October 12, 2016
While the focus continues to be the challenges of using the WaMS system for service authorizations (and there should be some clarification coming out later today), there is another more complicated and comprehensive WaMS issue under discussion. It is the intent of DBHDS that WaMS become the “record” which would contain the ISP and all related information.
Since it is neither reasonable, nor in fact possible, to have the primary health record reside in multiple “locations,” the challenge will be to have duplicate files without duplicate entry. The issues will be significantly different for those with and without electronic health records (EHRs) – our quick survey of earlier this week has shown that only 1/3 of our members use an EHR.
The other issues of concern are continued compliance with the regulations, the ability to produce the documentation when required for audit or under subpoena, good clinical practice in the maintenance of health records, protection of the integrity of the record, and cost of implementation. For everyone there will be some cost associated with revamping current systems, adapting internal processes to a statewide standardized format, staff training, etc. For those with EHRs there will likely be the added cost of adapting the format so that it can be linked.
DBHDS gains some better ability to gather data for compliance reports for DOJ, they also are moving quickly toward “service packages” which had been deferred pending the review of the impact of the new services; we lose a lot in the creativity and innovation which comes with a provider being able to approach the development and construction of a service plan in a way that fits their particular philosophy and clinical strategy! We will monitor very closely now that we are invited participants, along with representatives of two of our VNPP members, in the planning meetings!