Trey Rawles’ thoughts on healthcare markets and technology. Read the newsletter and listen to the podcast.
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Joined February 2026
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Trey Rawles retweeted
I'm noticing a trend
there's a growing number of "AI consulting" firms charging $20K+ to "deploy Claude" to legacy businesses (mid-sized law, accounting, PE firms) as "Anthropic enterprise partners"
what this means:
- they install claude code, cowork
- run a few commands to connect to tools
- give generic or misleading advice on a tech stack
meanwhile, there's more interest than ever for firms with 0 technical staff to build SaaS in-house and there's an entire industry of advice givers seeking to profit off of this trend
last week I was on a call with a PE firm (working with one of these agencies) and someone who had never written code was asking whether to run a RAG vector DB on a Mac mini to chunk internal docs
can't make this up
Trey Rawles retweeted
The Wake-Up Call Nobody Was Ready For
On February 21, 2024, I was in Washington, D.C. when Change Healthcare went dark. My practice leadership and I didn’t fully understand the severity at first, but within days we realized that we were living in a nightmare.
Change Healthcare is the clearinghouse that processes and submits medical claims to insurers on behalf of providers. When it went down, my practice couldn’t submit claims or receive payments for a minimum of four weeks. Insurers stopped sending electronic remittance advice. My staff spent countless hours manually reconciling deposits by logging into individual payor portals, comparing explanation of benefits to bank entries one payment at a time. Patients received automated bills that should have shown zero balances. We told them to disregard the bills but they were understandably frustrated. Every minute spent on fixing the problem was a minute not spent on patient care.
I testified about this before the House Energy and Commerce Health Subcommittee on April 16, 2024. I told the committee what most independent physicians already knew but Washington needed to hear: the average physician practice has only weeks to a month of cash on hand. Change Healthcare at that time handled an estimated 50 percent of all medical claims and processed more than $1.5 trillion annually in healthcare spending. That’s right… a single point of failure processed half the country’s claims.
The AMA’s post-attack survey of 1,400 physicians found that one-third reported an inability to submit claims, receive payment, or access electronic remittance advice. Twenty-two percent faced eligibility verification issues that caused substantial revenue loss. Fifty-five percent of practices had to use personal funds to cover regular expenses. And while UnitedHealth Group, the parent of Change Healthcare, reported $99.8 billion in revenue in Q1 2024, independent practices were scrambling just to make payroll.
This week I am going to walk through what the attack revealed, what regulators have since proposed, what it will cost small practices to comply, and what Congress can and should do. The breach is now in the rearview mirror. Unfortunately, the regulatory fallout is just beginning.
Trey Rawles retweeted
Goldman is betting Nvidia will get a boost from health care as industry builds out AI capabilities cnbc.com/2026/03/31/goldman-…
Trey Rawles retweeted
how do we pay for cures? the @CMSGov Cell and Gene Therapy (CGT) Access Model published an update this morning.
the program will be launching outcomes-based pricing agreements between states and manufacturers with an initial focus on Sickle Cell Disease (SCD). this selection comes weeks after recent approvals – Casgevy by @CRISPRTherapeutics and @VertexPharma and Lyfgenia by @bluebirdbio – and acknowledges that ~50% of patients with SCD are enrolled in Medicaid.
launching in January 2025, this voluntary model will help manufactures and government payers interrogate whether outcomes-based agreements for cell and gene therapies improves access to curative therapies, improves health outcomes, and reduces cost. CMS will provide both technical and financial support for participating states. as a voluntary model, state engagement will be key.
while I don't expect this model to be a silver bullet, I'm optimistic that we'll learn a lot about the feasibility of outcomes-based agreements for novel therapies and come one step closer to understanding sustainable mechanisms for paying for cures. we'll also learn how outcomes-based pricing models impact incentive structures for biotech innovation.
especially excited to see that the model considers coverage of ancillary services that are critical for SCD patients undergoing gene therapy, such as fertility preservation (post-myeloablative chemo), travel, and behavioral health.
if you're interested in this area – specifically working on building technology/services infrastructure for curative therapies, developing them, or pursuing research in this field – I'd love to hear from you!
Trey Rawles retweeted
One day we’re going to learn that we could have funded multiple moon bases by now if it wasn’t for all the fraud and waste.
Trey Rawles retweeted
I went through the different categories of potential fraud in my previous post, and dug out dozens more providers with suspicious billing.
The total amount of potential improper payments, across just these providers, is $3.5B!
@DOGE_HHS published a dataset with billing activity for every Medicaid provider; 227 million rows, from 2018 to 2024. I cross-referenced it against the federal NPPES provider registry and @OIGatHHS's exclusion list, and started looking for fraud. It didn't take long to find providers banned for fraud still collecting payments a decade later. Brand-new entities billing $170 million in their first 18 months. A lab that went from 73 claims to 48,000 in a single month. Here are five cases:
1. We Care Transportation, a Kansas transport company, was excluded from federal healthcare programs in January 2010. Their NPI was never deactivated. They kept billing Medicaid for another ten years, collecting $4.4 million through July 2020. As of today, their NPI is still active and their exclusion has not been lifted. They're one of 13 excluded providers in the dataset who continued billing after being banned -- $7.3 million in payments that were improper by definition.
2. Fishing Point Health Care LLC registered in Virginia as a "General Practice" in February 2023. Eighteen months later it had billed Medicaid $170 million, almost all of it on a single attendant care code (S5121). Claims went from 1,213 per month to over 10,000. Toward the end of 2024, it started tacking on ancillary codes -- labs, therapy, E&M visits -- which looks a lot like an attempt to make the billing profile seem more legitimate. There are 20 other entities formed since 2022 that have each billed Medicaid more than $50 million, totaling $1.7 billion.
3. Lifeline Biosciences LLC, an Illinois lab formed in early 2022, has exactly four rows in the entire dataset. In August 2023 it billed 73 claims for infectious agent detection. In December, it billed 48,355 -- a 662x increase in one month, good for $7.3 million. The national trend for that same code was flat. Forty-three providers had similar one-month explosions (10x or more, over $1 million) in the post-COVID period, across 48 separate events.
4. New Life Wellness Center LLC in Phoenix was excluded in November 2024 after a fraud conviction. The billing history tells you everything: 25 patients and $280,000 a month in mid-2021, ramping to 273 patients and $8.7 million a month by March 2023 across 14 behavioral health codes. Community mental health claims alone went from 125 to 5,603 in five months, then billing stopped abruptly. More than 4,200 behavioral health providers in the dataset have a similar growth curve -- peak monthly claims at least five times their trough, with total billing above $5 million -- a $98 billion pool that could use a closer look.
5. C&C Mental and Family Services, a Florida entity formed in April 2023, billed $3.6 million on a single code: H2019, therapeutic behavioral services. The monthly volumes make no sense -- 1,180 claims in October 2023, 804 in February 2024, then 34,760 in July. That's a 43x swing against a flat national trend, which is not what a real clinic's patient load looks like. Over 1,200 providers on behavioral health, attendant care, or waiver codes have the same kind of volatile billing while topping $1 million in total payments, accounting for $14.9 billion collectively.