The American Hospital Association (AHA) and the West Health Institute recently announced the launch of the West Health Accelerator (Accelerator) at AHA’s Health Research & Educational Trust (HRET), a three-year national initiative designed to help hospitals and health systems operationalize and scale proven technologies across care environments. The initiative is supported by a $12 million commitment from West Health Institute and will focus on three priority areas: electronic health record (EHR) optimization, virtual care, and artificial intelligence (AI) utilization and integration.

The announcement addresses a practical challenge for hospitals and health systems: many organizations are testing or adopting technologies that can improve care delivery, quality, safety, and operational performance, but it can be difficult to move those tools from limited pilots to consistent use across the organization. The Accelerator is intended to help close that gap. Participating hospitals and health systems will have access to a digital hub, implementation support, peer-learning opportunities, and examples from hospitals and health systems serving as national models. In other words, the initiative is focused on helping hospitals make the technologies work in real care delivery settings.

Why This Matters

The AHA/West Health announcement is another sign that AI, virtual care, and EHR optimization are moving out of the “innovation project” category and into the day-to-day operations of health care delivery. That shift matters because once technology is embedded in clinical workflows, staffing models, patient communications, documentation practices, triage pathways, and care management programs, it becomes more than an IT initiative. Implementation can raise practical questions about clinical oversight, medical staff governance, professional responsibility, documentation, reimbursement, and compliance infrastructure.

For hospitals and health systems, the key question is no longer only whether a technology works. It is whether the organization can implement the technology safely, consistently, and in a way that aligns with existing health care regulatory requirements.

The Accelerator’s Three Priority Areas

The Accelerator focuses on three areas that are already priorities for many hospitals, but that can be difficult to implement consistently across an organization: EHR optimization, virtual care, and AI utilization and integration.

EHR Optimization

EHR optimization has become both an operational priority and a compliance issue. Hospitals are looking for ways to reduce administrative burden, improve clinical workflows, support earlier identification of patient risk, and make it easier for care teams to act on the right information at the right time. As EHR workflows become more closely integrated with AI-enabled tools, clinical decision support, documentation functions, virtual care platforms, and care management programs, hospitals should assess whether those workflows continue to support integral functions including accurate documentation, appropriate billing, medical record integrity, and clear clinical accountability. This is especially important when technology changes how information is presented to clinicians, how documentation is generated, or how patient needs are escalated. Even when a tool improves efficiency, the hospital still needs a clear process for determining who is responsible for reviewing the information, acting on it, and documenting the clinical decision-making process.

Virtual Care

The Accelerator’s focus on virtual care also reflects the continued evolution of telehealth from an access tool to a broader care delivery and staffing strategy. For hospitals and health systems, virtual care may include telehealth visits, virtual nursing, centralized care teams, specialist consults, remote monitoring, and hybrid care models. These models can help expand capacity, support staffing flexibility, and improve access, but they also need to be structured carefully. Scaling virtual care requires more than selecting a platform. Hospitals need workflows that are clinically appropriate, operationally sustainable, and compliant across the states and care settings in which patients and clinicians are located.

Artificial Intelligence Utilization and Integration

The Accelerator’s AI focus is notable because it is framed around utilization and integration, not just experimentation. In hospital settings, AI tools may support a range of functions, including clinical workflow support, documentation, risk identification, operational efficiency, and care team coordination. The regulatory analysis depends less on the fact that a tool uses AI and more on how the tool is used, what role it plays in the care delivery process, and who remains responsible for clinical judgment. An AI tool that supports an administrative workflow raises different regulatory issues than a tool that influences clinical decision-making, generates clinical documentation, prioritizes patient outreach, recommends next steps, or communicates information to patients or care teams. Hospitals should classify AI-enabled tools by use case and risk level, then align oversight, documentation, monitoring, and escalation processes accordingly.

From Pilots to Systemwide Practice

A similar implementation challenge applies beyond the Accelerator. For many hospitals, the difficult step is not identifying a promising technology-enabled use case but moving that use case from a limited pilot to a workflow that can operate consistently across the organization.

Many hospitals are already testing or using AI-enabled tools, virtual care models, remote monitoring programs, or EHR-enabled interventions in limited settings. Those pilots can be useful, but broader implementation is different. A pilot may be managed through a narrow protocol, limited users, and close operational oversight. Systemwide implementation requires a more formal framework, including policies, governance, training, escalation pathways, documentation standards, medical staff involvement, billing review, and ongoing monitoring.

A workflow that is appropriate for a small pilot may not be sufficient once the same technology is deployed across multiple service lines, facilities, or patient populations. As hospitals move from pilots to broader implementation, legal and compliance teams should be involved early enough to help design a scalable model, not just review issues after the technology is already in use.

Regulatory Questions Hospitals Should Ask Before Scaling

Hospitals and health systems evaluating AI, virtual care, and EHR-enabled tools should consider several threshold questions before moving from pilot programs to broader implementation. These questions should be addressed early in the implementation process, rather than after the workflow is already live.

1. Who is furnishing the service?

Hospitals should determine whether the technology changes which clinicians or care team members are involved in furnishing the service. For example, a virtual nursing model, centralized monitoring program, or AI-supported triage workflow may involve different personnel than the hospital’s traditional in-person workflow. That can raise questions about licensure, scope of practice, supervision, delegation, credentialing, privileging, and medical staff oversight.

2. Where are the patient and clinician located?

For virtual care models, patient and clinician location remain central regulatory questions. Hospitals should evaluate whether clinicians are appropriately licensed or otherwise authorized to furnish services to patients in the states where the patients are located. This is especially important for centralized or cross-state virtual care models. Hospitals should also consider state-specific virtual care requirements.

3. How is the workflow documented?

Hospitals should confirm that the medical record accurately reflects the care furnished, the individuals involved, the information reviewed, and the clinical decisions made. If technology generates summaries, prompts, alerts, draft notes, risk scores, or recommended actions, hospitals should determine whether and how those outputs are incorporated into the medical record and who is responsible for reviewing them.

4. How is the service billed?

Technology-enabled workflows can affect coding, billing, and reimbursement. Hospitals should evaluate whether the workflow supports the requirements for the service being billed, including any applicable requirements related to clinician involvement, supervision, time, documentation, patient consent, or location of service, and payor-specific coverage or billing rules.

5. Who reviews and acts on technology-generated information?

Hospitals should clearly define who is responsible for reviewing alerts, summaries, escalations, or recommendations generated through AI-enabled tools, EHR workflows, remote monitoring platforms, or virtual care programs. If a workflow generates information that requires clinical action, the hospital should have a clear process for review, escalation, documentation, and follow-up.

6. Does the workflow require medical staff or committee review?

Some technology-enabled workflows may require review through medical staff, clinical leadership, quality, compliance, IT, or other governance channels, particularly if the tool affects clinical decision-making, patient safety, documentation, or care delivery responsibilities. Hospitals should consider whether existing committees and policies are sufficient or whether additional review processes are needed for AI-enabled or virtual care workflows.

Looking Ahead

The AHA/West Health Accelerator reflects the continued push to move AI, virtual care, and EHR-enabled tools from limited pilots into broader operational use. For hospitals and health systems, broader implementation of these tools creates an opportunity to improve quality, safety, efficiency, and access. It also underscores the need for practical regulatory planning. As these tools become part of day-to-day care delivery, hospitals should be prepared to show not only that the technology works, but that it is being implemented consistently and with appropriate clinical and operational oversight. Hospitals should also build regulatory review into the implementation plan, with clear accountability for clinical review, documentation, billing, escalation, and ongoing monitoring.

Foley is here to help you address the short- and long-term impacts in the wake of regulatory changes. We have the resources to help you navigate these and other important legal considerations related to business operations and industry-specific issues. Please reach out to the authors, your Foley relationship partner, our Health Care & Life Sciences Sector, or to our Health Care Practice Group with any questions.