Behavioral Health EHR: Dream or Reality, Obstacle or Asset

Last month I wrote an article about movement toward Electronic Health Records (EHR) in the behavioral health community. I was stunned by your silence on the issue. So much of my energy for the past two years has been focused on EHRs, their use in general medicine and in mental health, that I was very surprised that our readers were not interested in discussing EHRs. I am not sure whether the booming silence was a reflection of denial about movement toward these products, lack of information about them, or some other factors. So let’s start with some information.

In May, 2003 the President’s New Freedom Commission on Mental Health reported that the mental health community has been much slower to adopt Electronic Medical Records than the general medical community in spite of the potential benefit for consumers being just as great. The Commission concluded that a substantial effort should be made to develop the infrastructure to support interoperable electronic medical records and personal health records, and that the behavioral health community should move forward with adoption of appropriate products.

Early in 2006, a SAMHSA (Substance Abuse and Mental Health Services Administration)-funded Behavioral Health EHR Profile Workgroup, a multi-stakeholder effort to develop an EHR Conformance Profile for behavioral health began work. I joined that workgroup early in 2007 and participated through the adoption of a standard for Behavioral Health EHRs by HL7 this past summer. The Certification Commission for Healthcare Information Technology (CCHIT) has formed the necessary workgroup to develop testing and certification standards for Behavioral Health EHRs and plans to begin such certification by summer 2010.

The thinking about EHRs and their benefit are multiple. Primarily, they are believed to improve the quality of care by minimizing errors and duplication, by providing decision support for the provider, by offering evidence-based practice options, and by making all that information available rapidly to other providers. Adding Personal Health Records (PHRs) into the mix and connecting everything by way of a National Health Information Network (NHIN) or Health Information Exchanges (HIEs) will provide real-time information access for both consumers and providers of health care services.

The election of Barack Obama has spurred lots of discussion about the direction that healthcare reform will take. He mentioned electronic medical records in speeches and debates, but there is not yet much information about how he will pursue policy in that arena. The current financial crisis and recession will undoubtedly take priority over healthcare reform, but the cost of healthcare makes it a pressing issue for everyone.

I have heard providers talk about EHRs in widely varied ways. Some (including some of our customers) have used software products to maintain their clinical records for years and would not want to practice without one. Some clinicians believe that such a product would create obstacles to best care of their clients. Others are concerned about workflow interruption and the amount of time it might take to utilize an EHR. And those of us who work in the industry and are clinicians by training have major concern about privacy and security of health records generally and EHRs in particular.

What are your thoughts about EHRs? Do you see them becoming a part of the picture for your organization? Do you have a plan for purchase of such a product? Do you already use an EHR? How well does it do the job for you? Please let us know your thoughts. What providers think and how they plan to behave will control how this all unfolds.

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Thanks for your thoughts.

The Indispensible Data Backup

We were recently told by the IT person for an organization that had six weeks earlier lost all their data, that backing up was not a priority. Yes, they were having the same problem again. No, they did not have a good backup. They had needed to get up and running again and that took priority over getting a backup system in place. We were flabbergasted. They had just paid us to recover their database because they did not have a backup from which they could restore…yet backing up was not a priority.

On a regular basis, we are confronted by a customer organization that has a catastrophic event resulting in the loss of their entire SOS database including all of their practice management information…patient billing, clinical records, schedules. Some of the events have been a hurricane, a fire, or a crash of the computer causing irreversible corruption of the data. In the case where the customer has regularly been following our recommendations for data backup including verification and off-site storage, they merely retrieve their most recent backup, restore it to their computer in the appropriate folder, and pick up their work where they left off.

In all too many instances, that is not what happens. In some cases, the customer has not been creating backups of their data at all! In many others, they have been writing over the same single copy of their backup over and over again. If their hard drive fails in a progressive manner becoming flakier as it goes, their database becomes corrupted in the same gradual manner and their lone backup becomes as unusable as their corrupted database. Sometimes, they make their backup onto a partition of the drive on which their production database resides. When the main one goes, so does the backup. And quite often, they make backups regularly, one tape for each day, but they never verify that the backup can be restored. 

We have created documents, newsletter articles, email rants and verbal tirades trying to communicate the absolute necessity of having excellent backup procedures that are followed without fail and that produce reliable, verifiable backups of all necessary data. This information is certainly effectively used by many of our customers, but we do not seem to be successful at reaching others.

We need help understanding how folks think about data backup so we can more effectively assure that it occurs. How does an organization justify not making and verifying a backup of their mission critical data? What are the “reasons” that get used? If your company does not do data backup, what are the obstacles to doing so and how do you rationalize not removing the roadblocks? What can we and other software companies do to assure that backup happens? What have you done to assure that data backup works effectively in your organization? If you “got religion” about backup at some point, what triggered the change?

Talk to us, please. We need your assistance here.

Thanks!

E-prescribing and a Behavioral Health EHR: Where to from here?

For the past several years Synergistic Office Solutions, Inc. has had the privilege and pleasure of participating as a member of the Software and Technology Vendor Association (SATVA), a group of vendors of software and other technology for the Behavioral Health and Social Services community. Last Thursday, I returned from our semi-annual member meeting…charged up with information about what is happening in the behavioral health world and full of questions about how all of the current events will impact SOS and our customers.

Standards for Electronic Health Records (EHR) for Behavioral Health were our primary discussion topic at this meeting. The community mental health world has long known that they will need to use EHRs to maximize the efficiency of their services and document the effectiveness of their treatments. State reporting requirements alone make use of an EHR a worthwhile way to simplify the lives of clinicians and administrators. Psychologists and psychiatrists in the private practice community have been slower to embrace the idea that electronic clinical records will improve care. The cost of the product and the time it takes to learn and use such software has been an obstacle for many organizations. While our mental health clinical record software has been around since 1992, we have many fewer users of that product than of our billing software.

Some states and payers are rapidly moving toward mandates for implementation of aspects of an EHR. FierceHealthIT, a newsletter for those working in information technology for health care, reported last week that MA BCBS will be requiring e-prescribing by January 1, 2011 for physicians who participate in their incentives program. The Centers for Medicare and Medicaid Services (CMS) has developed an electronic prescribing incentive that will increase physician reimbursement by 4.5% by 2014 for those who use qualified electronic prescribing products. The National Governor’s Association (NGA) has provided a forum and support for states to move forward on Health Information Exchange (HIE), electronic prescribing and computerized physician order entry (CPOE) . At the federal level, a public-private partnership has been formed in the AHIC Successor, Inc. to move forward the process of developing a National Health Information Network (NHIN); and the Certification Commission for Healthcare Information Technology (CCHIT) has formed the necessary work group to certify a Behavioral Health EHR.

While the names and acronyms of these bodies may be new to many of you, they are working hard to assure that interoperable EHRs are widely implemented by 2014. Many in the industry consider this an unrealistic goal date for such comprehensive change, but many entities are dedicated to seeing successful adoption of this technology in the not very distant future.

How will the requirement for health care providers to utilize EHRs affect psychologists, psychiatrists and social workers in private practice? Will the expectations be different for private care providers than for behavioral health providers in a community setting? How do you expect these changes to affect your organization? Are you already using an EHR? Let’s talk about where you see this going in your world.

Mental Health Billing and the ICD-10

Back in August, the U.S. Department of Health and Human Services (HHS) posted a proposed rule requiring the implementation of the portion of HIPAA that mandates use of the ICD-10 by October 2011. The International Classification of Diseases-10 was endorsed by the 43rd World Health Assembly in 1990 and was implemented by many World Health Organization (WHO) member states as early as 1994. The United States is 14 years behind the curve on use of this updated version of the ICD, the list of diagnoses used in all medical billing. As more healthcare organizations implement electronic medical records (EMRs) ICD diagnostic codes are used ever more widely, but at present payment for health services is still the most important function of these codes in the U.S.

There was an immediate outcry from provider and payer organizations that the 2011 date was too soon. The Medical Group Management Association, the American Medical Association and America’s Health Insurance Plans registered objections with HHS over the implementation date indicating that the costs would be too great for providers and payers, especially given the recently completed and very costly implementation of the NPI (National Provider Identifier).  But now, the American Hospital Association has supported the 2011 date suggesting that the potential gains from use of the ICD-10 are too great to wait any longer to implement the new codes.

We know the pain that has been experienced by customers of Synergistic Office Solutions in adopting the NPI and continuing to get paid for services rendered. Our software has been able to handle the NPI since early 2007, but some of our customers still struggle with the confusion caused by this transition.  While software can be made ready for the ICD-10 without very much difficulty, we are concerned about how this change will be handled in the real world by psychologists and psychiatrists and social workers who are accustomed to using the DSM-IV and ICD-9 for diagnoses for mental health conditions.

What do you think about a move to ICD-10? Do you expect this next round of changes required by HIPAA to be simple? to be problematic? What do you expect the impact will be for your organization and how do you plan to handle it? What is the best way for vendors of mental health billing software and medical billing software, medical EMRs and behavioral health EMRs to assist providers in implementing the new ICD-10 codes? Let us know what you think. We want to help make this new transition as smooth as possible.

HIPAA Privacy Rule: Communicating with Family and Friends

New guidance about communicating with a patient’s family, friends or caretakers was released by the U.S. Department of Health and Human Services, Office of Civil Rights. This is the office entrusted with education about and enforcement of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule. They have created two documents which lay out details about sharing information about a patient, one for providers of care and one for patients or consumers of care.

 

As I read these two documents, I found myself recalling my internship training in a Community Mental Health Center. We were clearly instructed that we were not even to acknowledge that a person was a client of the Center if someone telephoned about them. Family or friends accompanying them to their visit were not invited into the session unless the patient asked that they be included. Even minor adolescents and children were granted the privacy of the therapy session unless a clear agreement including parents or caretakers was reached. Obviously, the therapeutic relationship in the behavioral health field is a more sensitive matter than in many physical health settings. My experience is that mental health providers have always been more concerned and responsible about securing a patient/client/consumer’s privacy than anyone providing physical health care I have ever met.

 

In this electronic world in which we live, I have seen some of that care diminished; and we have begun to bump into this matter in technical support at SOS. HIPAA provides that a Covered Entity (a health care provider who electronically transmits certain transactions including electronic claims) must assure the security and privacy of their patient information. It also requires that Covered Entities educate people and organizations who provide services to them about the necessity of protecting the health information of their patients. In fact, it requires that Covered Entities maintain a Business Associate Agreement (BAA) with each person or organization with whom they do business who might in the course of doing business be exposed to the Protected Health Information (PHI) of their clients. If you have any doubt about whether you are, or are not, a Covered Entity, it would seem prudent to assume that you are and to execute a BAA with anyone to whom you reveal PHI.

 

When implementation of the Privacy Rule was first mandated in April 2003, we were asked to execute BAA’s by a very small proportion of our customers. During the five years since then, we have almost never been asked to sign such a document. Since service to our customers is a big part of who we are, we have made available a BAA that makes it very easy for a Covered Entity to assure that SOS is handling their data in an appropriate fashion if we ever have access to it (http://www.sosoft.com/fod/doc105-sosbaa.pdf ). Even given the ease of accomplishing this agreement, we still have difficulty getting provider organizations to do so.

 

What is your take on the HIPAA Privacy Rule and how it is implemented in your organization? Were you on top of this in 2003 and 2004 but not as likely to educate staff and your computer and software vendors in 2008? Do you see a difference between how psychology, psychiatry and other behavioral health organizations handle the Privacy Rule and how physical health providers do so? Has the rule kept you from filing your claims electronically so you would not become a Covered Entity?