You can't price what you can't see
I spent two days inside a hospital-based occupational health program recently. Good clinicians. Real volume. A growing employer book. By every surface measure, a healthy operation.
Then I asked a simple question. What does the program earn? Nobody could tell me.
The revenue was there. It was invisible. Occupational health was folded into the hospital's outpatient ledger, and no one could pull it back out cleanly. Staff identified occ health visits by reading visit-ID prefixes and matching provider names by hand. Lab revenue sat in one bucket with outpatient and outreach, with no way to isolate the occ health share. And the monthly reconciliation didn't tie out. Not once. Charges on the bill didn't match charges in the system, month after month, and the team had built manual workarounds to live with it.
This is the quiet problem in hospital-based programs. The clinical work is solid. The financial picture is a fog. A program you can't see is a program you can't run.
Think about what that fog costs you. You can't set a defensible rate, because you don't know your true cost to deliver. You can't tell margin from leakage. You can't sit down at an employer renewal and justify a price with data. You can't make the staffing case to your own leadership. The program looks fine from the outside while it quietly underearns.
The contract that anchored this book had been priced years ago to build volume. Cost-plus, discounted, never revisited. The commercial work inherited the same logic and never captured the margin it should have. The fee schedule was only the symptom. You cannot fix a fee schedule you cannot isolate.
So separation comes first. Pull occupational health out of the hospital's general buckets. Tag revenue by service line and sub-location. Build a clean program P&L that stands on its own. Only then does a fee schedule mean anything, and only then can you benchmark it against the market instead of against your own cost.
Here is the test for your own program. Can you produce a clean occupational health P&L today. Not an estimate. Not a provider-by-provider guess. A real one. If the answer is no, the dollars are there. You just can't see them yet.
That is what the Executive Diagnostic is built to surface. It maps where occupational health revenue and cost are hiding inside a blended hospital ledger and gives you the separated view you need before you touch a single rate. If you run a hospital-based program, start there.
The access-model conversations keep coming
The direct-to-employer thread I've written about over the past month is still pulling health systems to the table. More reached out this month, and the conversations are getting concrete — staffing, contracting, the economics of standing up an employer front door. I'm working several in parallel right now. As they mature I'll bring the patterns back here, because what these systems are running into is exactly what the readiness work is being built to answer. If you're fielding the same questions inside your own organization, reply and tell me where you stand. I'm building around what members are actually hitting.
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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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
Paper DOT med cards get another reprieve — your job as an examiner didn't change
FMCSA extended the exemption that lets CDL and CLP drivers use a paper Medical Examiner's Certificate as proof of qualification for up to 60 days after issuance. It runs through about October 11, 2026. The reason is plain: the electronic pipeline behind National Registry II still doesn't post reliably across every state, and qualified drivers were getting stranded while their records caught up. Nothing about your obligation as a certified examiner changes. You still transmit results to the National Registry by midnight the next calendar day. Keep issuing the paper certificate too — it's what bridges the gap when the electronic record lags. Eight states still aren't on NRII at all, so know where your drivers are licensed.
→ DOT examiners are working through the NRII transition together in OccNation.
OSHA moves to cut respirator medical evaluations — the window to weigh in is closing
OSHA is advancing a proposal to drop the medical evaluation requirement for certain respirators: filtering facepiece respirators and loose-fitting powered air-purifying respirators. It's part of the agency's broader deregulatory push, now heading to informal public hearings beginning August 19, with the notice-of-intent-to-appear window closing July 6. If it finalizes, the respirator clearances you perform for those device types change, and some of that volume goes away. Whether that reads as relief or a patient-safety concern depends on your program. Worth forming a view before the process closes.
The healthcare workplace-violence standard just slipped — don't wait for it
OSHA's long-anticipated workplace violence prevention standard for healthcare and social services moved to long-term action status. A federal rule isn't coming soon. The exposure didn't move with it. Healthcare workers still absorb the highest rate of workplace-violence injury of any sector, and the General Duty Clause still obligates employers to address a recognized hazard. If you serve healthcare employers — or run a clinic yourself — the absence of a standard is not the absence of a duty. Build the program now.
→ We're developing a healthcare workplace-violence program starter for the Program Design Series — hazard assessment, model policy, and a BERT setup guide. Want it the day it drops? Reply "WPV" and we'll add you to the early-access list.