Latest / Technically Sound Strategy / Episode 50 - AI and HIPAA Compliance With Steve Goulet
Transcript
- 0:01Welcome back to Legal Marketing Radio.
- 0:03Today we're talking about AI and HIPAA compliance.
- 0:07One of the biggest tension points in regulated industries.
- 0:09Right now.
- 0:11Joining me is Steve Goulet, a healthcare technology executive.
- 0:13With over 20 years of experience leading digital health transformations
- 0:17and building AI systems at scale, we're getting into what firms need
- 0:22to understand about risk governance and how to actually use AI without
- 0:26creating compliance problems.
- 0:29Let's dive in.
- 0:34Steve, it is great to have you on the show here.
- 0:36We've been working together for a little while now, and I've really
- 0:39enjoyed getting to have a window into the way that you think and the way
- 0:44that you approach AI building tools.
- 0:47You've introduced me to some new technologies that I've found really
- 0:50exciting that I'm still learning especially around the Lang.
- 0:54Bucket and category.
- 0:57But I've really enjoyed our conversations.
- 0:58The things that you've exposed me to, gets me thinking about how we build new things.
- 1:02But I know in your role you have to deal with a lot of compliance.
- 1:06And I think for the folks that tend to listen to our podcast,
- 1:11it's an area they're dealing with and trying to figure out as well.
- 1:13So marrying AI and trying to navigate the complexity of the world of compliance.
- 1:21It's something that, obviously there's a lot of challenges there.
- 1:24We wanna stay at the front of the pack in terms of technology.
- 1:27So if you don't mind just give us a quick, give us some insight into
- 1:32a little bit of your background and and how you're approaching,
- 1:36how you're approaching that topic.
- 1:39Thanks, chip.
- 1:39Will do.
- 1:40I'm glad to be here.
- 1:42And yes, Avi is at the center.
- 1:46Of the the meeting between AI and compliance.
- 1:50We do a lot of work and I lead the teams.
- 1:55That do work with AI and healthcare, mental healthcare related work.
- 2:01Some of the guiding principles that we follow are that for one
- 2:07thing, AI should never be used to do the work of a clinician that
- 2:15involves making a medical decision.
- 2:20You may find that various chat clients that you use like chat, GPT
- 2:25or Claude, seem to cross that line sometimes, but what's become very
- 2:31clear is that the regulatory landscape in healthcare is not on the same page
- 2:39and that folks like us that deliver.
- 2:43Solutions that are customer facing, patient facing, we need to be very
- 2:49careful not to cross that line.
- 2:51So very interested in talking through that with you and digging
- 2:56deeper into those details.
- 2:59Again I lead a product team, a tech team, a analytics team, and
- 3:06let's see, who else An IT team.
- 3:08And each of those teams we touch ai, we use.
- 3:12Operational ai, things like cloud and chat, GBT On the clinical side, we have
- 3:20ambient listening, listening scribes that use our are integrated into our EHR.
- 3:27And that our listening to patient clinician interactions and then
- 3:33taking notes on those interactions.
- 3:36We have a support bot, custom AI that we wrote and delivered ourselves
- 3:44that handles our public website, our Zendesk support portal, our patient
- 3:51portal, etc. And that AI does a ton of heavy lifting in terms of helping our
- 3:58patients navigate our systems, so it's supporting their journey basically.
- 4:05And then we also do quite a bit of integrations on the operational
- 4:11side with other systems.
- 4:13We, it took us a while to get there but we have an enterprise agreement
- 4:18now with Anthropic, so we're in a good place where we have a, BAA with
- 4:22them and we're able to use that.
- 4:25BAA to leverage connectivity between Claude and other systems.
- 4:30So whole bunch of talk about really looking forward to it.
- 4:33Thanks for having me.
- 4:35That's cool.
- 4:35And that's, it raises a really good point.
- 4:38And I think our perspective always comes into the picture because when I think
- 4:41of Avi and having known a lot of folks there for some time, I always think
- 4:45of AVI as an AI forward organization.
- 4:48And a lot of the clients that we work with, especially on the legal
- 4:50side their heart and soul is the work that they do, as attorneys and
- 4:55as professional service providers.
- 4:58And I think you, you thread that needle really well.
- 5:02In using a suite of tools to help get that job done and make the people who
- 5:10are doing that job more effective without those tools actually doing the job.
- 5:16Exactly.
- 5:17And
- 5:18that's the trick.
- 5:19Yep.
- 5:20Yeah.
- 5:21And that's Interesting.
- 5:21It, the way you say it, it almost sounds like you're surrounding the, you're
- 5:25surrounding the service providers, you're surrounding the clinicians.
- 5:29With all the tools that they need to effectively do their job, but the
- 5:34clinician is needed to do the job.
- 5:37Exactly.
- 5:38You use the key word that I try to emphasize when discussing
- 5:43this, it's the word tool.
- 5:45And the other phrase that comes to mind a lot is human in the loop, right?
- 5:50So we want to use AI as a tool, and we always want to have a human in the loop.
- 5:57If that tool is going to encroach.
- 6:01On that line between decision making or tool, right?
- 6:08So is if the AI is gonna make a clinical decision, that's when
- 6:13we know we've gone too far.
- 6:15Now, can it make a recommendation?
- 6:18Have that recommendation be vetted by a clinician.
- 6:21Absolutely.
- 6:23That's the key, right?
- 6:24You can't cross that line into an independent AI that might be, and
- 6:31of course, hallucinations happen, hopefully less and less, although
- 6:34there's been some recent research that they probably will never go away.
- 6:39But happening less and less, but still.
- 6:42Until we can say there's never hallucination, folks like the
- 6:46FDA and other regulators are never gonna say, okay, just let
- 6:50your ai make clinical decisions.
- 6:52It's good.
- 6:53It might make a mistake, but that's okay.
- 6:55Heck no.
- 6:56That's not gonna happen.
- 6:58Yeah, that's exactly it.
- 7:00That makes sense.
- 7:01So how Did you get started down this path?
- 7:03, What were your first couple of steps.
- 7:05That's a big undertaking, right?
- 7:07Absolutely.
- 7:08So we earned our stripes early on by creating a AI infrastructure
- 7:15internally that we could use to implement safe and compliant AI systems.
- 7:23So the first thing we envisioned was if we're going to build AI patient facing ai.
- 7:30We need to monitor it very carefully.
- 7:33You mentioned the laying stack and for our listeners who haven't heard of
- 7:38that, it's also known as Laying Chain.
- 7:41And early on we identified a number of tools in that stack that we could
- 7:46use for observability and monitoring.
- 7:50'cause when you implement AI and you deliver it to anyone in a
- 7:55regulatory regulated environment.
- 7:58You need to make absolutely sure that it's auditable and observable and can
- 8:04be maintained and adjusted according to any sort of findings that result from
- 8:11that auditing and observing activity.
- 8:14We're using one of the Lang tools.
- 8:18It's actually not part of the Lang chain stack.
- 8:21It's another one.
- 8:22Called Laying Fuse.
- 8:24But that thing is very powerful and we can see every single
- 8:28conversation, every single response.
- 8:32We can trace every step that the AI system takes.
- 8:36It's a complicated application.
- 8:38We use it.
- 8:39I mentioned Human in the Loop a minute ago.
- 8:42Our AI support system allows users.
- 8:47To ask for help from our support team, the human beings on our support team.
- 8:53So if the AI conversation brings our, one of our users in one of those chats
- 8:59to a point where they're like, okay, I just, I need to talk to somebody.
- 9:03They can ask, talk to a human.
- 9:05We make that absolutely clear from the beginning of the chat.
- 9:09We also remind them that, we have regulatory rules in place and that.
- 9:15You, we, you have to make it absolutely clear that they're
- 9:17talking to an AI when they are.
- 9:20And then when we hand back and forth between the AI bot and the human
- 9:26who can jump in and help with the conversation, we have to make it clear
- 9:31who's who they're talking to as well.
- 9:34All of those steps.
- 9:36Are critical to maintaining a safe and compliant workflow for your ai.
- 9:42So we built our base tech stack, AI tech stack around those assumptions, right?
- 9:50We need observability and we also did not want to use third party vendors.
- 9:57If at all possible.
- 9:58Why?
- 9:59Because the more data, if you're collecting, say you're collecting
- 10:04chat transcripts between patients and your ai, that's PHI and the more
- 10:11PHI we collect and spread around the earth through third party vendors and.
- 10:18SaaS systems the worst we are in terms of exposure.
- 10:23So we don't wanna expose anything to anyone if we don't have to.
- 10:27And so early on we're like, okay, how can we do this?
- 10:31How can we build this AI infrastructure so that it's just
- 10:34our data and no one else can see it?
- 10:37And that's what we did.
- 10:38That's why we used an open source stack.
- 10:41We hosted all on our own infrastructure.
- 10:46We use tools.
- 10:49Sure, they may have been developed by a third party, but they are now ours.
- 10:54We have, we own them.
- 10:56We maintain them, we update them, we review the code.
- 11:00Everything is centered in our systems and no one outside of AVI can see
- 11:07that data or change those systems.
- 11:11We are, constraining that so that all of our AI interactions result
- 11:19in data that's private to avi.
- 11:23So we're very proud of that infrastructure.
- 11:26That said, not everything we do, obviously involving AI is built in that
- 11:32infrastructure, but that's given us a really strong foundation from which.
- 11:37To weigh other options against and to measure other options, right?
- 11:43So as we approach, say, a vendor that does ambient scribe listening in our electronic
- 11:51medical record for instance, we have clinicians who are speaking with patients.
- 11:57We didn't build that tech, so we are in fact using.
- 12:01A third party for that tech.
- 12:03But as we navigated those waters, we're like, okay, we know.
- 12:08We know what you're gonna have to do.
- 12:10You're gonna have to trace it.
- 12:12You're gonna have to store the data.
- 12:14You're gonna have to, enable auditing.
- 12:17It's gotta be HIPAA compliant, we need a BAA, etc. All those pieces have to
- 12:22be in place and by building our own.
- 12:25Version of this.
- 12:26First, we really learned a lot about how to extend our compliance and safety
- 12:34through to our vendors and require them to follow the same procedures.
- 12:39That's really valuable.
- 12:40I think that, as we look forward, policy frameworks and systems are
- 12:46gonna be, become more, they're gonna become increasingly important.
- 12:51And building out that framework and that clear understanding across the
- 12:56organization because organizations grow and change and they're still
- 13:00made up of people who forget what the SOP said in the first place.
- 13:05Having that framework and that clear accountability makes a lot of sense.
- 13:09You covered a lot of ground there, but I just wanna, I wanna
- 13:12pull back to the audit ability.
- 13:16And, it's something that I think we take for granted if we have good IT
- 13:21support or if we have a good IT vendor or somebody that we work with or someone
- 13:26on our team, for the organizations that we speak to, oftentimes, they, they
- 13:30may outsource their it, but they still feel confident that they have logs.
- 13:35AI presents a new and unique challenge because those logs
- 13:38can become huge very quickly.
- 13:41And there is some lack of transparency around what gets saved on the AI side.
- 13:49If you were, if you can put yourself in the position of, being in a smaller
- 13:55organization, how would you approach that observability and data retention around?
- 14:04Around that observability piece.
- 14:07Absolutely, yes.
- 14:08So of course it depends on the tech stack,
- 14:11right?
- 14:11You choose to use or, and, or the vendor.
- 14:15Yeah.
- 14:16Slash SaaS software as a service.
- 14:19Product you choose, but you just need to make sure upfront that there's a plan to
- 14:24track and observe every single interaction
- 14:29With your ai and whether that be an open source platform like Lang
- 14:34Fuse that we're using the Lang chain stack has one called Lang Smith.
- 14:39That is also extremely effective.
- 14:42Each vendor, each SaaS product has to have, if it's gonna, if they're
- 14:47gonna sign a, BAA or b SOC two compliant, they have to have that
- 14:52observability and audibility built in.
- 14:55And so it's just a matter of you requiring, as the owner of the system
- 15:01you have to require that be available.
- 15:05To your team, and that's, that was key for us.
- 15:08Like we were using chat GPT early on.
- 15:11Our, you mentioned our leadership is very AI centric and AI forward.
- 15:17They're also very AI careful and AI safe.
- 15:20So I should clarify that, but.
- 15:23Early on we're like, yeah, chat GPT, let's get a corporate team account.
- 15:27And that was good for a while until it dawned on me that we did not
- 15:32have auditability or observability.
- 15:35In that agreement, the team account in chat, GPT does
- 15:39not give you that capability.
- 15:41Yeah.
- 15:41So we explored, okay, we need an enterprise agreement with somebody.
- 15:46And chat GPT's enterprise agreement through OpenAI was gonna cost us.
- 15:51A huge amount of money.
- 15:53Then we looked at Claude and we also like Claude for other reasons, and
- 15:57we're like, okay, we can do this.
- 15:59Reasonable price.
- 16:01Enterprise got audibility.
- 16:03It's got all the enterprise controls, of course, the
- 16:06observability, everything we needed.
- 16:08So then from an operational standpoint, it was a clear no-brainer to convert
- 16:15all of our chat GBT accounts over to Claude Enterprise and now we are there.
- 16:21We have that observability and I sleep a lot better at night knowing that's true.
- 16:25So that's one way you can think about it is operationally.
- 16:30But then, if you're building custom ai, that's a whole different can of worms.
- 16:34Yeah.
- 16:35Yeah.
- 16:35You really need to attack it from, you are responsible for everything
- 16:41and you absolutely need to.
- 16:44Test carefully.
- 16:46Another advantage of using a tool like Lang use or Lang Smith is
- 16:51that you can create a database of prompts that you can use for testing.
- 16:58We have thousands of them.
- 16:59Yeah.
- 17:00And so we build our system, and then we test it against those prompts.
- 17:06And the prompts are like, prompt injection.
- 17:09Things, which you can get libraries of those, you can ask your AI to help
- 17:13you create prompts to test itself.
- 17:16That's a really good way to go.
- 17:18But you also need to talk to your business users and hopefully even your actual
- 17:23users, which we call patients on our side, and just ask them, what do you,
- 17:28what are the questions you're asking?
- 17:30Yeah.
- 17:30Of an AI that does this.
- 17:33And also then you can observe what questions are being asked
- 17:36and you can find the ones that might get answered incorrectly.
- 17:41Or worst case things that might violate the guardrails you have in place.
- 17:47And so that, by the way the guardrail piece is the other
- 17:52very important component to this.
- 17:55We have implemented guardrails in our custom ai of course, and of
- 18:01course, anthropic and other AI vendors include guardrails in their LLMs.
- 18:08But those are not enough when you're dealing in regulatory spaces like
- 18:13Yeah.
- 18:14Healthcare, and so we have special guardrails in place
- 18:18to make sure we never collect.
- 18:20PHI when, unless we're, using a system that's meant to
- 18:26collect PHI, of course, right?
- 18:27But those guardrails need to be configured early and tested, and
- 18:32then going back to that database of prompts, that's the secret sauce right
- 18:36there that becomes your ip, right?
- 18:39Because you need to know, okay, what's the universe of questions?
- 18:44And you're not gonna catch everything, of course.
- 18:47But what's the universe of questions that might get asked
- 18:50In this domain?
- 18:51And then have hopefully hundreds, thousands of those
- 18:56questions in a database.
- 18:58And then you can use a tool like Lang Fuse or Lang Smith to run through
- 19:03those questions and automate them.
- 19:06And then record, of course, the responses.
- 19:10Using Lang Fuse or Lang Smith.
- 19:13And then once you've got them recorded again, you can use AI to help you
- 19:17point your LLM at those responses and say, okay, which of these don't
- 19:22look right, which are incorrect?
- 19:24Let's log, let's flag those.
- 19:27We also use a human for that.
- 19:29Of course.
- 19:30Yeah.
- 19:30Yeah.
- 19:30We have a QA testing team.
- 19:32And they, so we get the visual human review of those responses too,
- 19:37and then you adjust your dataset.
- 19:40So that you might find some additional questions user questions that need
- 19:46to be added to your list of prompts, and then you run it again, and then
- 19:49you make a change to your system.
- 19:52You need to run your dataset test again.
- 19:55Yeah.
- 19:55And it's just, you have to be very thorough.
- 19:58You have to think of what's the worst case?
- 20:01Yeah,
- 20:02that could happen.
- 20:02Imagine it, document it.
- 20:06Create a data set that can test it and then run it every
- 20:10time you update your system.
- 20:12Yeah.
- 20:12It's
- 20:12a lot of work.
- 20:13Now, you covered a couple things that I think would be particularly interesting
- 20:16to this audience, which in general tends to focus on liability, right?
- 20:20There's protecting their own business and their own practice, but then there's
- 20:24also the application of liability to whoever the party is that violates right.
- 20:29You covered a little bit of prompt engineering and then testing or
- 20:33prompt injection and testing.
- 20:34So talk to me a little bit about that.
- 20:36I think that might be a, kinda a new concept to some of the folks here.
- 20:40So what is prompt injection?
- 20:42What type of risk does that introduce?
- 20:46Again, if you're using one of the Frontier Gen AI lms, and by that
- 20:52chat, GPT Gemini, Claude, they've got guardrails built in to prevent.
- 20:59Prompt injection from taking its toll, but generally what a prompt
- 21:05injection scenario looks is that a hacker thinks of a question that it
- 21:11can ask your LLM that will cause it.
- 21:14To break out of its rules that you've implemented and then go rogue, right?
- 21:21And that's the last thing you wanna have happen, of course.
- 21:24So you could do one of two things.
- 21:26Trust that Claude or whoever it is have that their guardrails are good
- 21:32enough and that you're not gonna get a jailbreak event resulting
- 21:37from some sort of prompt injection.
- 21:41Or do what we do, test the heck out of it.
- 21:44Find a library online.
- 21:45There's hundreds of libraries of prompt injection attacks.
- 21:50Download that library.
- 21:52Create a database.
- 21:53Use a system like Lang Fuse or Laying Chain, or I'm sorry, Lang Smith.
- 21:59There's too many out there.
- 22:01Use one of those systems to automate the testing to make sure that your.
- 22:08LLM is not going to respond to those prompt injections because if
- 22:12it does, you've got a huge problem.
- 22:15And that's where PHI can get leaked.
- 22:17That's where other huge safety issues may arise.
- 22:21Yeah, it'll be interesting.
- 22:22I have to imagine we'll start to see some volume of mass torts come
- 22:28down the pipeline as organizations are rolling out large systems.
- 22:33I mean there was a funny one that rolled out the other day around Chipotle, right?
- 22:36Their support, I dunno if you saw this, but their support bot on their website was
- 22:42answering all sorts of questions, right?
- 22:45So people were giving it code and saying, help me di help me debug my code.
- 22:49And it was doing it right because they just were using, and so
- 22:52they were just reusing I think one of the flagship models.
- 22:56But then they hadn't tightened it down for their own specific use case, you know?
- 23:01So.
- 23:02exactly.
- 23:02So even though they were using a model that has guardrails built in, wasn't gonna
- 23:06let it do anything particularly dangerous.
- 23:08Dangerous can also mean spending all your money on tokens, right?
- 23:12Absolutely.
- 23:13Yep.
- 23:14That's a very real problem.
- 23:16I'm sure they paid the price.
- 23:18I did read about that.
- 23:19That was interesting.
- 23:21One of the keys to developing a good safe LLM system in addition
- 23:27to having guardrails and tracing.
- 23:30It's the system prompt, right?
- 23:32Yeah.
- 23:32So every LLM has a system prompt built in, but if you build custom
- 23:39functionality on top of an LLM using a stack like Lang Chain, Lang
- 23:45Graph, Lang Smith, Lang Fuse those.
- 23:48tech stacks enable you to add your own system prompts.
- 23:52So that's what we've done.
- 23:53We've got a support bot and it has a probably 10 to 20 page, I
- 24:02forget it's growing all the time.
- 24:0420 pages worth of directives that we have curated.
- 24:08Yeah.
- 24:08In length.
- 24:09Fuse and the support bot will not respond to anything.
- 24:15Before it reviews those directives that are in the system prompt.
- 24:21And so that's typically marked down or whatever.
- 24:24Yeah,
- 24:24just simple text.
- 24:26But there's a lot of if then statements, which is a programmer thing, but
- 24:32basically if the user asks this question always respond like this.
- 24:38Yeah.
- 24:38And if the word, whatever, cancer is mentioned, always respond like this.
- 24:45So you've got those rules built in and that's part of what this
- 24:49database of prompts that you wanna maintain yourself for testing, that's
- 24:56part of what that needs to test.
- 24:58Yep.
- 24:59Because that can get really complicated.
- 25:01I just mentioned 10 to 20 pages of system, prompt directives.
- 25:05And how do they interact with each other,
- 25:08right?
- 25:08What if one is related to the other?
- 25:10Which one is it gonna pick?
- 25:12You don't know that until you test it, right?
- 25:14And you don't wanna wait and see what happens when it's out in the wild.
- 25:19You need to test it before you release it.
- 25:21So you definitely need to follow.
- 25:23What we in the, software dev world call development operations, DevOps for short,
- 25:31you need to follow those best practices.
- 25:33You need to, yeah, develop in one environment, test in another, and
- 25:38then deploy after you're thoroughly convince that you're testing has
- 25:44proven that your application is safe.
- 25:47Yeah.
- 25:47That's one of the biggest challenges that, it strikes me is, it used to
- 25:51be that you could test software.
- 25:54You hand it out to users and let them try to break it, but you still were
- 25:58in a rules-based system and now you introduce one, out of many, right?
- 26:02You start with one, but then you have all source.
- 26:04You have unpredictable outputs.
- 26:06Because you can have one prompt, and that one prompt can produce
- 26:12an infinite number of responses.
- 26:14And that's Such a new challenge on the development side where it historically
- 26:20has been one prompt is going to get a response, based on the variables
- 26:26that you have entered in the system.
- 26:27And we're not living in that world anymore.
- 26:29So that's a big change.
- 26:30Great point, chip.
- 26:31It's a whole new world knowing that the programmatic model is gone, right?
- 26:39Yeah.
- 26:39There's not a step by step.
- 26:43Expectation to this software.
- 26:46It is driven by, a neural network that we don't fully understand.
- 26:54And because of that, you, it's unpredictable and
- 26:58because it's unpredictable, you have to test it way more.
- 27:03We
- 27:03do, unfortunately, than you would a regular software
- 27:07application that's simply.
- 27:09Constrained by the limits of the software that wrote was written to make it work.
- 27:16That's the observability piece again, right?
- 27:17And like with the frontier models, we simply have a limited
- 27:21vis visibility and observability by the nature of the product.
- 27:26Exactly.
- 27:26So I think that will be interesting to see where that evolves.
- 27:29I'm sure there will be some ongoing litigation to get
- 27:32that figured out as well.
- 27:34As these things create problems, getting them litigated and figured out is gonna
- 27:39be an interesting part of the solution.
- 27:42Absolutely.
- 27:43And the way we look at it is we don't wanna be on the cutting
- 27:46edge of that li litigation, right?
- 27:49As a small company, we have to stay far away from that.
- 27:52We don't have hundreds of millions of dollars lined up in
- 27:56the bank to defend ourselves.
- 27:59Not that we would want to anyways.
- 28:01We don't wanna risk patient safety, not only to reduce our financial
- 28:06risk, but also just because we wanna do the right thing for our patients.
- 28:10Of course.
- 28:11And so let chat GPT, launch Chat, GPT, or chat, GPT Health, whatever it's called.
- 28:18Let them launch that.
- 28:19Let them, struggle to make sure it's effective and let them then.
- 28:24Find out if they do the hard way that it may have done some very bad things.
- 28:31Of course.
- 28:32Will it do some very good things?
- 28:33Absolutely.
- 28:35And that's why we want to stand by and see how that works out and
- 28:40not be involved in the potential risk of a, hurting a patient or B
- 28:47Losing a huge lawsuit.
- 28:50Or just getting tied up in a lawsuit.
- 28:52Yeah.
- 28:52We are taking the cautious approach and I strongly advise those of
- 28:58our listeners who, or, you know, counsel who are advising small
- 29:04businesses, take a similar approach.
- 29:06There's no reason to risk the farm on AI that may cross that line.
- 29:14Now, anybody who does is likely gonna face consequences.
- 29:19Just the state regulations alone are extremely complicated, right?
- 29:23So especially yes.
- 29:25Especially if
- 29:25you're operating more than one state.
- 29:28Exactly.
- 29:28Yeah.
- 29:28Yeah.
- 29:28And we are, we're operating 50, so we have to be extremely
- 29:32careful and keep a close eye.
- 29:35And of course, AI is your front again.
- 29:37We have to keep a close eye on all the regulations and make
- 29:41sure that we don't misstep.
- 29:43Right now we're looking at using a digital human avatar.
- 29:49As a new user interface, you would call it.
- 29:54In other words, a new way to interact with AI on our public facing websites.
- 30:00And then we are also entertaining even the possibility of doing
- 30:04that inside of our patient portal.
- 30:07But those.
- 30:08Capabilities introduce even more regulatory risks.
- 30:13So of course we're working closely with our attorneys proactively, not
- 30:18when it's too late, but proactively to make sure that whatever state
- 30:24we launch, this digital human.
- 30:27AI avatar in that is basically looks exactly like a human being talks to
- 30:33you on the screen in real time and introduces you to the services we provide.
- 30:39We have a very complicated patient journey at avi.
- 30:43Yeah.
- 30:43And a lot of the folks that.
- 30:44Come to avi.com and review what's possible.
- 30:49Really need a little extra help.
- 30:51And so the idea is we wanna offer this digital human and just let
- 30:56you talk to her and ask her, what am I supposed to do next?
- 31:01What?
- 31:01What if this happens?
- 31:02Do you.
- 31:03Prescribed medications or not, and all those kind of things that they
- 31:08couldn't like necessarily figure out just by looking at the text on our
- 31:12website, they could now talk to someone.
- 31:15And that's someone Yes.
- 31:17Is AI in the back?
- 31:18It's connected to an LLM in the background.
- 31:21But of course we can't risk violating regulatory rules when we implement that.
- 31:29So our proactive strategy is.
- 31:32We're gonna go to the state we wanna launch it in, and we're
- 31:36gonna say, here's what we wanna do.
- 31:38What do you think?
- 31:39Here's our policy, here's the plan.
- 31:42Here's a sample of what it looks like.
- 31:45Please let us know if you have concerns.
- 31:48And we're gonna pick the states.
- 31:49We do that in wisely.
- 31:51Yeah.
- 31:51We want to go to states that are of course, more likely to give
- 31:56us quick and honest feedback.
- 31:58Yeah.
- 31:58No, that makes sense.
- 31:59I really appreciate it, Steve.
- 32:00I appreciate you taking the time and your expertise and experience is invaluable.
- 32:05This was a great conversation.
- 32:07I'd learn things every time we chat.
- 32:09So thank you so much for this.
- 32:10This is gives me a lot to think about.
- 32:13Gives me a lot to try to prepare for as well.
- 32:14So thank you so much.
- 32:16This has been great.
- 32:17I loved being here.
- 32:18Thank you for having me.
- 32:21That was Steve Gullet on AI and HIPAA compliance.
- 32:23Thanks for joining, Steve.
- 32:25You can connect with Steve on LinkedIn or visit adhdonline.com to learn more.
- 32:31If you found this helpful, make sure to subscribe and share it
- 32:34with someone in your network.
- 32:36We'll see you next time on Legal Marketing Radio.