Podcast - What WISeR Means for Healthcare Providers, Patients and Policymakers

Morgan Ribeiro: Welcome to Counsel That Cares. This is Morgan Ribeiro, the host of the podcast and a director in the firm's healthcare practice. In this episode, we are looking at Medicare's Wasteful and Inappropriate Service Reduction, otherwise known as the WISeR model, which is a new value-based payment model launched earlier this year, which aims to crack down on waste in healthcare across six states. The model comes with a debate about the intended and unintended effects of the payment model as it potentially adds to the burdens of prior authorizations, which is already a huge problem across the nation's healthcare system. The WISeR model will use artificial intelligence technology to review physicians' recommended treatments for a number of medical conditions for beneficiaries enrolled in traditional Medicare in six states. Joining us for a discussion on the WISeR model are three experts who live in the trenches of the intersection of Centers for Medicare & Medicaid Services (CMS) regulations and reimbursement models. From Holland & Knight, we have Miranda Franco, who is a senior policy advisor out of our Washington, D.C., office, and Jennifer Hananoki, counsel in our Washington, D.C., office. And from the Medical Group Management Association, MGMA, we have Senior Vice President of Government Affairs Anders Gilberg. Really excited to have this group on the show, and they will share a little bit more background on what they're doing in D.C. and their background.

Miranda and Jennifer and Anders, thank you for joining us on Counsel That Cares today.

I want to give each of you a minute to tell our audience more about yourself. And I will first go to our guest, Anders. Can you tell us more about your background and your time at the MGMA?

Anders Gilberg: Sure. Thanks, Morgan. And thanks to Holland & Knight for including me on your podcast today. My background, I've been the head of government affairs for the Medical Group Management Association for about the last 15 years. Prior to that, I was an assistant director of federal affairs at the American Medical Association. So MGMA, we represent about 15,000 medical group practices and about 60 or 70,000 individual members that are involved with the administration and business side of medicine.

Morgan Ribeiro: Great. Miranda?

Miranda Franco: Thanks, Morgan. So I'm a senior policy advisor in Holland & Knight's Washington, D.C., office. I spend most of my time working at the intersection of the legislative, so Congress, and the regulatory, predominantly CMS. And certainly, for the purposes of this conversation, I'd say a significant part of my practice involves working with physician organizations and other healthcare stakeholders as they are navigating CMS and Centers for Medicare and Medicaid Innovation (CMMI) policy like this, both understanding what the agency is trying to accomplish, but also importantly how those policies translate at the practice and patient level. Before I joined the firm, and this is a little bit of a reunion for us, I was with the Medical Group Management Association and Anders was my boss, and prior to that I was with the American Society of Plastic Surgeons and the National Patient Advocacy Foundation. So spent about the first decade of my career in the physician trade space before joining the firm 13 years ago. And I would just say quickly to frame some of the conversation, I think a lot of my practice focuses on, I know Jennifer as well, is what we're focused on today, which is prior authorization, AI, admin burden and beneficiary access. So I think that's what makes this discussion and this demonstration worth watching. I think there's broad agreement around the goal of what some of this is aiming to achieve, but I think how you accomplish that goal and what safeguards are around it and whether the solution creates new problems for legitimate care is really a lot of our focal point, certainly is here at the firm.

Morgan Ribeiro: Awesome. Jennifer, we'd love to hear from you. I know you have a similar background and a connection, as Miranda alluded to. And you're our newest member of the Holland & Knight team. So tell our listeners a little bit about yourself.

Jennifer Hananoki: Yeah, thanks, Morgan. Happy to round things out. And absolutely, I have known Miranda and Anders my entire career. It is wonderful to be able to join them both for this timely conversation. I am senior counsel at Holland & Knight focused on Medicare and Medicaid reimbursement, regulatory strategy and federal healthcare law. Before I joined Holland & Knight in April of 2026, I was at the American Medical Association where I was director of federal affairs, focused again on physician reimbursement, value-based payment models, hospital reimbursement and other evolving and emerging trends in the healthcare space. Before that, I also worked for Anders at MGMA, and so I am delighted to be here and be part of the conversation.

Morgan Ribeiro: Awesome. Well, thank you all. Glad to just be here as a witness to your reunion and hear all that you have to educate us on here today. As I mentioned in my introduction, there has certainly been some friction in the air when it comes to the WISeR model. I think it's helpful first to take a step back and really get a lay of the land here. Jennifer, could you tell us more about just broadly the recent activity that we've seen coming out of CMMI and CMS as it relates to various alternative payment models and then where the WISeR model really fits into those larger plans?

Jennifer Hananoki: Yeah, absolutely. That's a great starting place. And as listeners may know, the Center for Medicare and Medicaid Innovation, or CMMI, was really stood up about 15 years ago to test innovative payment and care delivery models in Medicare and Medicaid. The Trump Administration, under the leadership of Director Abe Sutton, has laid out a very specific and new strategic direction, really designed to enable CMMI to contribute to this administration's goals to "make America healthy again." So this strategic framework is three pillars: evidence-based prevention, individual empowerment and choice, and competition. And I will note that really all of those pillars are sort of being filtered through three trends that we're seeing from CMMI right now, which is a large focus on generating savings to the Medicare program, savings for taxpayers, savings for Medicare beneficiaries. We are seeing a shift from voluntary to mandatory models, and then we're also seeing an increase in leading with private sector technology solutions. And as we'll talk throughout this conversation, WISeR really checks all three of those boxes. So again, just stepping back and taking a lay of the land about where this administration has prioritized their efforts in CMMI, we've seen them move very quickly.

At the beginning of last year, they terminated four models early – that was the Maryland Total Cost of Care Model, Primary Care First, End-Stage Renal Disease (ESRD) Treatment Choices and Making Care Primary – in order to generate savings for the Medicare program. And CMMI has also been very busy launching, implementing new models, numerous new models. And I'll talk about a few just to see where WISeR fits into the overall portfolio.

So we'll say one other technology-focused CMMI model is the access model. This is a 10-year voluntary model for technology-supported product care that just launched this summer, July of 2026. And it is a unique model. Participants cannot bill traditional fee-for-service for aligned beneficiaries. If they are going to provide care under the model, they have to rely on the outcome-based payment that they receive. Another related model that really exemplifies the trends that we're talking about is the recently announced ambulatory specialty model. This has not begun yet, scheduled to begin January 1, 2027, but this really fits that bucket of a mandatory model that expands into specialist care. So this really targets specialists who have been largely in the fee-for-service realm of Medicare. It creates more value-based payment pathways there. But similar to WISeR, there are a number of concerns about how the model is going to generate savings and whether there are sufficient safeguards for the specialists who are going to be participants in that model. So WISeR, as we'll get into, it's really at the intersection of trying to target those services that have some scrutiny for potential overutilization or potential fraud, waste and abuse, leaning into technology, specifically artificial intelligence, and also under the premise of trying to find a way to reduce the administrative burden surrounding prior authorization, which has gotten a lot of attention, and we will absolutely get into today. So I think the framework for this conversation and understanding where CMMI's priorities are is that they are overwhelmingly focused on fiscal accountability. They want to be able to certify and expand the models that they test. And I think WISeR is really a good case study for how this is going to play out. Is it going to achieve the administration's objectives of leveraging technology, reducing potential fraud, waste and abuse, protecting the taxpayer and being able to be certified and expanded? Or will it need to be modified and adjusted? And we'll talk about ways that we think that it could be. Back to you, Morgan.

Morgan Ribeiro: Yes. So perfect summary and background there. And I think this all sounds fine on the surface, and ultimately the goal of solving the administration's efforts to reduce fraud, waste and abuse in healthcare is a good goal to have. But there's a flip side to this. Anders, I'd like to get your perspective on that. Why has MGMA actively advocated for reforms to the WISeR model?

Anders Gilberg: Well, in our experience from our members, as well as just observing the administration's actions with respect to the WISeR model, to us, it's exactly the opposite of offering physicians and medical practices an opportunity to reduce the administrative burden. One of the real problems with prior authorization is the fact that a typical medical practice might have multiple contracts with multiple payers. They might be commercial payers, they might be Medicare Advantage payers, but each one has its own proprietary way that they handle prior authorization. So that means that they might have an electronic solution, but that the staff or a physician has to log on to a specific proprietary portal with its own password, go through its own type of algorithms to determine whether or not there's an authorization needed, and then to submit that via that portal, or in some cases, fax or some kind of manual transmission over the phone, etc. And so one of the things that we have been working on, ironically with the prior administration and this administration, is to standardize that. The reason this is related to WISeR is that WISeR is an initiative that doesn't even follow the pathway that the administration is following with respect to prior authorization for Medicare Advantage and Medicaid managed care plans in which they're rolling out a standardized approach for prior authorization. So a physician can, within their own electronic health record (EHR), go ahead and identify those services which require authorization and then ideally transmit that authorization seamlessly through the EHR through a standardized application programming interface (API) that is then taken in by the health insurer and then, within a relatively quick turnaround, the authorization is returned to the practice. And let's not forget that there's a patient involved here. So anything that's denied in a prior authorization request is a denial of care to a patient that a physician has authorized or prescribed or ordered. Prior authorization, when we survey our members, is their No. 1 burden. They have to hire multiple staff, each practice location, often for a larger practice, to deal with these multiple overlapping requirements. So standardizing prior authorization would be fantastic.

Morgan Ribeiro: Great. And you mentioned, obviously, the pain points for physicians in particular. Jennifer, how is WISeR different from the prior authorization processes that physicians already navigate in Medicare Advantage?

Jennifer Hananoki: Yeah, great question. And I do think there are a number of similarities, but it is worth unpacking a few of the differences. And Anders already alluded to a number of these. The first is the scope. WISeR is narrowly tailored, focused on a certain set of services, including skin substitutes, spinal procedures, rather than a number of the Medicare Advantage plans, which were really broad utilization management programs that apply across dozens, if not more, services. The second difference is one that CMMI emphasizes, which is that the WISeR prior authorization requirement is voluntary because there is an alternative. And the alternative is prepayment medical review. So the difference here is a matter of timing. Prior authorization takes place before service is delivered. And that's why Anders was mentioning that his members are concerned about impacts on beneficiary access, impacts on that physician-patient relationship, because prior authorization can delay care. Prepayment review takes place after the service is delivered but before CMS will pay for that care. So what it means is that a physician may have provided the service but now has to submit documentation verifying to the vendor that it has satisfied all of the criteria in order to be paid. So it is really a difference of timing when you go through that verification process. I'll say the third and likely most significant and important distinction is around gold carding. This is new in WISeR. The model began earlier this year, as we've talked about, in six states, and starting in July, the vendors have rolled out a gold carding option. This is for physicians and other clinicians to hit a minimum affirmation rate, and this may vary across vendors, but generally speaking, the vendors will look back at a certain set of claims data and a certain set of outcomes for prior authorization requests – typically it must be a minimum of 10 – and determine whether a physician or clinician has met at least an 80 percent or higher affirmation rate. And if so, then they would be exempt from the prior authorization process for one year. And they would have to go through this gold carding process again in the future.

Morgan Ribeiro: OK, so another area of, I'd say, friction or sort of a pain point here is around technical issues. So implementation was delayed slightly because of technical issues, and we've since heard anecdotal reports of portal problems, communications challenges and relatively low initial approval rates. Miranda, I want to kick this one to you. Can you elaborate on some of the technical issues that have been experienced, or those who are implementing this have experienced?

Miranda Franco: Just to do some framing, I know we've sort of hit on some of the model's key elements, but just to punctuate because it's instructive to some of those implementation and technical issues. So the model, as you've heard, is in six states. It's in Arizona, New Jersey, Ohio, Oklahoma, Texas and Washington. I flag those states because that's where the data that we are getting is certainly focused on. It is also important to note that this is affecting nearly one in five Medicare fee-for-service beneficiaries. So while it applies to a targeted group of Part B services that CMS believes are vulnerable to waste or fraud, and they certainly have to be governed by local coverage determinations or national coverage determinations (NCDs) as well, there are very broad implications around this model. So it may seem narrow in focus, but it has broad sweeping impacts, which is why some of those implementation and technical issues, I think, are really something that people are trying to review and understand.

So as you said, Morgan, the model itself was delayed from January 1 until January 15 because of technical issues. Since implementation, providers have reported some problems with online portals, some technical glitches and communication with model participants. And that's another thing to punctuate. This is a voluntary model for the technology vendors. It is not a voluntary model for the providers. And so that's a pretty big distinction when we're looking, again, at some of these implementation and technical issues.

So I think we have to be cautious about extrapolating them across the entire model, but they underscore why the implementation details matter. And now we're starting to see some more specific reports from providers. Sen. Cantwell of Washington state recently released data, which you can easily find online in a report, collected from 16 Washington hospitals. And according to that report, some hospitals are experiencing authorization timelines that substantially exceed CMS' stated standards. And then the University of Washington Medical System, for example, reported average responses of 15 to 20 days, again, compared with CMS standards of three days for routine requests and one day for urgent requests. The Washington State Hospital Association also reported that some procedures that previously took approximately two weeks from authorization through completion are now taking four to eight weeks. And again, that's one state's experience and relatively early data. I think it illustrates the bigger implementation question, whether we're not just asking if the technology works, but if we're asking whether the process works for patients and providers. A portal can technically function and still create enormous administrative burden. An authorization can ultimately be approved but still have delays for patient care that can take several weeks, as we're seeing in some of those reports. And CMS itself appears to recognize some of those operational concerns and that readiness matters. And I know we'll get into this, but they delayed implementation of two services to provide some additional time for operational readiness. So I think with all of that in mind, the metrics we need to watch aren't simply the denial and approval rates, but we also need to really review and scrutinize how long decisions take, how often initial decisions are reversed after a physician review, if there's additional staff time practices are spending on the process and then ultimately if patients are experiencing delays in medically necessary care.

Morgan Ribeiro: Anders, I want to flip this back over to you. So we've talked about some of the technical issues. We've talked about implementation and some of the delays there. I'm curious to know what you've been hearing directly from your members.

Anders Gilberg: Well, pretty much what Miranda just went through. You know, there is a lot of variability. And as Miranda highlighted, Washington state, we've seen the very same problems that both were identified by Sen. Cantwell, as well as the Washington State Medical Association and the hospitals in Washington state. It's worth keeping in mind that each one of these states typically has a different vendor. And for example, the vendor in Texas, there is a little more familiarity with that vendor. And the reason is because that vendor is used for prior authorization for a lot of the commercial plans in Texas. And so we have medical practices in Texas that are already used to using that third-party vendor. But it is familiar to those practices in Texas, and we have heard less problems in Texas than in other states. But just to recap some of the things that Miranda touched upon is, again, vendors not responding within the required 72-hour window, high denial rates, especially early on. There were really high denial rates, and it's come down a little bit, but they still are out there.

Morgan Ribeiro: Great. Well, you mentioned denials. CMS has emphasized that physicians and beneficiaries retain appeal rights and that contractors can be penalized for inappropriate denials. Jennifer, does that address providers' concerns?

Jennifer Hananoki: So those are certainly helpful tools in the toolbox that we should get into to fully understand what those tools will allow physicians and beneficiaries to do. So you heard from both Miranda and Anders about the prior authorization process, and you heard the initial denial rates were higher and then after a physician or other clinician went through the peer-to-peer process and were able to get another knowledgeable clinician or physician on the line, those denial rates did go down. So that is an option for clinicians. They're familiar with that. That is structurally very similar to many of the commercial payer and Medicare Advantage prior authorization programs that exist and have existed for a long time. The thing to note about the specific appeals is that those don't kick in at the prior authorization stage. The appeal kicks in at the claim denial stage. And so it's much farther down the road. And so if a Medicare beneficiary does ultimately want to appeal that denial, then the claim would have to be submitted, the Medicare administrative contractor would have to say that this is not covered and not going to be paid, and then it would go through the usual, the typical Medicare appeals process. And regarding the second part of your question around penalties, I certainly think that that is an important guardrail that CMS has put in place. And I do think we would want to see more information, a little bit more transparency, about how the agency is going to evaluate what is an inappropriate denial. I think we would want to see a little bit more detail about how they are going to hold these vendors accountable. We haven't seen that. A lot of that is just timing. And this model has not been up and running for a year yet. So we talked about the gold carding mechanism only went into operation in July, last month, and so a lot of this is still very much an unknown. And so we will see more information and see how CMS is utilizing these safeguards that they have stood up.

Morgan Ribeiro: Awesome, yeah, and I think we talked about this earlier, the delay in implementation. That was CMS-delayed implementation around two specific procedures, deep brain stimulation and percutaneous image-guided lumbar decompression, to allow additional operational readiness. So does that suggest that CMS is recognizing implementation challenges, Anders?

Anders Gilberg: You know one of the reasons, for example, deep brain stimulation was excluded, in my understanding, because the codes are on the Medicare inpatient-only list and that was never intended to be included in the WISeR model. So that's not really an implementation challenge. It's just I don't necessarily think they're going to move forward with that. The meetings that we've had or been a party to where CMMI has acknowledged some of the ongoing implementation challenges, they have a bit, but they've also pushed back significantly up on the Hill, as well as with some of the things identified in Washington state. And so I think we tend to see a fair bit of lack of transparency with respect to the WISeR model, or acknowledgment of the problems. In some cases, it wasn't necessarily ready for prime time. It wasn't necessarily aligned with other initiatives for prior authorization, as I mentioned. And so, despite the fact that we're kind of new, it hasn't been out for a year, we haven't really fully seen any kind of acknowledgment that the physician community or the implicated physician practices had these implementation challenges. So stay tuned. Maybe something else will transpire. And again, we are not looking to have this model rolled out in its current form in the current way it's implemented. If anything, CMS should step back and implement it in the same fashion that they're rolling out the standardized prior authorization criteria for Medicare Advantage plans. We'll see where implementation goes from here.

Morgan Ribeiro: Right. Well, another area of focus I would just say, you know, broadly speaking, as I'm out talking to folks in the industry, it seems like the topic around skin substitutes and wound care, I know that that's an area of focus when it comes to enforcement and fraud, waste and abuse. And one of the services included in the WISeR model is skin substitutions used in wound care. Medicare spending on these products has increased dramatically in recent years, and it has drawn scrutiny over the fraud, waste and abuse and inappropriate utilization. At the same time, CMS has pursued other policy changes, which have included significant changes to how these products are reimbursed. Miranda, I want to turn to you. Can you put this into context and explain how WISeR fits into CMS's broader efforts to address these concerns?

Miranda Franco: Sure. So we work with a lot of folks in the wound care space and wound care providers and manufacturers, for full transparency. I think as you alluded, Morgan, there's been a lot of concern about the growth of Medicare spending on skin substitutes, including some documented instances of fraud and inappropriate utilization and inappropriate billing. So I don't think anyone would debate really about whether CMS should address those problems, it absolutely should. I think the more important policy question is which tool you use to address which problem.

So skin substitutes were already subject to Medicare audit and program integrity oversight before WISeR. And I should note under WISeR, it's only applicable in the states that have local coverage determinations (LCDs) for skin substitutes, so not all six states are utilizing this model around skin substitutes. But at the same time that this is going on and those audits, CMS has pursued a much broader reimbursement change that moved away from product-specific payment toward a much lower standardized fixed-fee rate. And so those are very different interventions. And I would say CMS sort of took program integrity in this instance and cloaked it as payment. And so you now have those being exposed to both a very significant reimbursement change, but also this program integrity provision as well. So again, if the underlying concern is fraudulent billing or inappropriate utilization, then this approach certainly makes sense with the safeguards that we've been talking about, but broad reimbursement reductions affect everyone, including clinicians dispensing medically necessary care appropriately.

Conceptually, there's an argument for that kind of targeting, you know, can you identify inappropriate utilization more precisely rather than reducing payment across the board for good actors? So I think the experience here shows why you have to be really careful about the other side of the equation. Skin substitutes are among the services subject to WISeR in those states along with other, as we've discussed, treatments for pain and spinal conditions and other conditions. And so these aren't exactly abstract billing codes. They're services being furnished to Medicare beneficiaries with real clinical needs. So I think the challenge for CMS is to build a program integrity mechanism that is sufficiently targeted to stop bad actors without creating barriers for legitimate providers or delaying medically necessary care. So I think that's the balance that needs to be the focus, not just of this model, but certainly more broadly, just as we're looking at how judicious this administration has become around fraud, waste and abuse efforts.

Morgan Ribeiro: Miranda, just continuing with you, the U.S. Government Accountability office recently concluded that WISeR meets the definition of a rule, and is therefore subject to the Congressional Review Act. Democrats in both the House and Senate have now introduced resolutions seeking to overturn the model. What does the GAO decision actually mean? And how does the Congressional Review Act process work? And then how realistic is it ultimately that Congress could repeal WISeR?

Miranda Franco: Yeah, thanks, Morgan. So this is a really interesting development because it goes beyond WISeR itself and raises a broader question about how CMS implements models. I think the first thing to understand is that CMS implemented, as you said, WISeR through a notice rather than traditional notice-and-comment rulemaking. And so several senators subsequently asked the GAO to examine whether that action nevertheless constituted a rule for purposes of the Congressional Review Act (CRA). And in May, GAO concluded that it does. So the reasoning is important.

GAO found that WISeR establishes new requirements for traditional Medicare providers in those six states because those services previously did not require prior authorization now do. So the determination doesn't automatically invalidate WISeR. What it does is bring the model within the CRA, and the CRA gives Congress a mechanism to overturn an agency action through a joint resolution of disapproval. It also provides expedited procedures in the Senate under certain circumstances, including protection from a filibuster. If a CRA resolution passes both chambers and is signed by the president or Congress overrides a veto, the rule has no force or effect. And then there's an additional consequence that the agency generally cannot issue another rule that is substantially the same unless Congress subsequently authorizes it. So it's a very powerful tool.

In WISeR's case, Democrats introduced resolutions of disapproval in both the House and Senate following the decision. The Senate resolutions have already received a vote on whether to proceed, but that motion failed 46 to 50 in July. So by no means would I categorize congressional repeal as imminent at this point, but I also wouldn't minimize the significance of the GAO determination. I think the larger issue is that CMMI can make very consequential changes in how Medicare operates. And so here, providers in those six states suddenly became subject to new prior auth requirements in traditional Medicare. And so the decision is essentially a reminder that calling something a demonstration does not necessarily insulate it from congressional review when it creates substantive and significant new requirements.

And so politically, WISeR has now attracted scrutiny from several different directions. There's been congressional letters, an appropriations effort to withhold funding, the GAO determination we just discussed and the CRA resolutions, and now, as we also discussed, some of those provider reports about implementation and patient delays. So even if Congress does not repeal the model, which I don't anticipate under this current makeup of Congress, I think that level of scrutiny matters and it creates some pressure on CMS to demonstrate that WISeR is actually reducing inappropriate utilization without creating inappropriate denials or excessive administrative burden. So I think the question that Congress will be asking as this continues is, is WISeR reducing waste, or is it creating another layer of utilization management?

Morgan Ribeiro: OK, so Miranda, you just gave us a great overview of what's happening and what we're seeing in Congress. You mentioned that this creates some pressure on CMS. What have we seen most recently that may indicate that there is some pressure on CMS and [that] we may see some movement on that front.

Miranda Franco: I think, most recently, we heard from the CMS Deputy Administrator that there were a lot of things about WISeR not working, which I believe is probably one of the first public acknowledgments about concerns with the ongoing technology oversight and the humane clinical review and just some of the broader provider feedback concerns that have been articulated by many in the healthcare ecosystem. And because those concerns are no longer coming exclusively from physicians or patient advocates, I think the CMS leadership is publicly recognizing those implementation challenges. I think it's further compounded by the fact that just in the last week, the Electronic Frontier Foundation released more than 800 pages of FOIA (Freedom of Information Act) records or additional records. And so, within that, CMS had issued requests for information or corrective action plans involving four of the six participating vendors. And so some of the things that came out of those records were problems with delayed prior authorization decisions, potentially inaccurate denials and some inadequate provider communication and malfunctioning technology.

So given that WISeR is intended to reduce inappropriate utilization of Medicare spending, I think these early imitation difficulties highlight the risk of adding new prior authorization requirements. And then I think there are also some questions about the vendor financial incentives since participating companies receive a portion of the expenditures averted through the model. So I think CMS is probably grappling, at the moment, with how to demonstrate that the model is identifying an appropriate care, rather than simply reducing utilization. So, given that they have recognized and taken correction action with vendors, I think they'll continue to work through some of the broader questions about oversight and transparency, and I think they'll presumably try to address those issues before expanding the model in any kind of way, ensuring that there's evidence there that the model's working as intended. And certainly not creating any additional barriers for Medicare beneficiaries.

Morgan Ribeiro: Anders, let's say that Congress does not ultimately repeal the model. What changes would MGMA like CMS to consider?

Anders Gilberg: Miranda mentioned a few of them. So transparency reports on each vendor's response time, their denial rates, appeals rates, reversal rates, details on these gold carding plans. Again, that hasn't been consistent as well, so we would very much like to get that up and running as soon as possible. There hasn't been as much engagement with practices that we would like, physicians and practices, and that there should be consistent communications to practices that are within the six states and implicated by the 15 procedures. And then finally, I'll just reiterate that if they're going to roll out a plan like this, it needs to be consistent with their own words and actions. And so earlier this year, in addition to the implementation and finalization of regulations to standardize prior authorization for Medicare Advantage and some other health insurers, this administration sought and achieved receiving a pledge from private insurers on moving forward with reforms on prior authorization. And ironically enough, the WISeR model is inconsistent with the pledge as well as the administration's own regulations. So we would like to see, if this is continued, alignment with all the other programs that the administration is rolling out, which we do support. So stay tuned on that, but a one-off type of program like this just adds to administrative complexity and burden and ultimately to the detriment of patients in the Medicare program.

Morgan Ribeiro: Well, Anders, thank you for joining us today. It was very helpful to hear your perspective on this discussion. The WISeR model certainly sits at this kind of intersection of utilization management, artificial intelligence, there's certainly administrative burden as we've covered in this conversation and patient access. And these are all really important issues that are going to continue to be important as Medicare evolves. And we will continue to watch this closely as Congress and CMS and stakeholders respond in the months to come. So thank you all for joining me today. Always a pleasure to connect with you.