The impact of changing requirements and how to maximize business efficiency through them
The governance of health care is an ongoing process. Newly elected officials may bring widespread change, lawmakers revise existing regulation, and new knowledge and technology challenge us to rethink old paradigms. In short, federal and state healthcare mandates are always changing.
Even private behavioral health practices that aren’t tied to public funds are subjected to regulatory changes from time to time. Adapting to new standards or regulations can always have a disruptive impact on any organization, which is why it is so important for practices to ask themselves what kind of changes might affect them and how they can best manage the transition toward compliance.
Private practices will recall some of the more notable regulatory changes that have happened in recent healthcare history. For example, October 2015 was the deadline for ICD-10 implementation. Updating the coding standards for symptoms and diagnoses affected all healthcare settings, specialties, and record keeping systems, including the EHR and practice management software into which ICD-9 codes had been input. Most practices, billers, and payers were further challenged to maintain both sets of coding standards until all old accounts were closed out and the insurance industry transition was complete.
In 2015 Valant published an ICD-10 cheat sheet specific to behavioral health care, which can be found here.
Regulatory changes can also come from the state level, as demonstrated this past March in the state of New York. The Internet System for Tracking Over-Prescribing (I-STOP) program was designed to mitigate the growing “drug shopping” problem by requiring prescribers and pharmacies to adopt electronic prescribing systems, prompting organizations to make room in their budgets for eRx software or risk being in violation of New York Public Health Law.
Private behavioral health practices should expect new regulatory changes to roll out on an ongoing basis. Compliance will always be disruptive to the regular ebb and flow of business, but can be manageable when handled properly.
Stick with a proactive vendor
When a new round of regulation rolls out, how quickly does your EHR or billing software vendor make a compliant release available? Software development takes time, so a reliable vendor will stay ahead of impending regulatory changes and produce timely solutions.
Practice owners should always be mindful of current, upcoming, and ongoing regulatory developments. Having an idea of what to expect will help your practice plan for (and in some cases, budget for) the regulatory changes that affect it. Centers for Medicare and Medicaid Services (CMS) routinely publishes proposals outlining the details and deadlines of upcoming regulatory guidance, and keeping abreast with such publications is a great way to prevent unpleasant surprises.
Don’t actually change anything until the final ruling
CMS proposals usually go through a series of vetting and revision in collaboration with healthcare communities and associations. The goal of the process is to improve population health without overcomplicating the daily life of providers and staff, so the conversation will likely pass through several iterations before arriving on a final ruling. Don’t fall into the trap of investing into a new system or adjusting workflows only to find out the requirements have changed again. Practices should keep doing what they’re doing until the final ruling is published.
Expect last-minute revisions and delays
If recent examples in history are to be considered a reflection of what will come, practices can reasonably expect regulatory bodies to make last minute revisions and delays of proposed regulatory changes. ICD-10, I-STOP, and Meaningful Use, for example, were a few instances where the implementation date was pushed back an entire year (or longer). Unforeseen problems are likely to occur whenever legislation and technology intersect. Practices will need to account for the likeliness of last-minute revisions and delays when preparing for the next round of regulatory changes.
Change is inevitable in health care, but practices can still have a say over what happens. CMS has generally accounted for the concerns of healthcare communities and associations in the past, often relying on the feedback of providers to get legislation where it needs to be. Practices that wish to participate in the discussion should consider joining an association.
Having to respond to regulatory mandates will always be a challenge for private behavioral health practices, particularly when taking this industry’s inclination toward ongoing change into account. Taking a proactive approach to awareness and preparation will result in easier adjustment to new requirements and a less disruptive experience overall.
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