The growth nobody had mapped
I spent two days this month inside a health system's occupational health program. A full operational assessment — every function, end to end. Executive strategy, clinical workflows, staffing, the employer book, billing, referrals, return-to-work, the EHR migration (to EPIC, including the Occmed module). We looked at all of it.
An assessment earns its keep two ways. It shows you where you're losing ground. And it shows you where the program could grow. This program was already strong in the fundamentals — strong occmed boarded medical director, ortho access was solid, the clinical team was capable. So the more valuable work was the second part: the growth sitting there unused.
It clustered fast. The program was running episodic injury care well and leaving most of its potential on the table. Five openings stood out:
Employee wellness — for the system's own workforce, and as a service their employer clients are already asking them to provide.
Injury management run as a managed program — one that owns the case from first report through return-to-work, instead of a string of disconnected visits. A newly hired nurse case manager will faciliate this program.
Advanced surveillance exams — the complex medical surveillance most urgent care programs refer out or skip. A highly skilled medical director makes this an easy sell.
IMEs and medico-legal work — a high-margin line the program was fully qualified to do and wasn't doing. Again, qualified medical director, experienced in disability exams, not filled with cases in this newer role.
Advanced primary care strategies — the on-ramp to the direct-to-employer conversation so many systems are now having.
Of those five, advanced primary care is the one already under pressure. Well-capitalized national vendors are selling APC straight to employers in your market, and they're winning business a few miles from health systems that could deliver it better.
I laid out the full case this week — why the downstream economics, the urgent care and occ-med footprint, and the Total Worker Health bridge all sit on the health system's side of the table, and the five gaps you have to close to win.
We ran their local market through Market Analyzer to see which of these service lines the surrounding employer base would actually buy. That turned a list of ideas into a ranked, market-sized opportunity.
Here's the thread tying all five together: every one is a Total Worker Health® play. Each moves the program from treating injuries to managing the whole worker — physical health, the work environment, and the conditions that shape both. That's where employers are spending. That's where the margin is. And it's a role a hospital-based occupational health program is positioned to own better than any standalone clinic.
The point for you: this program wasn't unusual. Most occupational health programs are sitting on the same untapped capacity. They're so busy running the front door that no one has stepped back to map what the program could become. A structured assessment does exactly that — it makes the opportunity visible and puts it in priority order.
That's the work. If you want to look at your own program the same way — what you run well, what you're leaving on the table, and what your local market would actually buy — reply to this email and let's talk. Or go ahead and book a call here.
Larry Earl, MD
President, NAOHP
The core provider actions, the Dashboard domains, and the clinical decision standards behind them are the curriculum of the OccMed Providers Course —
If your providers are the ones making the calls that drive your employer outcomes, this is the program built for them.
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🫂 2026 conference plans - last chance to give us your preferences
We're gauging interest in a conference this fall (a Thursday evening through Saturday in mid-October to early November, likely in the midwest, possibly Ohio).
Please answer below—this is not a commitment to register, just a read on interest.
Purpose Built Occupational Health EMR
🗓 Upcoming Events
Prove Your Value: Hardwiring Client Communication & ROI in Occ Med
Client communication is essential to a successful Occ Med program.
How timely and thorough is your communication process?
Does your EMR assist you in that process?
Can you demonstrate a value/ROI to your clients?
Becoming a Safety Leader in Healthcare
The Expanding Role of the Nurse in Health Care Safety
Goal: Master the evolving intersection of occupational health and safety leadership.
Key Topics:
• Shifting expectations of OHNs: from clinical care to system safety oversight.
• Understanding the dual lens of employee and patient safety.
• Introduction to Total Worker Health® principles in hospital settings.
• The business case for nurse-led safety programs (ROI, risk reduction, engagement).
Target Audience:
Registered Nurses, Occupational Health Nurses, and Employee Health professionals transitioning into or expanding safety leadership roles in healthcare systems.
Free Intro Class:
Speaker: Shanna Dunbar
The first cohort for the full course is coming this fall.
Recent Events:
🏭 Occupational Health Industry News & Signals
Heat enforcement now comes with a checklist
The federal heat standard is stalled. The post-hearing comment period closed in October 2025, no finalization date is set, and it isn't a current administration priority. Enforcement is where the movement is. The original Heat NEP expired April 8, 2026 and was replaced two days later with a revised, expanded program that runs through April 2031. Two new appendices are the part that matters: one gives inspectors a checklist for evaluating an employer's heat plan, the other is citation guidance, and the program targets 55 industries. Your employer clients will now be measured against a defined list — water, rest, shade, acclimatization, training, a written plan. You can get them there before an inspector does. AlertMedia + 2
The HazCom clock is now the employer's
The first GHS Revision 7 deadline passed May 19 — manufacturers and importers had to reclassify substances and reissue safety data sheets and labels. That hands the next deadline to employers. By November 20, 2026, every employer using covered chemicals has to update workplace labels, revise the written HazCom program, and retrain workers on the new classifications. Updated SDSs are landing on desks now, which is the trigger to start. The extended dates are firm, not a grace period, and serious violations run over $16,000 each — on a standard that sits perennially among OSHA's most-cited. Workplacecomplianceinsights + 2
NIOSH puts chronic disease inside the occ health mandate
In February 2026, NIOSH Director John Howard published a science bulletin, Total Worker Health and Chronic Disease at Work, with a companion paper in the American Journal of Industrial Medicine laying out the evidence. The argument is direct: chronic disease management is core occupational health work and belongs inside the program. The bulletin's central point is that personal risk factors and workplace exposures are usually assessed separately, which misses how they compound — a worker with cardiovascular disease who also performs forceful, repetitive work carries more combined musculoskeletal risk than either factor alone. That is the national case for exactly the kind of integrated program expansion in today's lead. WorkplacecomplianceinsightsWorkplacecomplianceinsights