant where the chef prepares an excellent meal.

The customer enjoys it.

The waiter delivers the bill.

Then the restaurant spends three weeks proving that the customer actually ordered the food.

Welcome to healthcare.

We call it revenue cycle management.

In almost any other industry, we might call it a design problem.

Here is the uncomfortable question.

What if the medical billing industry has become exceptionally good at solving problems that should never have existed?

We hire billing specialists to correct claims.

We hire coding experts to interpret documentation.

We hire denial management teams to challenge payers.

We purchase software to track all the work.

Then we purchase AI to make the work faster.

Everyone is busy.

Everyone has a dashboard.

Everyone can explain why the claim was denied.

Meanwhile, the physician is still waiting to get paid.

Something about this deserves a second opinion.

I am a physician and the founder of OnnX, an AI-powered medical billing initiative focused on independent clinics.

The more I examine revenue cycle management, the more I question one of its fundamental assumptions.

We treat billing failures as downstream administrative problems.

But many begin much earlier.

At registration.

During eligibility verification.

When authorization requirements are overlooked.

When clinical documentation is transformed into structured data.

When information moves between disconnected systems.

The denial is often the symptom. The disease is upstream.

And healthcare has developed an impressive industry around treating the symptom.

That is not an argument against billing professionals.

Their work is essential.

It is an argument against designing systems that repeatedly require them to repair preventable mistakes.

A good billing department fixes errors. A better system prevents the avoidable ones.

The distinction may determine the future of independent medical practice.


Seven Uncomfortable Truths Every Clinic Owner Should Consider

Before diving into the details, consider these seven ideas.

  1. Your billing department may be doing excellent work inside a poorly designed system. More effort cannot always compensate for broken information flow.
  2. A paid claim is not necessarily a successful process. If it took five corrections, three phone calls, and two appeals, payment may have come at an unnecessarily high administrative cost.
  3. Your EHR may be excellent at storing information and terrible at moving the right information to the right place. Storage is not understanding.
  4. AI cannot repair clinical meaning it never received. A confident answer built on incomplete information remains unreliable.
  5. A high denial recovery rate can coexist with an inefficient revenue cycle. Recovery is valuable. Prevention may be more valuable.
  6. The most useful billing dashboard may be the one that explains why problems happen. Knowing that money is missing is less useful than knowing what to change.
  7. The future of medical billing may belong to companies that make billing less complicated, not companies that make billing software more complicated.

That last point is worth remembering.

The ultimate purpose of automation is not to create a more impressive workflow. It is to make unnecessary work disappear.


The Patient Was Treated Successfully. Then the Administrative Adventure Began.

Consider a fictional independent clinic.

The physician sees a patient named Michael.

Michael is 62 years old and has diabetes, hypertension, and worsening fatigue.

The physician reviews his medications, evaluates his symptoms, documents the findings, and develops an appropriate care plan.

The encounter takes 25 minutes.

The administrative consequences may last 25 days.

Here is how.

Monday: Everything Looks Fine

Michael checks in.

His insurance card is scanned.

The front desk confirms his demographic information.

The physician sees him.

The encounter is documented.

The charge is entered.

The claim is submitted.

The clinic moves on.

Nobody notices that Michael recently changed insurance plans.

His new coverage has different administrative requirements.

The system has information.

Unfortunately, it is yesterday's information.

Outdated data is not harmless simply because it is neatly organized.

Wednesday: The First Problem Appears

The claim fails an eligibility-related requirement.

The billing specialist begins investigating.

The front desk is contacted.

Michael may need to provide updated information.

The billing system displays an error.

But the error did not begin in the billing system.

It began before the encounter.

The billing system is merely delivering the bad news.

Like a smoke alarm, it is useful.

But nobody would describe a smoke alarm as a fire prevention strategy.

Friday: The Second Problem Appears

While reviewing the claim, the billing specialist notices a discrepancy between the documented assessment and a diagnosis selected from the patient's historical problem list.

The physician receives a clarification request.

The physician must reopen the record.

The billing team waits.

The practice manager follows up.

A problem that might have been identified during charge capture has become another administrative task.

Nobody intended to create the work.

Yet everyone is now participating in it.

Two Weeks Later: The Claim Is Corrected

The information is updated.

The documentation discrepancy is resolved.

The claim is resubmitted.

Eventually, payment arrives.

The billing department records a successful resolution.

And technically, it is.

But what exactly was accomplished?

The practice delivered one clinical service.

Then several employees worked to correct information associated with that service.

The clinic did not necessarily have a billing problem. It had an information problem that billing exposed.

This fictional example is a composite of common operational issues, not a documented OnnX customer case.

Its purpose is to reveal a larger structural weakness.

The claim was not the beginning of the revenue cycle.

It was the final messenger carrying information assembled by many people and systems.

And as physicians know, treating the messenger rarely cures the underlying condition.


The Most Expensive Word in Medical Billing May Be “Rework”

Healthcare loves productivity metrics.

Claims processed per employee.

Days in accounts receivable.

Denial recovery rates.

Average reimbursement.

Collections per physician.

These numbers matter.

But one of the most revealing measurements receives less attention.

How much work does your clinic perform more than once?

Consider a simple hypothetical example.

A clinic submits 1,000 claims monthly.

One hundred require preventable correction or additional administrative work.

That is a 10% rework rate.

Assume each affected claim consumes 20 minutes of staff time.

That produces approximately 33 hours of rework every month.

At an illustrative fully loaded labor cost of $35 per hour, the direct expense is approximately $1,167 monthly, or $14,000 annually.

That excludes physician interruptions, payment delays, vendor costs, and potentially unrecovered revenue.

Now imagine reducing the preventable rework by half.

The clinic could save approximately 17 staff hours monthly.

Not because employees worked harder.

Not because the clinic hired more people.

Not because the physician saw more patients.

Simply because fewer mistakes needed correction.

These are illustrative calculations, not verified savings from a particular practice.

But the principle is powerful.

The cheapest administrative task is often the one you never need to perform.

That raises a provocative question.

Why do so many revenue cycle conversations begin with collections instead of rework?

Perhaps because collections are easy to count.

Prevented mistakes are harder to see.

A recovered $5,000 claim appears on a report.

An eligibility error prevented before the encounter rarely receives applause.

There is no dramatic recovery story.

No heroic phone call.

No appeal letter.

Just a claim that processes correctly.

How boring.

How valuable.

The best operational improvement often looks like nothing happened.


Healthcare AI Has a Garbage-In Problem. But the Real Problem Is More Interesting.

The familiar technology expression is garbage in, garbage out.

It is useful.

But healthcare deserves a more precise version.

Incomplete context in. Confident mistakes out.

Healthcare information is rarely simple.

A physician's clinical note may contain symptoms, observations, uncertainty, medical reasoning, patient preferences, and contextual details.

A billing claim contains a much narrower representation of the encounter.

Between those two forms of information, something important happens.

Clinical meaning is translated into structured data.

Diagnoses become codes.

Services become billing entries.

Clinical documentation becomes evidence supporting the reported services.

Patient information becomes administrative fields.

This transformation is necessary.

But it is not always perfect.

The Translation Problem

Imagine translating a novel into a restaurant menu.

Both contain words.

Both can be structured.

But they serve different purposes.

A menu cannot preserve every detail of a novel.

Similarly, a claim cannot contain every detail of a clinical encounter.

That is not inherently a flaw.

The problem arises when information essential to an administrative or clinical decision is lost, misinterpreted, or disconnected during transformation.

A physician may document a clinically important finding in free text.

A downstream system may not recognize its relevance.

A diagnosis may be selected from an outdated problem list.

A required authorization may exist but remain inaccessible to the billing workflow.

A claim may contain technically valid codes without adequate supporting documentation.

Data can be structured, standardized, and still wrong.

This is where the conversation about healthcare AI needs more sophistication.

The question is not simply whether an AI model can read clinical documentation.

The question is whether it can preserve the meaning required for a particular decision.

And whether it can recognize when that meaning is missing.

The Role of FHIR

Fast Healthcare Interoperability Resources, or FHIR, provides a standardized framework for exchanging healthcare information.

It can support more consistent access to clinical data.

But interoperability is not the same as clinical understanding.

A successful transfer does not prove that the information is complete.

A valid code does not prove that it is appropriate.

A structured field does not prove that the original clinical meaning survived.

And an AI model receiving the data does not automatically know what was excluded.

Moving bad information faster is not interoperability success. It is efficient confusion.

That is why data validation should occur throughout the information lifecycle.

Not only after the claim fails.


We Have Been Asking AI the Wrong Question

Most discussions about AI-powered medical billing begin with capabilities.

Can AI code encounters?

Can it identify denials?

Can it generate appeals?

Can it predict payment delays?

Can it automate follow-up?

These are reasonable questions.

But I would begin somewhere else.

What administrative work should not exist in the first place?

This reframes the problem.

Instead of asking how AI can accelerate denial management, ask how AI can help identify preventable errors before submission.

Instead of asking how AI can summarize unpaid claims, ask why those claims became unpaid.

Instead of asking how AI can increase billing productivity, ask whether the workflow contains unnecessary tasks.

This does not mean downstream automation lacks value.

It does.

Payer disputes are real.

Coverage policies are complex.

Some denials are inappropriate.

Appeals remain necessary.

But a system focused entirely on downstream recovery risks becoming very good at managing recurring failure.

Consider the difference.

Reactive AI: This claim was denied because the authorization number was missing.

Preventive AI: This service may require authorization, and the required information has not been confirmed.

The first identifies a problem.

The second may help prevent it.

Both are useful.

But they operate at different points in the process.

One repairs.

The other protects.

The most intelligent billing system may be the one that knows when not to submit a claim.

That does not mean delaying valid claims unnecessarily.

It means identifying material, resolvable problems before they become avoidable rejections or denials.


Three Medical Experts, Three Lessons the Billing Industry Should Hear

The future of medical billing is not only a technology question.

It is a systems-design question.

A clinical workflow question.

A policy question.

And ultimately, a human question.

Three prominent physicians offer useful perspectives.

Their ideas are interpreted here through their established work and public policy positions. These are not direct interviews or endorsements of OnnX.

Dr. Donald Berwick: Stop Blaming People for Problems Created by Systems

Dr. Donald Berwick, a pediatrician and influential healthcare quality leader, has spent much of his career advancing systems-based improvement.

His work challenges a common management reflex.

When something goes wrong, find the person responsible.

In medical billing, that often sounds like this.

Who entered the wrong insurance number?

Who missed the authorization?

Who selected the incorrect code?

Who forgot to follow up?

These questions may identify the immediate action.

But they often miss the conditions that made the error likely.

Perhaps the front desk was switching between three applications.

Perhaps the authorization requirements were not visible during scheduling.

Perhaps the clinical note and charge entry systems did not share information effectively.

Perhaps nobody owned the final validation step.

The better question is:

Why did the system allow this mistake to happen?

This does not eliminate individual accountability.

It places accountability within a better-designed process.

A clinic should make correct actions easier and predictable mistakes harder.

When the same mistake happens repeatedly, stop calling it a mistake. Start investigating the system.

That is the first expert lesson.

Dr. Robert Wachter: A Brilliant Algorithm Can Still Be a Terrible Coworker

Dr. Robert Wachter, an internist and leading voice in digital healthcare, has examined the complicated relationship between technology and clinical practice.

His work offers an important warning.

Technology does not operate in a vacuum.

It operates around real people.

People who are interrupted.

People who are busy.

People who have incomplete information.

People who must make decisions under pressure.

An AI system may demonstrate impressive coding accuracy during testing.

But what happens inside a clinic?

Does it generate excessive alerts?

Does it require physicians to review trivial discrepancies?

Does it interrupt documentation?

Does it explain why a recommendation was made?

Does it recognize exceptions?

Does it reduce work?

Or does it simply create a more technologically advanced way to annoy everyone?

A brilliant algorithm can still be a terrible coworker.

The true test of healthcare AI is not how impressive it looks in a demonstration. It is how much unnecessary work disappears on Monday morning.

That is the second expert lesson.

Dr. Mehmet Oz: Payment Policy Is Changing. Administrative Systems Must Keep Up.

Dr. Mehmet Oz, CMS Administrator, has emphasized changes in Medicare payment policy intended to better align reimbursement with value, prevention, and accountability.

The November 4, 2026 Medicare Physician Fee Schedule announcement illustrates the connection between payment policy and practice operations.

Policy changes affect more than reimbursement calculations.

They can influence documentation, coding, billing, staffing, and workflow design.

A large healthcare organization may assign teams to interpret and implement new rules.

An independent clinic may rely on one practice manager.

Perhaps that manager is also handling payroll, scheduling, vendor contracts, and an employee who called in sick.

This is the reality of small-practice management.

A new payment rule may look like a paragraph in a federal document.

Inside a clinic, it can become several operational changes.

A regulation does not implement itself. Someone in the clinic has to translate it into work.

The third expert lesson is that technology should help practices adapt to changing requirements without creating another layer of complexity.


This Week's News: Medicare Changes the Rules. Again.

On November 4, 2026, CMS announced the final 2027 Medicare Physician Fee Schedule.

The announcement included payment adjustments, coding changes, and policies affecting several aspects of physician practice.

For independent clinics, three developments deserve attention.

First: Payment Pressure Is Not Disappearing

CMS reported 2027 conversion factors of approximately $32.95 for qualifying alternative payment model participants and $32.63 for nonqualifying participants.

Those represent projected decreases of 1.83% and 2.31%, respectively, from the corresponding 2026 conversion factors.

These percentages are not estimates of every physician's overall revenue change. Actual effects vary by specialty, service mix, geographic adjustments, and other policies.

Still, the operational implication is obvious.

When reimbursement is under pressure, preventable administrative waste becomes harder to ignore.

A clinic cannot control every payment rule. It can control more of the information it submits.

Second: Coding Rules Continue to Evolve

CMS finalized changes involving separately identifiable office and outpatient evaluation and management services performed on the same day as certain procedures.

The final policy applies to specified circumstances involving 0-day global procedures, with the lower-valued separately payable service paid at 80% rather than the initially proposed 50%.

The agency also finalized changes transitioning the G2211 office and outpatient visit complexity add-on to a modifier-based approach.

These details matter because a billing system configured for yesterday's rules can become tomorrow's source of errors.

Third: Technology-Enabled Care Still Requires Administrative Discipline

CMS also finalized remote monitoring policy changes, including delaying a restriction involving contracted clinical staff until 2029.

The broader lesson extends beyond remote monitoring.

A clinical service may be appropriate.

A technology may function properly.

A physician may deliver excellent care.

But reimbursement still depends on meeting applicable administrative and documentation requirements.

Clinical innovation moves quickly. Payment rules move differently. Independent clinics live in the gap.

That gap is where better information management can create practical value.


The Statistics Physicians Should Actually Care About

Healthcare loves big numbers.

Billions lost.

Millions of claims.

Thousands of administrative hours.

These statistics attract attention.

But national estimates rarely tell a clinic owner what to fix on Tuesday.

A practice needs its own measurements.

Here are the numbers I would prioritize.

First-Pass Claim Acceptance

How many claims are accepted for processing on the first submission?

A clinic might establish 95% or higher as an internal target, depending on its baseline and definition.

Acceptance is not payment.

But repeated submission failures reveal unnecessary work.

Initial Denial Rate

How often do payers initially deny claims?

Measure consistently by claim count, claim line, or dollars.

Separate preventable administrative failures from disputed payer decisions.

A denial rate without a root-cause breakdown is a symptom report, not a diagnosis.

Accounts Receivable Aging

How much collectible revenue remains outstanding beyond 30, 60, 90, and 120 days?

An internal goal of fewer than 45 days in A/R may be useful for some practices, but specialty and payer mix matter.

The trend is often more informative than a single target.

Staff Rework Hours

How much time is spent correcting information?

How often are physicians interrupted for documentation clarification?

How many claims require multiple submissions?

These questions expose the hidden labor cost of poor information quality.

Preventable Denials

Which denials could reasonably have been avoided through earlier validation?

This is where a clinic begins moving from recovery toward prevention.

Cost to Collect

How much does the practice spend collecting revenue?

Include relevant staffing, software, vendor, and administrative costs.

A low cost to collect is not inherently good if collections or compliance suffer.

The goal is accurate, timely, compliant reimbursement with reasonable administrative effort.

The best metric is not the one that makes the dashboard look good. It is the one that tells you what to fix.


The Great Billing Paradox: Success Can Hide Failure

Imagine two clinics.

Clinic A has an excellent denial recovery team.

It successfully overturns many denials.

The team works hard.

The practice eventually collects much of the money.

Clinic B has fewer preventable denials.

Its staff spends less time correcting claims.

It may need fewer appeals.

Which clinic has the better revenue cycle?

The answer depends on the complete financial and operational results.

But this comparison exposes a blind spot.

A high recovery rate can be evidence of strong performance after a failure, not evidence that the overall system is well designed.

Think about hospital quality.

We would not judge surgical safety solely by how effectively a hospital treats postoperative complications.

We would also ask how many complications could have been prevented.

Why should billing be different?

Recovery matters.

Prevention matters too.

The industry needs both.

But the emphasis should shift toward eliminating avoidable work wherever possible.

A system should not receive all the credit for solving a problem it repeatedly allows to occur.


The Ten Pitfalls That Make AI Billing Projects Fail

Technology can improve medical billing.

It can also create expensive disappointment.

Here are ten pitfalls worth avoiding.

1. Automating before understanding the workflow. If the process is broken, automation may simply accelerate failure.

2. Treating AI output as authoritative. A confident coding suggestion is not proof that the code is supported.

3. Ignoring clinical context. Structured data may omit important information.

4. Confusing acceptance with payment. A claim can pass initial validation and still be denied.

5. Measuring productivity without measuring rework. More processed claims do not automatically mean better performance.

6. Applying generic payer rules. Coverage and billing requirements vary across payers, contracts, and services.

7. Overloading physicians with alerts. A tool that interrupts clinicians constantly may create more burden than it removes.

8. Ignoring privacy and security. Billing automation frequently involves protected health information.

9. Buying features instead of outcomes. A long feature list is not evidence of value.

10. Forgetting that some denials are payer failures. Practices need effective appeal and escalation processes, not merely internal correction tools.

The common theme is simple.

Technology cannot substitute for understanding the problem.


A Practical 90-Day Plan: Fix One Problem Before Buying Another Platform

Independent practices rarely have the resources for endless transformation projects.

Fortunately, meaningful improvement can begin with a focused process.

Days 1–15: Find the Friction

Review recent claims.

Identify recurring denials, rejections, payment delays, and staff rework.

Interview the people closest to the process.

Ask the front desk what repeatedly goes wrong.

Ask billers which problems consume the most time.

Ask physicians what administrative questions interrupt their work.

Do not assume management already knows the answers.

The people doing the work often understand the friction better than the people reviewing the reports.

Days 16–30: Follow the Information

Choose one recurring problem.

Trace it backward.

Where did the information originate?

Who entered it?

Who verified it?

Which system received it?

Where did it become incomplete or incorrect?

Was the problem detectable earlier?

This is the most important step.

Do not begin by asking who made the mistake. Begin by asking where the information stopped being trustworthy.

Days 31–45: Redesign the Checkpoint

Create a simple prevention mechanism.

For example, verify eligibility before the encounter.

Clarify authorization responsibilities.

Standardize charge capture.

Establish a documentation query process.

Improve communication between clinical and billing staff.

The intervention should be specific enough to measure.

Days 46–60: Introduce Appropriate Automation

Determine whether technology can make the improved process more reliable.

Sometimes a simple rule is sufficient.

Sometimes integration is necessary.

Sometimes AI can help interpret unstructured information.

Choose the least complicated solution that addresses the problem effectively.

Do not use a neural network to solve a problem a checkbox can prevent.

Days 61–75: Measure the Results

Compare performance against the baseline.

Did the error rate fall?

Did rework hours decrease?

Did first-pass acceptance improve?

Were there unintended consequences?

Did staff actually use the new process?

Days 76–90: Decide What to Keep

Retain what works.

Modify what does not.

Document the results.

Then identify the next priority.

A successful improvement program does not need to fix every problem immediately.

It needs to make the next improvement easier.

Small improvements compound. Repeated mistakes compound too. Choose which one your clinic wants to accumulate.


What Physicians Should Demand From AI Billing Vendors

If you are evaluating an AI-powered medical billing platform, ask questions that go beyond the demonstration.

Do not begin with:

How many features does it have?

Begin with:

Which specific problem does it prevent?

Then ask:

  • Can the system identify missing information before submission?
  • Does it explain the reason for its recommendations?
  • Can staff review and override appropriate suggestions?
  • How does it handle uncertain or conflicting information?
  • Does it integrate with existing EHR and practice management workflows?
  • How are payer and coding updates maintained?
  • What security and privacy safeguards are provided?
  • Can it demonstrate measurable reductions in rework?
  • What happens when the system makes a mistake?
  • Who remains accountable for the final claim?

These questions separate impressive technology from practical technology.

A vendor may show you a beautiful dashboard.

Ask what the dashboard changes.

A vendor may demonstrate an intelligent coding assistant.

Ask how unsupported recommendations are prevented.

A vendor may promise greater efficiency.

Ask how efficiency will be measured.

A demonstration shows what software can do. Evidence shows what it actually improves.


Legal Implications: AI Does Not Come With a Liability Eraser

Medical billing is regulated.

AI does not change that.

Practices must still comply with applicable documentation, coding, reimbursement, privacy, and contractual requirements.

Several issues deserve attention.

Billing Integrity

Claims must accurately reflect services provided and meet applicable requirements.

AI should not recommend unsupported diagnoses, unnecessary services, or inappropriate billing strategies.

Improper claims can create serious compliance consequences, including potential exposure under federal and state laws.

HIPAA Compliance

AI vendors handling protected health information may require appropriate business associate agreements and security safeguards.

Practices should understand how data is accessed, stored, processed, and protected.

Human Oversight

Automation should not eliminate required professional review.

Clinical judgment, medical necessity, documentation accuracy, and complex coding decisions may require qualified personnel.

Auditability

A practice should be able to reconstruct important decisions.

What information was used?

What recommendation was generated?

Who reviewed it?

What changed?

Why?

An AI system that cannot explain a consequential recommendation may create a new compliance problem while trying to solve an old billing problem.


Ethical Considerations: The Patient Is Not a Billing Code

It is easy to discuss revenue cycle management entirely in financial terms.

Claims.

Collections.

Margins.

Denials.

Productivity.

But every claim begins with a patient.

And every patient encounter contains more meaning than a reimbursement transaction.

This creates ethical responsibilities.

Clinical accuracy must come before financial optimization.

AI should not encourage documentation designed to justify services that were not provided.

It should not recommend diagnoses merely because they may increase reimbursement.

It should not conceal uncertainty.

It should not make decisions that unfairly disadvantage patients with complex or unusual conditions.

And it should not compromise patient privacy in pursuit of efficiency.

The objective is not to maximize reimbursement at any cost.

It is to support appropriate payment for legitimate, properly documented care.

The right goal is not getting paid more for the same care. It is getting paid correctly without unnecessary administrative friction.

That distinction matters.

Especially when technology companies promise to revolutionize healthcare.

Revolution is a large word.

Accuracy is a more useful starting point.


Myth Busters: Eight Beliefs That Deserve a Second Opinion

Myth 1: More AI means fewer billing problems.

Reality: More AI can also mean more automated mistakes. The outcome depends on data quality, workflow design, and oversight.

Myth 2: A paid claim means the process was efficient.

Reality: A claim may be paid only after substantial administrative rework.

Myth 3: Medical billing begins after the patient visit.

Reality: Revenue cycle processes begin before care, including registration, eligibility, and authorization.

Myth 4: Structured data is trustworthy data.

Reality: Information can be consistently formatted and consistently wrong.

Myth 5: Outsourcing billing eliminates administrative responsibility.

Reality: Outsourcing changes who performs the work, not the practice's need for oversight.

Myth 6: The best billing company recovers the most denials.

Reality: Recovery performance matters, but so do preventable denials, cost to collect, and overall financial outcomes.

Myth 7: AI will replace all medical billing professionals.

Reality: Automation may change roles, but complex exceptions, compliance, payer disputes, and clinical questions still require expertise.

Myth 8: Independent clinics need enterprise-level technology to improve performance.

Reality: Many improvements begin with better processes, clearer responsibilities, and reliable measurement.

The larger lesson?

Sophisticated technology cannot compensate indefinitely for unsophisticated processes.


Why I Am Building OnnX Around a Different Question

As a physician-entrepreneur, I have become increasingly interested in the gap between clinical work and administrative outcomes.

Physicians deliver care.

Then the information describing that care enters a complicated system of codes, rules, software, vendors, and payer decisions.

Some complexity is necessary.

Much of it deserves scrutiny.

When thinking about OnnX, I could begin with the familiar technology question:

How can AI make medical billing faster?

But I find another question more interesting.

Why does so much billing work need to happen at all?

That question leads upstream.

Toward eligibility.

Toward demographics.

Toward authorization.

Toward documentation quality.

Toward charge capture.

Toward reliable information exchange.

And toward systems that identify uncertainty before it becomes an expensive problem.

OnnX is being developed around the premise that revenue cycle management is partly an information-quality problem disguised as an administrative workflow problem.

The ambition is to help independent clinics reduce unnecessary intermediaries and administrative friction while improving visibility into the revenue cycle.

That is a product thesis, not proof that every problem has been solved.

The practical value must be demonstrated through real-world workflows and measurable outcomes.

I am especially interested in understanding which upstream interventions produce the clearest improvements.

Fewer preventable denials?

Less staff rework?

More reliable first-pass claim acceptance?

Better visibility into outstanding receivables?

More predictable cash flow?

Those are the outcomes that matter.

Not the number of AI features.

Not the complexity of the algorithm.

Not the sophistication of the sales presentation.

Physicians do not need more artificial intelligence to admire. They need fewer administrative problems to manage.

And perhaps that is the most useful way to judge healthcare innovation.

Not by how much technology we add.

But by how much unnecessary work we remove.


Future Outlook: The Next Revenue Cycle Revolution May Be Invisible

Healthcare technology is moving toward greater automation.

AI models are becoming more capable.

Interoperability tools are improving.

Administrative workflows are becoming increasingly digital.

But the future may not look like a giant command center filled with dashboards.

It may look surprisingly ordinary.

A patient arrives.

Insurance information is current.

Authorization requirements have been checked.

The physician documents care.

The relevant billing information is accurately captured.

The claim is validated.

Exceptions are identified.

Appropriate human review occurs.

The claim is submitted.

Payment is reconciled.

The clinic learns from problems that arise.

Nobody spends the afternoon searching for an insurance number.

Nobody asks the physician to clarify information already available in the record.

Nobody celebrates recovering a preventable denial.

The process simply works more reliably.

That may sound less exciting than autonomous AI agents.

But for an independent clinic, boring can be beautiful.

The highest form of administrative intelligence may be making administration almost invisible.

Of course, payer disputes, regulatory complexity, and unavoidable exceptions will remain.

The goal is not perfection.

The goal is to make preventable problems less common and necessary work easier to perform.

That is a future worth pursuing.


Frequently Asked Questions

What is AI-powered medical billing?

AI-powered medical billing uses artificial intelligence to assist with administrative and revenue cycle tasks, including documentation review, coding suggestions, claim validation, denial analysis, and workflow prioritization.

Its effectiveness depends on the underlying information, implementation, and appropriate oversight.

Can AI eliminate medical billing denials?

No. Some denials arise from payer policies, coverage restrictions, disputed medical necessity decisions, or other circumstances.

AI may help reduce certain preventable errors and support denial management, but eliminating all denials is not realistic.

Why do claims get denied?

Claims may be denied because of eligibility issues, missing authorization, documentation problems, coding discrepancies, coverage limitations, medical necessity determinations, or payer processing errors.

The cause should be identified before choosing a solution.

What is the difference between denial prevention and denial management?

Denial prevention focuses on identifying avoidable problems before claim submission.

Denial management focuses on investigating, correcting, appealing, or otherwise resolving claims that have already been denied.

Both are necessary.

Why is data quality important in medical billing?

Medical billing depends on accurate patient, insurance, provider, service, diagnosis, and administrative information.

Incorrect or incomplete information can lead to delays, denials, rework, or improper reimbursement.

Is FHIR a medical billing standard?

FHIR is primarily a healthcare information exchange standard.

It can support access to clinical information, but medical billing also relies on other standards, transactions, code sets, and payer-specific requirements.

Can small clinics benefit from AI?

Potentially.

The strongest use cases are those that address measurable problems without creating excessive implementation costs or staff burden.

What should a clinic measure first?

Start with first-pass claim acceptance, denial rate, A/R aging, rework hours, and preventable denial categories.

Use consistent definitions and establish a baseline.

Should physicians outsource billing?

Outsourcing may be appropriate depending on staffing, cost, specialty, internal expertise, and vendor performance.

The practice should retain adequate visibility and oversight.

Can AI select medical diagnosis codes automatically?

Some systems can suggest codes.

However, recommendations must be supported by documentation and reviewed as appropriate.

AI should not invent clinical facts or recommend unsupported diagnoses.

Will AI replace medical billers?

AI may automate repetitive tasks and change the responsibilities of billing professionals.

Complex coding, payer disputes, compliance decisions, and exception management will continue to require expertise.

How can physicians reduce administrative burnout?

Begin by identifying recurring interruptions and rework.

Improve workflows, clarify responsibilities, eliminate unnecessary duplication, and introduce technology only where it reduces meaningful burden.

What is the best AI billing platform?

There is no universal best platform.

The right choice depends on the practice's needs, existing systems, compliance requirements, costs, and evidence of measurable improvement.

How long does revenue cycle improvement take?

A focused 60- to 90-day assessment and improvement cycle can help evaluate specific changes.

More complex financial results may require longer observation.

What is the biggest mistake clinics make when adopting AI?

Buying technology before identifying the operational problem.

The most expensive software is often the software purchased without a clear reason to use it.


Final Thoughts: Stop Celebrating the Fire Department. Start Preventing Fires.

Healthcare has developed remarkable capabilities.

We can image the human body in extraordinary detail.

We can detect diseases earlier.

We can perform complex procedures with extraordinary precision.

We can develop AI systems capable of interpreting increasingly sophisticated clinical information.

Yet an independent physician can still spend weeks trying to get paid because an insurance identifier was outdated.

There is something almost comical about that contrast.

Almost.

Because the consequences are real.

Administrative waste consumes staff time.

Delayed reimbursement creates financial uncertainty.

Repeated documentation requests interrupt physicians.

And operational complexity makes independent practice harder to sustain.

We should not accept these problems as unavoidable simply because they have become familiar.

The industry has invested heavily in recovering denied claims.

Now it should invest more attention in preventing avoidable denials.

It has invested in processing information faster.

Now it should invest in making that information more trustworthy.

It has invested in making billing systems more intelligent.

Now it should ask whether those systems can make billing less burdensome.

The future of healthcare AI should not be measured by how many mistakes it can correct. It should be measured, in part, by how many mistakes never happen.

Because the ultimate goal is not to build a more impressive billing industry.

It is to give physicians more time to practice medicine.

And that may be the most important innovation of all.


Get Involved: The Conversation Independent Physicians Need to Have

A question worth debating: Has healthcare become too comfortable paying people and software to repair preventable administrative mistakes instead of redesigning the processes that create them?

Have your say: If you own or manage a clinic, comment with the single biggest source of administrative rework in your practice: eligibility, authorization, documentation, coding, or payer denials.

Help change the conversation: Repost this article if you believe independent physicians deserve fewer billing headaches, better information, and technology that removes unnecessary work rather than creating more of it.


About the Author

Dr. Daniel Cham is a physician, medical consultant, and healthcare entrepreneur whose interests span medical technology, healthcare management, medical billing, and the practical application of artificial intelligence.

He is the founder of OnnX, an AI-powered medical billing SaaS initiative focused on helping independent clinics address administrative inefficiencies, improve information quality, and reduce unnecessary intermediaries.

His work explores a central question: How can healthcare technology remove complexity rather than add another layer of it?

Through writing, research, and professional discussions, Dr. Cham shares practical perspectives on healthcare innovation, physician entrepreneurship, revenue cycle management, and the future of independent medical practice.

Connect with Dr. Daniel Cham on LinkedIn

P.S. Visit the Featured section of my LinkedIn profile for a free resource. No signup is needed here.


Continue the Conversation Beyond LinkedIn

Healthcare improves when physicians, innovators, and practice leaders challenge assumptions and exchange practical ideas.

For more insights into medicine, technology, healthcare operations, and the realities of building better systems, explore the following channels.

Personal website: DrDanielCham.com

Podcast: Listen on Spotify

Video discussions: Subscribe on YouTube

Professional perspectives: Follow on X | Facebook | Substack

Short-form insights: TikTok | Instagram | Threads

Community discussions: Reddit | Quora

Better information creates better decisions. Better decisions create better systems. Better systems give physicians more time to care.


Professional Note

This article is intended for education, commentary, and professional discussion. It does not provide individualized medical, legal, financial, coding, or regulatory advice. Healthcare organizations should consult qualified professionals and authoritative guidance before implementing changes affecting clinical care, reimbursement, privacy, or compliance. Illustrative examples are not representations of actual OnnX customer outcomes.


References and Further Reading

1. CMS: Calendar Year 2027 Medicare Physician Fee Schedule Final Rule

Outlines changes to Medicare physician reimbursement, coding requirements, remote monitoring, and payment policies. Essential context for understanding how evolving regulations affect revenue cycle management and independent practice operations.

2. CMS Finalizes CY 2027 Physician Fee Schedule to Shift from Sick Care to Healthcare and Curb Waste

Explains CMS's policy direction toward preventive care, payment accountability, and reducing unnecessary healthcare spending, reinforcing the need for efficient and accurate administrative processes.

3. CMS Issues CY 2027 Physician Fee Schedule Final Rule

Provides an industry perspective on Medicare payment changes and their implications for healthcare organizations, physician practices, and operational planning.

4. Your Billing Denial Has a Plot Twist: The Problem May Have Started Before the Claim Existed

Explores how upstream data errors, fragmented workflows, and information loss can create billing failures long before claims are submitted. Extends the article's argument that prevention begins with trustworthy information.

5. The Denial Isn't the Problem. It's the Clue.

Reframes claim denials as signals of deeper operational weaknesses. Examines denial patterns, root-cause analysis, and opportunities to shift from reactive recovery toward proactive prevention.

6. Anthropic Wants More AI Regulation. Physicians Should Be Asking Why.

Examines AI governance, physician accountability, transparency, and regulatory oversight, highlighting why healthcare organizations must evaluate more than efficiency when adopting intelligent systems.


#HealthcareAI #MedicalBilling #RevenueCycleManagement #DenialPrevention #IndependentPractice #PhysicianEntrepreneur #HealthcareInnovation #HealthcareTechnology #MedicalPracticeManagement #HealthcareData #PhysicianLeadership #ClinicalDocumentation #HealthcareAutomation #PracticeManagement #HealthInformatics

 

Wednesday, November 4, 2026

Healthcare Doesn't Have an AI Problem. It Has an Information Problem. And Your Billing Department Is Paying for It.

The uncomfortable truth about medical billing, healthcare data, artificial intelligence, and why independent medical practices keep paying for problems that should have been prevented upstream.

 


“Better is possible. It does not take genius. It takes diligence. It takes moral clarity. It takes ingenuity. And above all, it takes a willingness to try.” — Dr. Atul Gawande, surgeon and author


The Broken Wrist That Broke the Billing System

A patient walks into a medical practice with a fractured wrist.

The physician examines the patient, confirms the diagnosis, applies a cast, documents the encounter, and completes the treatment.

The biller enters the appropriate procedure code.

The claim goes out.

The clinic gets paid.

That is how it should work.

Except it doesn't always work that way.

The insurance information might be outdated. The eligibility check might never have happened. The diagnosis might be buried in a paragraph instead of entered into the appropriate structured field. An authorization might be missing. A modifier might have been overlooked.

Now the biller is investigating.

The physician is being interrupted.

The office manager is calling the insurance company.

Someone is searching through old documentation.

And the claim that should have taken minutes to prepare becomes a small administrative crime scene.

Here is the interesting part.

The fracture was treated correctly. The billing problem may have started before the patient ever entered the examination room.

Think about that.

We can diagnose a broken bone, take an X-ray, apply a cast, and send the patient home. Yet the administrative machinery responsible for getting the practice paid can struggle to establish whether the insurance information was correct.

We have sophisticated medical technology.

We have electronic health records.

We have cloud computing.

We have artificial intelligence.

But sometimes the person responsible for collecting payment still needs to ask Susan what happened to the authorization.

If Susan is on vacation, apparently the technology is on vacation, too.

That is not a technology strategy.

That is institutional amnesia with a software subscription.

The problem with healthcare automation is that we keep making the wrong things faster.

And independent physicians are paying the price.


The Real Healthcare AI Debate Nobody Wants to Have

The healthcare industry is excited about artificial intelligence.

Every week, someone announces another AI platform.

AI coding. AI documentation. AI eligibility. AI prior authorization. AI denial prediction. AI revenue cycle management.

The promises are impressive.

Fewer employees. Faster claims. Lower administrative costs. Higher collections.

But there is a question that deserves more attention:

What happens when you automate a process that is already working with inaccurate information?

You do not necessarily eliminate the problem.

You may simply distribute it faster.

Imagine giving a medical biller an AI system that can process 10,000 claims instead of 1,000.

Sounds wonderful.

But what if the patient identities are wrong?

What if the insurance information is outdated?

What if the clinical documentation is incomplete?

What if the system interprets a physician's narrative incorrectly?

Congratulations. You have successfully automated confusion.

The healthcare industry often approaches AI as if the primary problem is insufficient computing power.

I would argue that the more fundamental problem is insufficient information discipline.

Healthcare does not need more intelligence applied to information it cannot trust. It needs better information before intelligence is applied.

This is where the debate becomes interesting.

Should medical practices first build standardized, structured data systems before deploying AI?

Or should they use AI immediately to clean the incomplete and inconsistent information they already have?

Both arguments have merit.

But neither tells the whole story.

For independent practices, waiting for perfect infrastructure is unrealistic.

Deploying AI without validation is irresponsible.

The answer is not choosing one technology over another.

It is understanding what each technology should be allowed to do.


The First Mistake: Confusing More Data With Better Data

Healthcare produces enormous amounts of information.

Physicians document symptoms, examination findings, diagnoses, treatment plans, prescriptions, and follow-up instructions.

Laboratories generate results.

Imaging departments produce reports.

Insurance companies generate eligibility responses, authorization requirements, remittance information, and claim decisions.

Electronic health records collect much of this information.

Yet collecting information and making it useful are two different things.

Consider a typical medical encounter.

The physician documents the patient's condition in a SOAP note.

The biller needs the appropriate diagnosis and procedure information.

The insurance company needs the information required to adjudicate the claim.

The practice management system needs the information to support the revenue cycle.

The problem is that these systems may not interpret or exchange information consistently.

One system contains a narrative.

Another expects a structured field.

A third expects a specific code.

The information exists, but the connections are missing.

This is a crucial distinction.

Data availability is not data usability. Data usability is not data accuracy. And data accuracy is not automatically clinical validity.

These are different problems.

Healthcare organizations frequently treat them as if they were interchangeable.

They are not.


The Two Competing Schools of Thought

 

Argument One: Standardize the Data Before Introducing AI

This position begins with a reasonable assumption.

A computer system needs consistent information to perform reliable operations.

Healthcare data comes from different systems, formats, and terminology standards.

The same patient may appear under different names.

The same clinical concept may be represented differently.

The same insurance requirement may be stored in a different location depending on the software.

One solution is FHIR, or Fast Healthcare Interoperability Resources, developed by HL7.

FHIR provides a standardized framework for exchanging healthcare information.

It defines resources representing information such as:

  • Patients.
  • Conditions.
  • Observations.
  • Medications.
  • Procedures.
  • Encounters.
  • Diagnostic reports.

FHIR can improve interoperability by giving different systems a common way to represent and exchange information.

But there is a catch.

Standardizing incorrect information does not make it correct.

If a patient's date of birth is wrong, a perfectly formatted FHIR resource can still contain the wrong date of birth.

If the physician never documented a required clinical finding, FHIR cannot magically create it.

If an insurance policy is inactive, a standardized data structure cannot make it active.

Standards improve consistency.

They do not replace verification.

Another important concept is policy as code.

Instead of asking employees to remember every payer requirement, organizations can translate defined rules into machine-readable instructions.

For example, a system can check whether:

  • Required patient information is present.
  • Insurance coverage has been verified for the date of service.
  • A required authorization is recorded.
  • A claim contains required information.
  • A known payer-specific requirement has been addressed.
  • A particular coding combination requires review.

The benefit is straightforward.

Instead of discovering every problem after submission, the system can identify many problems before submission.

That is meaningful progress.

But there is a potential downside.

What happens when the system encounters a field that is blank because the physician never entered the information?

The system can stop the workflow.

But stopping a workflow is not the same as solving the problem.

The biller still needs the information.

The physician still needs to be contacted.

The patient may still be waiting.

A system that identifies every problem but cannot help resolve any of them is not intelligent automation. It is an electronic hall monitor.

 

 

Argument Two: Use AI to Clean the Data That Already Exists

The second position is more practical for many independent practices.

Most small and medium-sized clinics cannot afford to replace their entire technology infrastructure.

They already have years of clinical documentation, scanned records, inconsistent patient information, and fragmented administrative workflows.

Waiting for a perfect data environment means waiting indefinitely.

This is where targeted AI becomes useful.

Natural language processing can identify information in clinical notes.

Document intelligence can extract information from insurance cards and scanned forms.

Entity-resolution algorithms can identify potentially duplicated patient records.

Machine learning can flag unusual patterns and inconsistent information.

AI can also help organize tasks, identify missing documentation, and direct exceptions to the appropriate employee.

Consider a physician's SOAP note.

The physician documents the patient's symptoms, examination, assessment, and treatment plan.

The information exists.

But it may not be available in the structured format another system needs.

Natural language processing can extract candidate information and organize it into structured fields.

This can reduce repetitive manual work.

However, there is an important distinction:

Extracting information is not the same as verifying information.

An algorithm can identify a diagnosis mentioned in a note.

It cannot automatically determine that the diagnosis is appropriate for every billing purpose.

It can identify a missing blood pressure.

It cannot establish what the patient's blood pressure actually was.

It can suggest that two records belong to the same person.

It cannot safely merge every similar-looking record without considering the consequences.

AI should help people find information.

It should not manufacture reality.


My Position: Stop Treating This as an Either-Or Decision

The two approaches are not enemies.

They solve different parts of the problem.

AI helps organize messy information.

Standardization makes information more consistent.

Validation checks whether defined requirements are satisfied.

Human review resolves uncertainty.

Audit trails preserve accountability.

The sequence should be practical:

Extract. Organize. Validate. Reconcile. Escalate. Automate.

Start with the information already available.

Use AI to identify what is missing or inconsistent.

Apply deterministic rules to what can be verified.

Ask humans to resolve ambiguous or consequential decisions.

Preserve the source and history of important information.

Then gradually improve the underlying data infrastructure.

Independent practices do not need to build a technology empire before benefiting from automation.

They need a sensible starting point.


Five Healthcare Data Problems Hiding Inside Medical Billing

 

1. The Missing Information Problem

A physician documents an examination in a narrative note.

The biller needs a particular piece of information to complete the claim.

The information may exist in the narrative, but not in the structured field.

The biller searches.

The physician is contacted.

The claim is delayed.

This is not necessarily a coding problem.

It may be an information extraction and workflow problem.

The information was recorded, but the system failed to make it useful at the right moment.

 

2. The Duplicate Patient Problem

Consider John Smith and Jonathan Smith Jr.

One record lists an abbreviated name.

Another includes a middle name.

The addresses are formatted differently.

The phone numbers may have changed.

Are they the same patient?

Sometimes yes.

Sometimes no.

An overly aggressive matching algorithm can merge two different people.

A poorly designed system can maintain two records for the same person.

Both situations create risk.

AI-powered entity resolution can compare multiple attributes and identify possible matches.

But uncertain matches require appropriate review.

Patient identity is not a guessing game. A mistaken match can become a clinical problem, not merely an administrative inconvenience.

 

3. The Eligibility Problem

A patient presents an insurance card.

The staff enters the information.

The system shows an insurance company.

Everyone assumes coverage is active.

But the patient may have changed plans.

The policy may have terminated.

The benefits may not cover the intended service.

The practice should verify the appropriate coverage for the relevant date and service.

An insurance card is evidence of an insurance relationship.

It is not proof of current eligibility.

 

4. The Authorization Problem

A physician orders a service.

The practice assumes authorization is not required.

The appointment is scheduled.

The service is performed.

The claim is submitted.

Then the payer identifies a missing authorization.

Now everyone is looking for the person who was supposed to check.

This is why prior authorization should be treated as a trackable workflow, not a phone call that disappears into someone's notebook.

A useful system should record:

  • Whether authorization is required.
  • Which payer rule applies.
  • What documentation is needed.
  • Who owns the request.
  • When it was submitted.
  • Whether additional information was requested.
  • Whether approval was received.
  • Whether the authorization applies to the intended service and date.

An authorization that exists only in someone's memory is not a reliable authorization-management process.

 

5. The Denial Problem

A denial arrives.

The biller investigates.

The original encounter occurred weeks earlier.

The person who entered the information may have forgotten the details.

The physician has moved on.

The relevant documentation is buried somewhere.

The biller must reconstruct the event.

This is where the revenue cycle becomes reactive.

The practice is not managing information.

It is investigating history.

And that brings us to one of the most important principles in healthcare administration:

The denial is the crime scene, not necessarily the crime.

The original mistake may have occurred at registration, eligibility verification, documentation, authorization, or coding.

Treating the denial as the beginning of the problem is like treating a fever without asking why the patient has an infection.


Three Expert Perspectives Worth Remembering

These are perspectives drawn from published work and current health IT policy, not personal endorsements of OnnX.

 

1. Dr. Atul Gawande: Better Systems Beat Heroic Workarounds

Dr. Atul Gawande, surgeon, author, and public-health researcher, has written extensively about the importance of systems, checklists, teamwork, and disciplined execution.

His book The Checklist Manifesto challenges the assumption that expertise alone can overcome complexity.

The lesson applies directly to medical billing.

A practice should not depend on one exceptionally experienced biller remembering every payer's requirements.

It should build systems that preserve knowledge and make important steps visible.

The best employees should not have to rescue the same broken process every Monday morning.

Takeaway: Do not build a business around people repeatedly compensating for preventable system failures.

 

2. Dr. Tom Keane: Technology Regulation Should Support Practical Innovation

Dr. Tom Keane, National Coordinator for Health Information Technology, has discussed the need to reduce unnecessary technology development burdens while supporting innovation.

The October 26, 2026 HTI-5 final rule reflects this direction by revising and removing selected requirements in the ONC Health IT Certification Program.

The broader question for independent physicians is whether technology becomes more usable, affordable, and interoperable.

A smaller practice does not need another complicated system that requires additional employees to operate.

It needs technology that reduces work.

Takeaway: Technology should make healthcare operations easier, not create another department to manage.

 

3. Steven Posnack: Interoperability Must Make Information Useful

Steven Posnack, a health IT policy leader at ONC, has contributed to federal work on health information exchange, interoperability, and standards.

The broader interoperability challenge is not simply transmitting information.

It is ensuring that receiving systems can interpret and use that information appropriately.

A record that arrives without sufficient context can create more work.

A duplicated patient identity can create confusion.

A prior authorization response that cannot be connected to the correct encounter may not solve the administrative problem.

Takeaway: Data exchange is only the beginning. The information must support an actual decision or action.

These perspectives point toward the same conclusion.

Better healthcare technology is not measured by how much information it processes. It is measured by how much unnecessary work it eliminates without compromising accuracy.


The Statistics: Impressive Numbers Do Not Automatically Mean Better Healthcare

Healthcare technology discussions often feature enormous statistics.

Some estimates suggest that healthcare generates approximately 30% of the world's data. Industry reports also frequently describe rapid growth in healthcare data volumes.

These numbers are interesting.

But here is a more important question:

How much of that information can a physician or biller actually use when a decision needs to be made?

The volume of data does not tell us whether it is accurate.

The number of automated transactions does not tell us whether they were completed correctly.

The number of claims processed does not tell us whether the practice collected the money it was entitled to receive.

For independent practices, I would focus on these measurements:

First-pass claim acceptance: How many claims pass initial submission without rejection?

Denial rate: What percentage of submitted claims are denied?

Days in accounts receivable: How long does it take to collect outstanding payments?

Eligibility accuracy: How often does recorded insurance information match verified coverage?

Authorization completion: How frequently is required authorization obtained before the service?

Manual rework hours: How much time do employees spend correcting avoidable problems?

Exception resolution time: How long does it take to resolve incomplete or conflicting information?

Data accuracy: How often does recorded information match the verified source?

Here is the point.

A software company may proudly report that its system processed one million transactions.

I would rather know how many transactions required no human correction.

Throughput is not productivity when the output is wrong.


Recent News: Healthcare Technology Is Changing. Are Medical Practices Ready?

The timing of this discussion matters.

Healthcare technology policy is evolving, and independent practices should pay attention.

 

October 26, 2026: HHS Finalizes the HTI-5 Rule

The Department of Health and Human Services announced the HTI-5 final rule, which revises the ONC Health IT Certification Program.

The government projects more than $1.5 billion in regulatory cost savings for health IT developers.

The rule removes 14 of 60 certification criteria and revises seven.

This is an important development because it changes the regulatory environment for health IT developers.

But physicians should ask a more practical question:

Will these changes lead to more affordable, usable, and interoperable technology for independent practices?

That remains to be demonstrated.

Reducing developer compliance burdens does not automatically reduce a clinic's administrative workload.

 

October 29, 2026: Healthcare Stakeholders Examine the HTI-5 Implications

The American College of Cardiology published an analysis of the final rule and its implications for health IT certification.

One issue deserves particular attention: changes to requirements concerning the reporting of information about AI-enabled health IT capabilities.

For physicians, the broader lesson is that innovation and transparency must remain in balance.

A practice should understand what an AI system is intended to do, where it may fail, and when human review is required.

Removing regulatory requirements does not remove the need for responsible purchasing decisions.

 

January 1, 2027: A Major Interoperability Milestone Approaches

CMS established implementation requirements for certain impacted payers under the 2024 Interoperability and Prior Authorization final rule.

Beginning in 2027, applicable payers must implement specified APIs, including Provider Access, Payer-to-Payer, and Prior Authorization APIs, according to their applicable compliance dates.

The goal is to improve access to information and reduce administrative friction.

For medical practices, this creates an opportunity to reconsider how eligibility, authorization, and payer communication are managed.

But do not confuse an API with an operational solution.

An electronic connection can move information.

It cannot guarantee that the information is accurate, complete, or acted upon.

The next competitive advantage will not simply be connecting systems. It will be making connected information useful.


Seven Mistakes Medical Practices Should Stop Making

1. Buying AI before identifying the problem.

A vendor promises to automate everything.

But if the biggest problem is eligibility, purchasing an AI coding product may not help.

Identify the bottleneck first.

2. Assuming AI can fill in every missing field.

AI can locate information and flag missing values.

It should not invent clinical measurements, diagnoses, or treatment details.

3. Treating a complete record as an accurate record.

A database with every field populated can still contain incorrect information.

Completeness and accuracy must be measured separately.

4. Assuming FHIR automatically fixes interoperability.

FHIR provides standards for exchanging information.

It does not eliminate poor mapping, incorrect source data, or incompatible workflows.

5. Automating unnecessary steps.

If a workflow is inefficient, automation may simply make the inefficiency faster.

Redesign the process before automating it.

6. Depending on one employee's memory.

If only one person knows how to resolve a particular payer problem, the practice has a knowledge-management problem.

Preserve the process.

7. Measuring software activity instead of financial outcomes.

More automated transactions do not necessarily mean more collected revenue.

Measure the results.


A Practical Eight-Step Plan for Independent Practices

You do not need a multimillion-dollar technology project.

Start with the problems you already know exist.

Step 1: Map the revenue cycle.

Document the entire patient journey, from registration to payment.

Identify every handoff.

Ask where information gets lost or repeatedly entered.

Step 2: Find the recurring failures.

Review recent claims and identify the most common reasons for rework.

Do not rely exclusively on employee opinions. Examine actual claim and operational data.

Step 3: Establish a baseline.

Measure denial rates, first-pass acceptance, eligibility errors, accounts receivable aging, and manual rework.

You need a starting point.

Step 4: Introduce targeted automation.

Start with repetitive tasks such as insurance information extraction, eligibility monitoring, document classification, and missing-field detection.

Step 5: Use AI to organize unstructured information.

Apply appropriate natural language processing and document intelligence to identify relevant information in clinical notes and supporting documents.

Preserve the original source.

Step 6: Add validation rules.

Use deterministic rules to check required information, dates, known payer requirements, and coding consistency.

Distinguish between errors and issues requiring review.

Step 7: Create an exception-management process.

Every unresolved problem needs an owner.

The system should show what is missing, who is responsible, and what must happen next.

Step 8: Review the results monthly.

Compare actual performance with the baseline.

If the technology saves time, reduces errors, and improves collections, expand it.

If it creates additional work, reconsider the implementation.

The objective is measurable improvement.

Not another software subscription.


Legal Implications: AI Does Not Become the Responsible Party

A common misconception is that using an AI vendor transfers responsibility for billing accuracy and compliance.

It does not.

Medical practices must consider applicable federal and state requirements.

 

HIPAA

If a technology vendor creates, receives, maintains, or transmits protected health information on behalf of a covered entity, the vendor may qualify as a business associate.

An appropriate business associate agreement may be required.

Practices should examine:

  • Data access.
  • Permitted uses.
  • Encryption.
  • Security controls.
  • Audit trails.
  • Retention and deletion.
  • Breach notification.
  • Subcontractor arrangements.

 

Billing and Documentation Integrity

AI-generated recommendations must not be treated as established clinical facts.

The submitted claim must be supported by the applicable documentation and billing requirements.

Physicians should not approve unsupported diagnoses simply because an algorithm suggests them.

 

False Claims Exposure

Incorrect claims and unsupported billing can create exposure under applicable federal and state laws.

The specific legal consequences depend on the facts, applicable rules, and circumstances.

AI does not provide immunity.

 

California Privacy Requirements

California practices should also evaluate applicable state privacy and security requirements, including the California Confidentiality of Medical Information Act where applicable.

Qualified legal and compliance professionals should review higher-risk implementations.

Automation changes how work is performed. It does not eliminate professional responsibility.


Ethical Considerations: Patients Are Not Data Points

There is something dangerous about treating healthcare information as if it were just another business dataset.

A patient is not a spreadsheet row.

A duplicate record is not merely a database inconvenience.

A missing clinical value is not an invitation to estimate.

An incorrect identity match can have consequences far beyond reimbursement.

Responsible healthcare AI requires:

  • Accuracy.
  • Privacy.
  • Transparency.
  • Fairness.
  • Accountability.
  • Human oversight.

The system must be able to distinguish between verified information, extracted information awaiting confirmation, and an algorithmic suggestion.

That distinction should never disappear simply because automation is convenient.

The purpose of AI in healthcare should be to reduce administrative friction, not to introduce a new source of clinical uncertainty.


Myth Busters: Five Things Healthcare Technology Vendors Should Explain

Myth 1: AI eliminates medical billing errors.

Reality: AI can identify patterns and prevent certain errors, but it cannot guarantee that source information is correct or that every payer decision will be favorable.

Myth 2: More data means better decisions.

Reality: More data without context can create more confusion.

Myth 3: FHIR solves all interoperability problems.

Reality: FHIR improves data exchange. Accurate mapping, validation, implementation, and workflow integration are still necessary.

Myth 4: AI can safely repair every incomplete record.

Reality: AI can identify missing information and locate potential sources. It should not manufacture clinical facts.

Myth 5: Medical billing is simply a coding problem.

Reality: Billing is the final stage of a much larger operational process involving registration, eligibility, authorization, documentation, coding, claim submission, and payment.

The fifth myth is perhaps the most expensive.

Because when practices treat billing as an isolated department, they often ignore the upstream problems creating the downstream workload.


The OnnX Perspective: Stop Fixing the Same Problem Twice

This is where my perspective as a physician-entrepreneur and founder of OnnX comes in.

OnnX is built by a physician and a medical biller.

That combination is intentional.

Medical billing is not simply a software problem.

It requires understanding clinical documentation, payer requirements, administrative workflows, coding, reimbursement, and the realities of operating an independent medical practice.

I have seen how much operational knowledge can become concentrated in a few experienced employees.

They know which payer requires what.

They remember which authorization is pending.

They know which claims need attention.

They understand why a particular account has been sitting in accounts receivable for weeks.

But what happens when they leave?

The knowledge leaves with them.

The practice starts asking the same questions again.

Who handled this?

Was authorization obtained?

Did we receive the documentation?

Why was this claim rejected?

What did the payer say last time?

That is not institutional knowledge.

That is institutional memory loss.

A business should not depend on someone remembering what the system should have remembered.

The OnnX philosophy is built around a different way of thinking.

Instead of treating each claim as an isolated transaction, we believe the entire revenue cycle should be understood as a connected operational process.

Patient information affects eligibility.

Eligibility affects authorization.

Authorization affects the encounter.

The encounter creates documentation.

Documentation supports coding.

Coding supports the claim.

The claim produces a payer response.

Payment and denial information should inform the next action.

Every stage is connected.

The technology should understand those connections.


From Data to Workflows to Revenue

Our central philosophy is:

Data → Workflows → Revenue

First, capture and organize information.

Second, connect that information to the correct workflow.

Third, make sure the work reaches an appropriate outcome.

This means moving beyond software that simply displays information or generates recommendations.

A useful system should help answer:

  • What information is available?
  • What information is missing?
  • Which requirement applies?
  • What has already been completed?
  • What remains unresolved?
  • Who owns the next action?
  • What happened to the claim?
  • What should happen next?

It should preserve the history of important actions.

It should identify exceptions.

It should reduce unnecessary handoffs.

It should make work traceable.

Most importantly, it should help independent practices operate without depending on unnecessary intermediaries.

The goal is not to replace experienced billers with algorithms. It is to stop wasting experienced billers' time on preventable administrative problems.

That is a very different proposition.


What the Future of Medical Billing Should Look Like

I believe the next generation of medical billing technology will be defined by several developments.

 

Intelligent Workflow Orchestration

Instead of automating isolated tasks, systems will coordinate connected workflows.

A missing authorization should trigger a defined process.

An incomplete claim should create an actionable exception.

A payer response should update the relevant account.

An unresolved task should remain visible until someone addresses it.

 

Predictive Compliance Monitoring

Systems will increasingly identify potential documentation and payer-rule problems before claims are submitted.

But predictions must remain distinguishable from verified facts.

 

Better Interoperability

FHIR and related standards will continue to influence how healthcare information is exchanged.

The opportunity is to connect systems without forcing small practices to manage increasingly complicated administrative infrastructure.

 

Privacy-Preserving Analytics

Federated learning and other privacy-preserving approaches may allow organizations to develop insights without centralizing all underlying patient information.

However, privacy protection still requires careful technical and organizational controls.

 

Auditable AI

The next generation of AI should be able to demonstrate:

  • What information it accessed.
  • What it extracted.
  • What it recommended.
  • What action it performed.
  • What information it changed.
  • When human review occurred.
  • Whether the intended outcome was achieved.

An AI system should not simply tell us what it did. It should leave enough evidence for us to verify what it did.

That is how trust is built.


Final Thoughts: The Most Expensive Mistake May Be the One Nobody Notices

Let's return to the patient with the fractured wrist.

The physician did the examination.

The diagnosis was documented.

The treatment was completed.

The patient went home.

But the claim did not get paid on time.

Somewhere in the process, information failed to connect.

Maybe eligibility was not verified.

Maybe the authorization was missing.

Maybe the documentation was incomplete.

Maybe the biller had to reconstruct the encounter.

The practice spent time and money correcting something that could have been prevented.

And tomorrow, another patient will arrive.

Another claim will be submitted.

Another employee will search through another chart.

Unless the underlying process changes, the same problem will happen again.

Here is the contrarian argument:

Healthcare does not need to become better at fixing billing mistakes. It needs to become better at preventing the information failures that create them.

We should stop celebrating how quickly we can process claims and start asking why so many claims require intervention in the first place.

We should stop treating denial management as the primary solution and start examining what happened before the denial.

We should stop building technology around isolated transactions and start building systems around connected information and accountable workflows.

And we should stop confusing artificial intelligence with operational intelligence.

AI is a tool.

Data is the foundation.

Workflows are the machinery.

Revenue is the result.

At OnnX, we believe independent medical practices deserve technology that helps them retain control, reduce unnecessary administrative friction, and operate with greater financial predictability.

Because physicians did not spend years learning medicine to become full-time insurance investigators.

And medical billers should not spend their days searching for information that the system should have preserved.

The future of medical billing will not be won by whoever automates the most steps. It will be won by whoever eliminates the most unnecessary steps.


Get Involved: Help Change the Conversation

I want to hear from physicians, clinic owners, practice administrators, and medical billers.

Here is the question: If you could eliminate one recurring problem in your practice tomorrow, would you choose eligibility verification, prior authorization, documentation gaps, claim denials, or the disconnected systems that create all four?

Share your experience in the comments.

What is the one administrative problem that consumes the most time in your practice without adding value to patient care?

And if this perspective challenges how you think about healthcare technology, share the article with another physician or practice owner.

The conversation should not be limited to software developers and hospital executives.

Independent practices deserve a voice in shaping the future of healthcare technology.

Better information. Better workflows. More predictable revenue.

That is a movement worth building.

If you agree, consider reposting this article to help more independent physicians and clinic owners join the conversation.

PS: A complimentary resource is available in the Featured section of my LinkedIn profile. No registration or email signup is required. Explore it, share your thoughts, and help move the conversation forward.


About the Author

Dr. Daniel Cham, MD, is a physician-entrepreneur, medical consultant, and founder of OnnX, an AI-powered medical billing SaaS platform designed for small and medium-sized medical practices.

His work focuses on the intersection of clinical operations, healthcare technology, medical billing, and practice management.

Drawing on experience in medicine and medical billing, he examines how better information, intelligent automation, and accountable workflows can help independent physicians reduce administrative friction and build more sustainable practices.

His philosophy is simple: healthcare technology should solve problems, preserve institutional knowledge, and give physicians greater control over their practices.


Disclaimer

This article provides general educational and informational perspectives on healthcare technology, clinical data management, artificial intelligence, and medical billing. It does not constitute medical, legal, coding, or regulatory advice. Requirements vary by jurisdiction, payer, organization, and individual circumstances. Consult appropriately qualified professionals before making clinical, legal, compliance, or operational decisions.


Continue the Conversation

Healthcare is changing. The challenges facing independent medical practices are changing with it.

Explore more practical insights, thoughtful discussions, and behind-the-scenes perspectives on healthcare management, medical billing, technology, and innovation.

Continue learning and connect through these platforms:

Connect: LinkedIn | Website | YouTube| Spotify

Knowledge creates progress. Curiosity challenges convention. Better information creates better decisions. Keep learning, keep questioning, and help shape the future of independent healthcare.


References and Further Reading

1. The Denial Isn’t the Problem. It’s the Clue. — Why billing denials often reveal upstream information and operational failures.

2. Your Medical Billing Problem May Not Be a Billing Problem: The Hidden Cost of Creating Work You Should Never Have to Do — How fragmented information creates unnecessary administrative work and financial losses.

3. The Cheapest Claim Is the One You Never Have to Fix — Why upstream intelligence and prevention are more valuable than downstream claim correction.

4. Atul Gawande: A Conversation About Better Healthcare Systems — Systems thinking, diligence, and the importance of improving how healthcare work is performed.

5. HHS Finalizes HTI-5 Deregulatory Rule — The October 2026 federal action to streamline the Health IT Certification Program.

6. HTI-5 Final Rule: What It Means for Health IT — Industry analysis of changes to certification requirements, transparency, and AI-related provisions.

7. ONC HTI-5 Final Rule — Official information on the revised certification framework and FHIR-based interoperability direction.


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